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Tuesday, September 22, 2009

Mel’s palantir

OK, so I’m done with a full day of USAC training, and I’m ashamed to admit it was kind of fun. Kind of.

SPOILER ALERT: If you’re going to attend one of the trainings, there will be fewer surprises if you read further. And without surprises, it is harder to remain conscious through some of the sessions.

I found the nuts & bolts sessions somewhat informative, though I heard “case by case” too often. For a long time, I bought the argument that USAC can approve more funding if they have more wiggle room by not locking down the rules. But now I’d rather have more specific rules. Because it’s a drag for applicants when they can’t get funding because of some rule that they can see, but the bigger bummer is having funding denied because of some unknown rule or procedure. Even worse is having funding granted, then taken back, and that almost always happens because the rules are unclear. (Oh, wait, no, the rules are clear, but applicants disregard them.)

The most interesting session, as usual, was Mel Blackwell’s, mostly because he gets to make predictions.

The only prediction that had a guaranteed timeline was that the Round 4 audits will not until the filing window is closed. I asked in a different session if the Announcement Letters (which start the clock for supplying documents) will come out before the end of the window, and the answer was “no comment.” So I guess we can assume that Round 4 will start right after the window, with some Announcement Letters coming out before the end of the window.

Perhaps even better news (which came from Mel, but during the “Audit Response” session) is that the Round 4 audits will not be attestation audits. Mel promised that the audits will be less painful, and more proportional to the amount of funding involved.

Mel also talked about shortening the window. He had a great graph showing that almost all 471s are filed in the last 7 days. So why keep a 50-day window? I’m OK with that if they want to start the window in mid-March and end it in May. But if we’re talking moving the end of the window earlier, I’m against that.

Mel also talked about the upgrade in USAC’s computer systems. He promised several improvements, but said we’ll see “a few for 2010, more for 2011.” Among the improvements he said he expected:

  1. Online Item 21 Attachments will be available to service providers.
  2. Applicants will have a “copy my app” tool, allowing us to copy and revise previous year’s 471, instead of having to start from scratch.
  3. Online applications will do more data validation, making it harder for us to make mistakes.
  4. USAC will set up a data portal to improve our access to USAC data.

Mel’s last big prediction: The denial threshold for 2009 will be below 80%, “in the 70% area.” I think he’s wrong, but I think just having him say it creates downward pressure on the denial threshold. Yesterday I heard another E-Rate veteran predict that we’ll never see 80% again, and I’d have to say that I think that’s more likely. (For the jargon-impaired, the “denial threshold” is the discount level below which Priority 2 funding will not be available.)

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