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Saturday, May 31, 2008

BMIC: Better Mail In the Contract

Well, one change in the 700-page tome of secret PIA rules has become obvious: so far this year, 100% of the time I have been asked to produce a contract for FRNs for Basic Maintenance. So if you haven't hit PIA yet and you have a Basic Maintenance FRN, you might as well send in the contract with your Item 21 Attachment. And, of course, "The agreement or contract must specifically identify the eligible components covered, including product name, model number, and location." (From the Eligible Services List.)

I wonder what the difference is between an agreement and a contract? Is it possible that you can get Basic Maintenance funding without a signed contract? I haven't had the cojones to try.

Thursday, May 22, 2008

Doctor's note

Here's a pretty routine appeal with one difference that brought a smile to my face: the appellant actually attached a doctor's note to prove he was in the hospital on February 7, 2008.

Not that a doctor's not is necessary any more. As I've said before, it seems the FCC will remand almost any late filing, even if you provide no excuse.

I wonder if the applicant's spike in blood pressure was due to the E-Rate deadline....

Tuesday, May 20, 2008

It is aLIVE!!

Man, I hate Cost Effectiveness Reviews (CERs). They're just wrong. I was hoping that a series of appeals would make them go away. Alas, the FCC hasn't made any decision on those appeals, and the CER will not die. And it looks like USAC hired Dr. Frankenstein, because someone took the CER and combined it with parts of the Selective Review, and the result is something unholy. Here's what it looks like.

So now in addition to answering all the CER questions, we also have to supply competitive bidding and budget info about *all* the applicants' FRNs. And we still only get 15 days to do it.

So how does one kill Frankenstein's monster? Wooden stake?

Saturday, May 17, 2008

TANSTAAFL on surveys

Why doesn't the FCC just put this issue to bed? Yet another appeal has been filed aksing the FCC to allow applicants to use the percentage of low-income students looking only at those that returned the free lunch form, rather than looking at the entire enrollment.

Schools are allowed to use surveys, so several seem to have taken the idea that the NSLP form can be used as a survey instrument. And as the applicant in this appeal correctly pointed out, the FCC has never expressly forbidden this, nor do the USAC rules tell applicants not to do this.

But the reason for not allowing this is obvious. If I made up an income survey, and on it said: "Please fill out this survey. All low-income families that return it will receive $100. Families that return the form but are not low income will receive nothing." Would the response be representative of the population? Of course not. Well, a low-income family that fills out the NSLP form gets a couple hundred dollars in free lunches. Families that are not low-income get bupkus.

So the FCC should just come out and say outright: "Any survey (including the NSLP form) which rewards low-income families for returning the form, but does not reward families that are not low-income, cannot be used as a survey instrument."

As my physics teacher used to say: TANSTAAFL; There Ain't No Such Thing As A Free Lunch.

Friday, May 16, 2008

USAC gives me REM

I read the warning posted on Wednesday, but it didn't really hit home until I just went to no USAC Web site for the whole weekend. I feel bereft. For all the griping I do, I spend a lot more time on that site than I realize.

And this shutdown was positive in two ways. First, we got warning. Only 2 days, it's true, but except for me, there probably aren't many people who are impacted. Second, when I try to access the Web site, I get a nice "Web site down for maintenance, back on Monday" message. That's a step up from the regular maintenance of the Data Request Tool, which is not announced anywhere, and you just get a message saying that no records match your query. Which, let me tell you, can really freak you out when you're trying to get an update on a client's FRNs late at night. "What?! No records?! What happened to those FRNs?! ... Oh, yeah, the database must be offline."

Maybe I'll catch up on sleep this weekend. Most people, E-Rate puts them to sleep. Me, lack of E-Rate allows me to sleep.