CER fun?

Ah, my perfect storm to point out the ludicrous nature of the Cost-Effectiveness Review (CER) process.

Now, many of you know that I hate the CER process. I put at #2 on my hit list of E-Rate rules to be eliminated, behind the 2-in-5 Rule. CERs are actually more heinous than the 2-in-5 Rule, but CERs are actually warranted in some cases, and probably do some good. The 2-in-5 Rule is useless and heinous. On the other hand, at least the 2-in-5 Rule isn't shrouded in secrecy. There's even a cool tool for figuring out if you're about to violate the 2-in-5 Rule (www.universalservice.org/sl/tools/search-tools/two-in-five-tool.aspx). Whereas if you ask what it would take to pass a CER, you are told flat out that the information is an "internal control," which means "secret." Not only won't Solix tell you how you got into this mess, they also won't tell you how to get out. (So much for the "pull you through the application process" emphasis from last year's training.)

So the 2-in-5 Rule is a bad rule well implemented. CERs are a good idea horribly implemented.

Anyway, back to my perfect storm. What most people don't know, and what Solix doesn't tell you, is that if you fail a CER, you can submit a modified request. Unfortunately, that usually doesn't work out because the complexity of redoing the proposal means it can't be done fast enough, and the CER of one FRN will hold up the whole application.

But now I have an 87% application who needs 300 cable drops repaired. Solix thinks that's too many drops for the number of students at that location. Two factors have come together: 1) since it's an 87% district, they aren't going to get Priority Two approval for months, anyway, and 2) the entire request is just cable repair, priced per drop. So I can easily reduce the request to 299 drops to see if that gets approved. No? OK, how about 298? No? 297? Eventually, I'll get down to exactly the number needed to get this thing approved. I've got a couple of months.

If I do discover the secret drops-per-student ratio that will pass a CER, I'll let you all know.

Of course, I don't get to make the decisions on strategy, so it may be that our client will decline to participate in this Chinese water torture, since they don't share my level of resentment towards the CER.

But a fellow can dream....