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Tuesday, July 23, 2013

WTF happened to WFA?

I was looking at the 2003 recommendations of the Waste, Fraud and Abuse Task Force, and I got to wondering if any of the recommendations had been approved, so I thought I'd like the recommendations and their status.  And, of course, since I'm so opinionated, I'll give my view on whether each recommendation is a good idea.

Recommendation Good idea? Status
Lower top discount for Priority Two to 80% Yes, but it doesn’t go far enough. Dead? It isn’t mentioned in the Fact Sheet for the current NPRM. I don’t think it’s been part of any reform NPRM since 2004.
Impose a funding ceiling Yes. The current NPRM includes a proposal to allocate funding on a per-student basis. Not quite the same as a ceiling, but close.
Simplify forms for small funding requests Yes. Dead. The forms just get bigger and bigger.
Require applicants to list services on the Form 470 even if they have a separate RFP Yes. Dead.
Align tech plan requirements with other federal agencies Tech plan requirements are a bad idea. Pretty much done.
Provide clear policy, procedures, eligible services list, etc. before start of training cycle Yes. Let’s have a rule book. Partially done. The ESL has come out before training the past couple of years, but policy changes whenever, and application processing procedures are secret.
Develop guidelines on generally reasonable cost and functionality Develop and publish guidelines. Dead. Well, USAC has developed secret bright lines for reasonable cost and functionality, but the Task Force clearly wasn’t thinking of Cost-Effectiveness denials.
Disallow transfer of equipment during its service life. Yes, with one exception. Implemented, sort of.
Establish and publicize reasonable standards for warranties and other maintenance Yes. Established, but not publicized. The standards are part of the kafkaesque Cost-Effectiveness Review process.
Publicize the eligible services information that is provided to PIA reviewers Yes. Dead.
Create an “eligible services team” within PIA Yes. Who knows? PIA is a black box. We don’t know who works there or what they do.
Give specific guidance on service provider assistance with technology planning and procurement Yes. Nope. The guidance has gotten better, but just last month the FCC overruled its own decision on service provider involvement, so the rules are not clear.
Deny only FRNs with procurement or contract problems, not an entire 471. Yes. Implemented.
Standardize Item 21 attachments Yes. The online Item 21 Attachments kind of comes close, but it's so kludgy that a lot of applicants don't use it.
Increase resources to provide info and guidance:

  • More workshops
  • National webcast 
  • Email alerts
  • Make a FAQ
  • Provide more info using the web
Yes to all. This kind of communication has gotten better.  USAC even opened a division for it.
  • Implemented
  • Nope
  • The weekly News Brief
  • The News Brief kind of addresses this
  • Implemented
Publicize best practices, bad practices and success stories Yes. The HATS program was pretty good for the positive aspects.  The problem is that no one can keep track of all the ways to screw up.
Consultant registration and disclosure Yes. Consultants are required to register, but are not required to disclose conflicts of interest or co-sign forms.
Strengthen review process for SPIN and ETP registrations Yes. Dead.
Allow applicants to see service provider invoices for Internal Connections Yes. Implemented, though I'll bet most applicants don't know they have this option.  Most IC invoices trigger a Service Certification, so applicants are forced to review invoices.
Prevent applicants from filing without authorization of central authority I guess. Dead.  I don't see this as much a problem any more.
Audit based on rules as they existed at the time of funding Yes. Not really the practice, because we often don't know if FCC decisions are rule changes, or rule clarifications.
Tiered audit results Yes. Audits are much milder now, but there were a couple of tiers.
Simplify service substitutions; create safe harbor, allow applicants to spend more Yes. Service substitutions have been very quick for the most part, and applicants are allowed to increase the cost of a project (but can't increase funding).
Streamline process for combined SPIN change/service substitution Yes. This is going to be a rarity thanks to the heinous change in SPIN change rules.  But it used to go pretty smoothly.
Reduce application review for small requests Yes. Dead.
Publicize criteria for invoice review Yes. No chance.  Another secret.
Reduce invoice review for small amounts Yes. Dead.
Notify applicants of systemic errors at USAC and expedite appeals Yes. I can't think of a recent systemic error, but USAC has been very good about quickly correcting their errors on appeal.  The FCC has been good, but not quick.
Give applicants and service providers more info on application status Yes. The Application Status tool is a big step forward.  It would be nice to get more info on what is snagging specific 471s.
Exempt Good Samaritans from COMADs Yes. Implemented.  Since Good Samaritan disbursements are always going to be BEARs, USAC is always going to COMAD the applicant.
Give automatic service delivery extensions for FCDLS after Jan. 1, not March 1 Yes. Dead.

Boy, that WFA Task Force had some good ideas.  My rough count has 14 out of 32 recommendations implemented.  That's also better than I expected.

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