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Thursday, May 27, 2010


OK, now this appeal gets my goat. Some little library is getting a little funding for their phone line, and USAC drops an audit on their heads, and then COMADs them for not being able to document the number of bids received.

First of all, who says the district has to create documentation of the number of bids? If the FCC wants to have that information, then it should be on the Form 471. I know, it would make the form more complex, but it wouldn't make the application process more complicated. It just makes it obvious how complicated the process is.

Second, the recovery amount is $486. How did an applicant this small get audited in the first place? And how about we have a bid threshold like government purchasing law at every other level of government everywhere? Making a purchase under $1,000? No bid necessary. At least the FCC seems to be moving in that direction with the NPRM. And what is the de minimis level on COMADs? Because I guarantee that this COMAD has already cost more than $500, and now that it's been appealed to the FCC, the cost is going into the thousands.

What a waste of everyone's time.

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