Searching for the silver lining

The June 16th newsletter from E-Rate Central has an interesting article on the incentives of the E-Rate program. The idea is that the E-Rate rules have created incentives that change school and library behavior in positive and negative ways. They list 3 positive and 4 negative incentives.

Let's start with the negative, because I agree with all those points:

1. The 90% discount creates all sorts of waste, fraud and abuse. Back in 2003, the FCC formed a Task Force on the Prevention of Waste, Fraud, and Abuse. Their report was clear: 90% is just too close to free.
2. The Eligible Services List is not technology-neutral. I agree. It also promotes inefficiency. But at least we get to comment on it every year.
3. The "2-in-5 Rule" is a failure, promotes premature spending, punishes those who lease. This is currently the worst rule in the program. And it was sprung on us with no warning. (Most rules go through a Noticed of Proposed Rulemaking, but not this one.) It has to go.
4. E-Rate support for maintenance by outside personnel provides an incentive to cut district tech staff. That's why I left my last district job: I outsourced all the interesting parts of my job, quit, and was replaced by someone who was an expert in integrating tech into the curriculum, not maintaining technology.

The incentives that E-Rate Central sees as positive, however, I find at best ineffective.

1. Technology planning requirements force schools and libraries to plan ahead. I disagree. If you force someone to write a plan, they'll do whatever's required. But then the plan gets filed away until a required revision. And the E-Rate rules prevent applicants from seeking outside expertise. In my experience, the best way to determine what technology to implement is not a top-down planned approach, but in response to grass-roots demand. The E-Rate, with its long application cycle, makes this more difficult.
2. Item 25 certifications help make applicants mindful of the ancillary expenses in implementing technology. It makes the person who fills out the application mindful of it for a few hours in January, but I don't think that makes much difference. And since applicants are not allowed to include possible grant funds in the Item 25 total, it provides a disincentive to leveraging E-Rate funding with other grant funding.
3. E-Rate deadlines prevent procrastination. Well, OK, in a disfunctional system where necessary tech procurements are put off, E-Rate deadlines will force the procurements to happen. But saying that's a good thing is kind of like saying it's good that my PC crashes often, because rebooting from time to time can help clean crud out of memory. Well, sort of, I guess.

Call me the E-Rate Curmudgeon, I guess. I can't see any real silver linings in these rules.