Entities on the move

I have ranted more than once about the use of the word "entity" in the E-Rate program. A November 2010 News Brief tried (but mostly failed) to explain the difference between "entity number" and "billed entity number."

I just noticed a new muddying of the water. On Item 5c of the new Form 470, applicants are asked to put the number of "eligible entities" covered by the Form 470. The instructions give examples of eligible entities, including elementary schools, bus barns, library branches, bookmobiles, ... (insert sound of record scratching here). Bookmobiles?! Does this mean bookmobiles get entity numbers? Or are there eligible entities that do not require entity numbers?

I'll say it again: the term "entity" should be struck from the E-Rate lexicon. The meaning of the word has become irreparably muddied.

90% is too close to free

I've said before on this blog that the top discount on Priority 2 should be lowered to 70%. Now I'm kind of rethinking that. Now I think maybe the discount should be lowered for Priority 1, too.

Why am I changing? Well, I've always said that the waste, fraud and abuse (WFA) caused by the 90% discount is really just in Priority 2. Now I'm not so sure. I recently saw a case where an applicant made a purchasing decision on telecommunications services that I think is wasteful, because they knew that they were going to get 90% off the cost. Now, this applicant didn't do anything wrong that I could see: they followed all the rules, and the solution they chose is not fraudulent or abusive. But I'm sure without E-Rate funding, they would have made a different decision. And I think they might have made a different decision if they'd been forced to pony up 30% of the cost, instead of just 10%.

I still think all the real WFA is in Priority 2, but for the first time I've seen how a 90% discount in Priority 1 is a problem, too.

To paraphrase a recent New York mayoral candidate: "The discount is too damned high!"