Last week's News Brief reports, apparently without any sense of irony, that the final regular wave for 2007 will be issued this week. It took me a second before I snorted. A "regular" wave of funding is being issued over 10 months after the end of the funding year?! That doesn't meet my definition for regularity.
Maybe USAC should pay more attention to the amount of fiber in their commitments; perhaps the rules on fiber WANs need to be more lax.
These delayed commitments are a serious matter. For recurring services, districts have to forego service or pay full price and get reimbursed a year after the end of the funding year. It would be interesting to see what percentage of the undisbursed funding (bemoaned in the recent GAO report) are the result of committals rendered useless because the applicant had to forego the service. And it's an accounting nettle to receive reimbursement for costs incurred two fiscal years ago.
Some suggestions for fiscal regularity:
- Simplify the rules
- Simplify the rules some more
- Set the denial threshold before the start of the funding year
- Streamline PIA process for Priority 1 funding requests
- Don't make rule changes midstream (look at all the time Solix is wasting on Web hosting requests this year)
- Penalize PIA for Basic Maintenance FRNs left undecided after the start of the funding year.
- Use "As Yet Unfunded" more liberally (only call it something like "Funded Pending Funds Availability"); knowing that an FRN will be funded unless it falls below the denial threshold can be very helpful in deciding whether to forego service or pay the full cost.
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