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Wednesday, January 30, 2008

Home alone

I just got notification that the "Apply Online" section of the SLD Web site will be unavailable from midnight Friday until 6:00 am Saturday. I am bereft. That section of the Web site is my constant companion this week. If I try to sleep, I'm sure I'll have nightmares. Oh sure, I can distract myself for a little while by trying to find more rules that I've never heard of, or enjoy the whimsy of putting in a common keyword in the "Search" box and seeing what useless pages come up, or ponder things like who is that little girl in the USAC banner, and what is she working on.

But it just isn't the same as that rush of fear I still get from hitting the Submit button, wondering if I've made an error. Yes, I've submitted thousands of forms with no problem, and the forms are double-checked, and Bishop Perry means I get a second chance on almost everything, but the fear is still there.

Tuesday, January 29, 2008

Let's do the Time Warp

Here's a fun appeal: the applicant admits that it had no contract when it submitted the 471 on Feb. 8th, but then signed a contract Feb. 13th, but with an effective date of Feb. 7th. Their lawyer says that the contract is effective Feb. 7th.

It's like a trippy Star Trek episode. When we signed the 471, we didn't have a contract, but by the time PIA review rolled around, we had a contract which existed before the 471 was filed.

To avoid situations like this in the future, the FCC should stop requiring applicants to have a binding contract before filing the 471. Forcing applicants to set a service provider, equipment models and prices 6-18 months before installation results in less cost-effective solutions.

What to do?

Do what we all do when we're making up budgets for the next fiscal year. Get quotes from vendors and set the expected cost based on that. Then sign a contract when it's time to start the project, and send the details of the project then. The current contracting set-up just drives up the cost of the program.

Wednesday, January 23, 2008

Am I blue

I got my first batch of "Notification of Form 470 Posted but No Associated Form 471" letters. I have nothing but gripes about this letter.

Those of you who have been reading this blog can guess the first one: I am saddened to see a letter on blue paper inside a white envelope. As I keep saying, envelopes should be color-coded. Actually, the smaller envelope size makes the blue peeking through less pitiful, but in Sept./Oct., when letters for 3 funding years are flying around, it would be nice to have colored envelopes.

And who came up with that catchy title? If I were going to make a parody of a USAC letter, it would have a title like that. How about calling it the "Missing 471" letter? Even more accurate, give it the title: "Useless Notification: File Without Reading."

I read somewhere that they sent out 26,000 of these things. I'll bet 25,000 of the letters went to applicants who were not allowed to submit the Form 471 yet, since their Form 470 had not been submitted by December 20th, 28 days before the letters went out. I'm all for USAC communicating more, but this letter communicates nothing for most applicants.

The letter is a response to the FCC's instructions in Paragraph 24 of the Bishop Perry Order: "USAC shall also develop a more targeted outreach program and educational efforts to inform and enlighten applicants on the various application requirements.... USAC should also notify applicants that have filed an FCC Form 470, but have failed to file an FCC Form 471 or its certification by the close of the filing window." Let's see:
  • Targeted: Uh, according to a recent white paper from Funds for Learning, there are about 23,000 applicants each year. 26,000 letters to 23,000 applicants is "targeted"? Strike One!
  • "Failed to the close of the filing window": This letter does not notify applicants that they have failed to file by the close of the window. It notifies us that we have failed to file an application 21 days before the close of the window, and in most cases before we're allowed to file. Strike Two!
  • The FCC never said anything about using paper. It galls me to get two sheets of paper and a non-color-coordinated envelope telling me nothing new. Email me. Strike Three!

This letter should be dejectedly dragging its bat back to the dugout.

Friday, January 18, 2008

Please Mr. Postman

Two disappointing missives from USAC yesterday.

I got my first letter with the new mail regime: a BEAR Notification Letter with a 3-hole punch, folded in the middle. John Noran announced the change to the new format back in the fall trainings. I have no problem with the middle fold, and the holes are no skin off my nose (though I don't see myself moving to binders). The environmentalist in me likes the printing on both sides, but my office copier won't handle two-sided originals automatically, so I foresee some cursing later.

But where is the color? Why aren't BEAR Notifications color-coded like everything else? I am a big fan of the colors, especially the yellow. It's so nice to be able to look into a folder and find all correspondence from USAC instantly. All correspondence except BEAR Notifications, that is. (Well, there are other letters that come on white paper, but they're non-standard enough that I can live with it.)

And I got a couple of revised FCDLs on yellow paper, but in white envelopes. I miss the colored envelopes. That little bit of yellow peeking out of the envelope windows just looks a little forlorn. Bring back the color!

Wednesday, January 16, 2008

Giant timing problem

OK, back when in October when the filing window was set, I didn't dare hope that the Giants would even make the playoffs, but now that they have a chance at the SuperBowl, I have to ask: who sets a major deadline so soon after Super Bowl Sunday?

Oh, wait, I get it: Redskins fans. The Washingtonians at the FCC and USAC can always count on not having anything to do that Sunday.

Wednesday, January 09, 2008

Where's my fake moustache?

So the Operations Support Services contract for E-Rate (and Rural Health Care) is going out to bid. This is the contract that USAC currently has with Solix to handle paperwork, do PIA and run the Client Service Bureau.

You've got to figure Solix will win again, especially since the first priority mentioned in the RFP is "continuous ... client service delivery without any disruption " (wisely, USAC is not making price the primary factor). But imagine if they didn't. The contractor has to supply the buildings, so we might have all new addresses for forms, extension requests, etc. The Client Service Bureau phone number could change, too.

I want to bid on this thing. Not because I want to win (can you imagine being PIA?), but because on January 24th, there will be "demonstrations of application and invoice processing." I have been jonesing for a peek behind the curtain. It would just make my communication with PIA so much more effective if I knew what my clients' applications look like to them. Alas, only pre-qualified bidders are allowed in, and from the looks of the pre-qualification questionnaire, they're not going to pre-qualify consultants. Cue the Mission Impossible music....

Saturday, January 05, 2008

A late Xmas present.

When I went got my mail today, my heart sank. There was a new shape of missive from USAC: a standard letter-sized window envelope. A different form factor is usually bad news: either USAC has dreamed up a new way to scrutinize an application, or one of my clients has come under unusual scrutiny. But not this time.

When I opened the envelopes, I found a late Christmas present: quarterly payment authorization reports!

Those of you who are not consultants may not understand my glee, so I'll explain. Every quarter, USAC prints a report of all disbursements for each applicant, and mails it to the applicant. That's a good idea, since it gives applicants a chance to spot service providers who are not forwarding disbursements. The problem is that the reports are sent to the Billed Entity's address, to no person in particular. So at a typical school district, they bounce around like Pachinko balls until they either get to the E-Rate person, or go into the trash. That's bad for me as a consultant, since I'm not even in that Pachinko machine. Now, the letter comes straight to me. Excellent!

Just goes to show you, you gotta believe. That Santa at the mall looked fake to me, but I told him that I wanted Quarterly Payment Authorization Reports mailed straight to me, and here we are. I wonder if I'll get the changes to the Eligible Services List I asked for....