Search This Blog

Wednesday, March 27, 2013

Form 470 cold calls throw a chill

First, the spambids, then spam unrelated to E-Rate, then phishing emails, then phishing phone calls, and now cold calls.

Ever since the filing window closed, we have gotten repeated phone calls from a certain Web hosting company.  If we pick up, the callers say, "Oh, sorry, wrong number," or just hang up.  Somehow, I can't believe they're dialing the same wrong number several times a day for weeks. What's really going on?  My supposition: this company has a list of everyone who was a contact on a Form 470, and are running down the list making cold calls, looking for new clients.  They apparently aren't clever enough to find duplicates in the list, so they call us over and over, but once the callers hear that they've reached a consulting company, not a district, they hang up.

It's time to hide all contact info on the Form 470.  And not just the download tool.  There is at least one company extracting contact info from the form itself and selling that.  Contact info should be scrubbed from all public display.

Monday, March 25, 2013


OK, the window is closed, time to take a look at the new forms the FCC is releasing, and has requested comments on.  I think I'll just look at the changes listed in the press release, rather than poring through the actual documents.  Here are the changes listed, and my take on them:
  • Requiring the FCC Forms ... to be certified under penalty of perjury:  Oh, good plan.  Everyone who clicks submit on one of those forms is already jittery about the rules.  Throw the word "perjury" in there, and people will just be lining up to risk jail time to get their school a few thousand dollars.  Remember back in 2005 when BearingPoint made its initial report to the USAC board about their site visits, and reported that the E-Rate generated more fear than other grant programs?  Let's jack the fear index a little more.  Because that fear drives applicants into the arms of consultants, and my kids' tuition just keeps going up, so I need more customers.
  • Modifying the existing certifications in FCC Forms 472 and 473 regarding recordkeeping:  Fine, but I have a feeling that the form will just talk about complying with section 54.516, rather than mentioning what the requirements actually are.
  • Adding certifications to the FCC Forms 472 and 474 regarding overall compliance with the E-rate program rules:  Hey, how about first you tell us what the rules are?  In addition to six Report & Orders, dozens of appeal decisions, some with rules tucked into footnotes and the 700 pages of secret rules, the FCC has treated old USAC Web pages and even slides from old USAC presentations as rules.  First, let's have a complete rule book, as SECA suggested.  Then we'll promise to follow the rules.
  • Adding certifications to the FCC Form 473 regarding the cost allocation of eligible and ineligible services, the payment of the non-discount share, the prohibition of gifts as defined by Federal statute and regulations, compliance with the lowest corresponding price requirement, compliance with state and local competitive bidding rules, verification of suspension or debarment, and overall compliance with the E-rate program rules:  Yeah, yeah, OK, of course you want to reinforce compliance with all those rules, but do we need to...Wait.  Did that list include lowest corresponding price?!  Has the service provider community noticed that little bombshell tucked in among the blather?  They're still waiting on a response to their request that the LCP regulations be gutted.  Which makes this little addition to the Form 473 seem like a poke in the ribs.  And the perjury certification makes it a poke with a pointed stick.
Let's boil down the changes further.  In their simplest form, the changes are:
  • More certifications
  • More certifications
  • More certifications
  • More certifications
I think I see a pattern.

Monday, March 18, 2013

Fresh phish

Wow, this is a really well done phishing attack.  Someone is sending emails to all the addresses that were on 2012 Forms 470, saying:
AT&T payment confirmation
Dear Valued Customer,

Thank you for using AT&T online payments.

You submitted the following payment(s) for your account.
Payment Method
Payment Date

For more information about payment please see the attachment.

Thank you,
AT&T Online Services

This email looks completely legit to me, and all the links in the email seem to point to AT&T URLs.  And I've tried a number of virus scanners on the attachment, and none of them caught a virus, so either there isn't one, or it's a new one.  I won't be opening the attachment to find out.

The Confirmation number and Amount are the same on all the emails, though, so they're definitely fake.

Fresh spam

On the second working day after the close of the window, we have our first batch of spam to addresses culled from 2013-2014 Forms 470.  We got spam inside the window, of course, but service providers could argue the spam was an attempt to take part in the competitive bidding process.  But since the window is now closed, emails to addresses on those 470s are just spam.  And it looks like they are also targeting the emails of form certifiers, not just the contact emails.

Let's get email addresses off the publicly visible part of the Form 470.  And hide the phone numbers, too.

New goals, new funding?

The Godfather of the E-Rate, Sen. Jay Rockefeller, made remarks about the E-Rate at the U.S. Senate Committee on Commerce, Science, and Transportation on March 12th.  It was nice to hear such positive words about the E-Rate, especially from the Senator who has the most influence over its future.

My favorite remark was an aside that is in the video, but not in the transcript.  Talking about how the E-Rate became legislation, Sen. Rockefeller said, "I thought it was a toy at first."  Kind of puts my career in perspective.

Apart from vague support, Sen. Rockefeller mentioned two specific initiatives, to which I will give shoot-from-the-hip response:
  1. "By the end of this decade, ... every school in America should have 1 Gigabit of connectivity.."  Well, my smallest client has 24 students.  They're a long way from needing 1 Gbps, but I suppose by the end of decade maybe they'll need it.  At the other end of the spectrum, the current guidelines for the PARCC assessment is 100 kbps per student.  So a district with 10,000 students will need 1 Gbps this time next year just so their kids can do online testing.  Still, not a bad benchmark, and the GAO is always saying the program needs some benchmarks.
  2. "[E]very school in America should be able to offer [wireless connectivity]."  Sorry, Sen. Rockefeller, I think wireless in schools would be nice, too, but the fund is several billion dollars short of being able to provide Priority Two funding for every school in the country.  And please, be careful how you talk about this.  The Senator mentions wireless in coffee shops as a model, so it's clear he's talking about wireless LANs, but the cell phone companies are going to see this as an opportunity to expand their $40/device/month cell-service-as-network model.  Here's what the Senator could do to help achieve his vision without spending more money: His vision is apparently the coffee shop model, which is BYOD ("BYOD" has displaced "1-to-1" as the most overused term in ed tech), so the Senator could help considerably by modifying CIPA legislation to clarify whether devices which are not school property, but are connected to a school network, need to be filtered.  Or exempt E-Rate from CIPA requirements, on the grounds that E-Rate funds are not actually government funds.
The New York Times published an article on the speech, and it has an interesting tidbit.  The Times reports that Sen. Rockefeller "hoped to gradually expand the amount of money devoted to E-Rate, providing for an additional $5 billion to $9 billion in total funds over the rest of the decade."  Let's see, we've got 7 years left in the decade, so that works out to around $700 million to $1.3 billion per year.  That would be a welcome addition, but it's still not going to pay for wireless access in every school.  I don't think it will even cover 1 Gbps connectivity for every school.

 Wait a minute, the Times says that the FCC "renamed the Universal Service Fund the Connect America fund."  What the fund?  I didn't get the memo about "Universal Service Fund" going the way of the dodo.  I thought CAF was just the new name for the High Cost Program.  The FCC overview on CAF does mention "transforming the existing USF into a new Connect America Fund (CAF)."  Time to go to the Connect America Fund & Intercarrier Compensation Reform Order (FCC 11-161).  Paragraph 115 says, "we establish the Connect America Fund to bring broadband to unserved areas; support advanced mobile voice and broadband networks in rural, insular and high-cost areas; expand fixed broadband and facilitate reform of the intercarrier compensation system. In establishing the CAF, we also set for the first time a firm and comprehensive budget for the high-cost program."  The Executive Summary says it even more clearly: "We create the Connect America Fund, which will ultimately replace all existing high-cost support mechanisms."

Is it a coincidence that they changed the name just a month after I pointed out that "The High Cost Program" was a terrible name for a government program?

At least the E-Rate is still safely in the USF.  I think.

Friday, March 15, 2013

Put on your thinking cap

A recent ex parte filing by the Superintendent of the Miami-Dade County School District had an attachment that looks like the slide deck from a presentation by Funds for Learning to the Council of Great City Schools.  I dislike slide decks, and I hate slide decks disconnected from the presentations that went with them, but I figured anything by FFL would be filled with pretty graphs in the FFL color scheme with factoids that no one else has compiled.  So I read it.  It's worth looking at.

The core of the presentation was the idea of setting a per-student (or per-patron) cap on funding.  It's an interesting way to redistribute the E-Rate fund.  Basically, the FCC would pick a number (FFL used $160), and schools would only be able to get funding on pre-discount amounts up to that limit.  So if you had a school with 100 kids, you would only be able to get funding on your first $16,000 of expenses.

So what would be the result?  Basically, it distributes Priority Two funding away from 90% applicants and spreads it more evenly.  It sounds fair, but think a little deeper.  Everyone would get an equal amount of funding, but some applicants would be more equal than others.

Small applicants would be disadvantaged.  When it comes to telecom and Internet, there are decidedly economies of scale.  In the bandwidth world, my rule of thumb is that for every tenfold increase in bandwidth, cost doubles.  FFL acknowledges this by giving a per-building minimum, so that a school with only 100 kids would end up getting more per student than a school with 300.  (Small special ed schools, with their flipped student/staff ratios would be really hard hit.)

Rural applicants would be disadvantaged.  They'd get to keep their higher discount, sure, but since the cap is on pre-discount amount, this plan would not really offer any compensation for the higher costs for telecom in rural areas.

So the plan would really benefit large, urban districts.  Wait, for whom was this presentation prepared?

In the past, those Great City districts which have a significant percentage of 90% schools would have lost out, as their P2 gravy train would have been redistributed, but since there is unlikely to be any P2 funding, that gravy train is empty, anyway.

Anyway, it's not a bad plan, but not as good as lowering the top discount rates.  Which brings me to the part of the presentation that got my teeth grinding: on page 30, it says that an across-the-board 10% cut in the discount race would hurt 90% applicants disproportionately because they would have to pay twice what they're paying now.  That's the wrong way to look at it.  What matters is the amount of funding received.  If a 90% applicant went down to 80%, the amount of dollars it would receive from the program would drop by about 11%.  But that 20% applicant dropping to 10% would lose 50% of its funding.

But I don't advocate cutting the discount level for 20% applicants.  Because just as 90% is too close to free, 10% is too close to zero.

I'm not opposed to caps, but I've proposed that the existing soft caps be published.  Just tell applicants that if they spend more than $160 per student, they'll get a Cost-Effectiveness Review.  So people who really need the extra cash would endure the hell of a CER to get it, but most applicants would just spend right up to the limit.  These soft caps exist, but they are secret.

Recess Deployed Ubiquitously

First, I'll skip to the highlight.  From atop Rocinante, a recent article in Education Week reads like this:  blah blah blah blah blah blah blah blah blah [it's a long article with a paucity of graphs] blah blah blah blah blah blah blah "Would I give up using federal dollars to pay for cellphones...? You bet...." blah blah.  Have I found a Sancho Panza to assist me in tilting against the cell phone windmills?

No, my ellipses [in this case, the plural of ellipsis, not ellipse] hide the fact that the quote above is actually in support of mobile data plans.  At least the tech director quoted clearly thinks if something's got to go, it should be cell phones.  But I think I'll have to find someone else to hold my lance.

The article is really about a couple of districts that won grants under the FCC's pilot "called Learning on-the-Go, or LOGO," which allowed them to send devices home with wireless Internet access, and now they want more.

OK, first, who ever called the program "LOGO"?  I don't remember hearing it called that.  The program had a perfectly good acronym, EDU2011, which include a U for Ubiquitously, and made it clear it was a one-year deal.  If we're going to give the program an acronym, let's go back to that one.

Now, on to the policy issue.  I think there is a lesson from the free-phones-with-VoIP-service mess which can be applied here.  Let's look at unintended consequences.  What if the FCC said that schools were allowed to pay for mobile data plans so that students could use their mobile devices from home?  Well, if a school can pay for Johnny to use his tablet at home, why can't they pay for Susie to use a computer at home through a DSL connection?  I mean, DSL costs half what mobile data costs, so it would save the program money.

Every loophole is like the mitten in that Ukranian folk tale.  It looks so cozy in there, and service providers that walk by will think, "I can stretch it just a little more to accommodate my previously ineligible service."  We've seen it over and over: web hosting, free cell phones, on-premise Priority One equipment, video transport.  The FCC creates a reasonable loophole, and service providers try to shove all kinds of services through it.

Here's a good example I heard lately: the E-Rate won't pay for intercom systems, so a school I talked to was looking for a cell phone plan that would allow one phone to call everyone on the plan.  They were going to use cell phones as a lame intercom system.  Because the cell phone plans are 90% off, and the handsets are free.  And if they could incorporate push-to-talk, it would be a decent intercom, and only cost $2 per teacher per month after E-Rate discounts, with no upfront costs.

Please, no mobile data.

But I agree with the idea that if we need to throw something out of the program, it should be cell phones.  Because cell phones can only stay in the program with the help of multiple loopholes.  And let's be honest: no one is giving cell phones to students, and not many teachers get them, either.  Let's fund services that are at least close to the education of students, not services that make it more convenient for principals when they're looking for custodians.

And because I'm punchy from the funding window, I'm going to go on a rant that is not related to E-Rate.  [Long-time readers are thinking, "Most of his rants have little to do with E-Rate.  What will it be this time?  Capitalization?"]  Here's the worst quote in the article: ""We're trying to extend the learning day beyond the duty day of 7:30 to 4:30."  To which I say, "Stop!"  My main complaint with school is not low standardized test scores or any of the other complaints I hear from policy-makers.  My main complaint is that they have taken all the fun out of the school day by slashing the arts and recess, and now they're trying to take the fun out of my kids' afternoons.  First graders with homework?  That is wrong.  And by the time my kids got to high school, the workload was ridiculous.

"Extend the learning day" means "further deprive kids of opportunities for self-directed learning."  Kids are always learning, especially if you let them decide what to learn.  Unfortunately, the standardized tests (by which schools and teachers are evaluated) aren't focused on the things that most kids want to learn, so schools keep trying to get kids to spend more of their time learning things that they don't want to learn.

So don't extend my kids' school day.  And you know what?  Give them art and music every day.  And phys ed, too.  And definitely recess.  You know what?  Recess twice a day.  Really, what kind of idiot expects a 10-year-old to sit at a desk for 6 hours a day without running even a little?

Today's rallying cry:  "Recess twice a day, and no mobile data in the E-Rate program!"

[Grammar note: did anyone else notice that I used "E-Rate" anarthrously a couple of paragraphs back?  I did it twice in a row.  If you didn't notice, it means you spend too much time on this program.]

Saturday, March 09, 2013

Same data, different conclusions

Funds for Learning's blog recently mentioned that E-Rate funding requests for cell phones are up 40% since 2008.  The author's conclusion?  Free the Priority Two funding, so schools don't have to rely on wireless technology.  My conclusion?  Throw cell phones (and wireless data plans) out of the program.

My other conclusion?  90% is too close to free.  The blog post mentions a recent troubling funding request, where a district is getting $6.3 million for wireless data connections for 12,500 netbooks.  The school district's share will be $700,000/year.  If they'd chosen to install WiFi in all their schools, it wouldn't have cost more than $2 million, saving the district at least $500,000, and the E-Rate program $4.8 million.  And the next year, the district would have saved $700,000, and the E-Rate $6.3 million.  [Niggle with me arguments about support costs, etc., and I'll counter with higher data rate.]  I'm guessing when the Superintendent heard that the district could get $6.3 million in funding, the fact that it was going to cost the district $700,000/year didn't raise any eyebrows.

Cutting the top discount to 75% would solve a myriad of problems, among them:
  1. Waste: A 90% discount creates an incentive to buy things you don't really need.  Imagine if you walked into Target and everything was 90% off.  How many shopping carts would you fill?  And how much of what you bought would you end up not using?
  2. Fraud: It's easy to fudge 10% of the cost of a purchase.
  3. Funding shortage: The E-Rate funding for Priority One would drop, since the USF's share would drop, which might leave more for Priority Two.  Add in the savings resulting from the reduction in waste, and maybe even suburban schools would see a little P2.
Cutting cell phones and wireless data plans from the program would help in two ways: 
  1. Abuse: "Off-campus use must be removed by cost allocation." (2013 ESL)  So every time an administrator's smartphone receives an email while not on school grounds, that should be recorded and removed from the funding request.  It's the most violated rule in the program.
  2. The bundled equipment quandary: Because the FCC didn't want to mess with the proud American tradition of a free cell phone with a two year contract, they opened a loophole through which a myriad of service providers are trying to drive their equipment.  And some of the cell phone deals are phone purchases disguised as service plans.
  3. Funding shortage: Removing any service from the program will save money.  Removing the service with the fastest-growing demand will help preserve the future.
Time to cut loose cell phones and put more applicant skin in the game.

Thursday, March 07, 2013

Radical, militant filtering data

Somehow this snuck under my radar: the American Association of School Librarians (AASL, a division of the American Libaray Associaiont (ALA)) released a report on filtering in schools.  Interesting reading.

I've had a sort of platonic crush on librarians ever since the FBI complained that "radical militant librarians kick us around" because the librarians opposed the portion of the Patriot Act that allows the FBI to come into your library and ask for a record of every book you've ever checked out without the inconvenience of getting a warrant, and the library is forbidden to tell you that the FBI stopped by to collect info on you.  The ALA response?  "Radical Militant Librarian" buttons.  [Another reason to love the librarians: they correct the FBI's grammar by inserting a comma between "radical" and "militant."]  My local library's response?  They no longer keep any record of any books checked out; I guess the FBI can find out what books I currently have checked out, but not the book I returned yesterday.

Actually, my affection for librarians started when they fought CIPA all the way to the Supreme Court.  Unfortunately, they lost and we're stuck with CIPA.

Back to the school librarians.  The AASL got responses from the librarians in 4,229 schools.  Here are the factoids I found noteworthy:
  1. 94% of schools use filtering software.  That's about what I would have expected, since CIPA requires it, but it's good to see my guess confirmed.
  2. 88% of schools block social networking sites, and 74% block chat sites.  So much for the new CIPA requirement that students learn about "interacting with other individuals on social networking websites and in chat rooms."  It seems that schools are teaching a simple lesson about interacting: Don't.
  3. 47% of filters use blacklists.  Bulldinky.  I'm not aware of any commercially available software that doesn't use blacklists.  They all dress it up with bragging about heuristic this and dynamic that, but I'll bet 90% of all pages blocked are filtered because they're on a blacklist.
  4. The biggest impact of filtering?  "Impeded student research when topic or key word searches are filtered."  OK, it was almost a tie with "Decreased the number of potential distractions."  Still, it's nice to see school librarians corroborate the USDOE statement about the negative effects of CIPA.
Nothing shocking, but leave it to the librarians to provide some actual data for the filtering discussion.

RJ-11 phishing lines

Yesterday we got a new kind of abuse of the contact info on a Form 470.  An unscrupulous service provider called us to find out when they could install the Internet connection.  The idea behind the scam seems to be to confuse a school employee into letting them in to install the circuit before anyone realizes that no one had ordered the circuit.  It's a variant on the old maintenance-proposal-disguised-as-an-invoice scam.

Fortunately for our client, we're the contact on their 470, so we got the call and smelled a rat.  I wonder how many schools will have surprise circuits installed because USAC publishes names and phone numbers on the Form 470.

So now in addition to my call to have the Form 470 include a contact form instead of providing spammers with a list of email addresses, I am now calling for the phone number to be hidden as well.  Up until now, I've just been annoyed at how many service providers call us when our Forms 470 state that we want email contact.  We should have an option to hide our phone and fax numbers.  Now we have a documented case of a scammer taking advantage of a phone number from a 470.  I wonder how many of the spamfaxes we get are the result of our fax number being published every year.

And the drumbeat of phishing emails continues.  Today's email purports to come from the University of Chicago, informing me that "Help desk requires to upgarde your account click here. third party tried to access your account please update for security reasons."  That's a poor phishing email.  First, why would the Univ. of Chicago help desk be contacting me?  Second, I suspect the people working the help desk at such an august university know how to spell "upgrade" and write in complete sentences.