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Thursday, October 04, 2007

Tech plan debacle

As I mentioned in my previous post, I took a look at the report for the E-Rate that the FCC Inspector General did as part of an analysis of audit results. The IG singled out the number of failures due to tech planning. I hope that will make the FCC rethink its rules on tech planning. I have two alternatives for fixing the problem.

Alternative #1: Scrap the tech planning requirement. Mandatory tech planning is like mandatory sensitivity training; the people who need it are just going through the motions. Most of these tech plans are dusted off every 3 years, renewed, then put back on the shelf. We can argue about the merits of a long-term plan vs. a flexible response to changing needs and costs, and maybe schools would benefit from more planning, but it's certain that if a tech plan is done only to satisfy outsiders, it's useless.

Alternative #2: USAC should run an online tech plan tool. The tool should create a much clearer idea of what the tech plan should be, and automate creation and maintenance of the plan. I know the PA Dept. of Ed has done this with their eTechPlanner, and Kellogg & Sovereign created an online tech plan creator for their clients (and has made it available to others). A tech plan tool from USAC could go further in forcing applicants to report progress on completing the plan and to update the plan. Also, if USAC were running the tool, if an applicant tried to file a Form 470 for a period or category of service that was not covered by the tech plan, the applicant could get a warning.

I know that many people would be reluctant to turn the tech plan into basically another form to be filled out, but here's my attitude: USAC and the FCC have certain requirements when it comes to tech plans (incidentally, the IG report points out that those requirements clashed when it comes to tech planning). A well-designed form clearly lays out expectations, and makes it more difficult to inadvertently fail to meet requirements. Turning the tech plan into a form wouldn't create new rules or add complexity, it would bring the existing rules and complexity out into the open.

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