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Tuesday, February 10, 2015

What's in a word?

It's been some time since I complained about the word "entity," but the new $150-in-5 Rule gives some importance to the confusion, so I'll renew my gripe, and my call for a new ID numbering scheme.

Since it's been something like 3 years since I whined about this, I'll recap: the term "entity" is way too vague in this program.  Sometimes it means "organization," sometimes "school," sometimes "campus," sometimes "bookmobile," sometimes "location."  USAC tries to clarify things by creating "billed entities" (organizations) and "entities" (locations), but then it violates its own convention by telling us to put an "entity" (location) in Block 1, when that is clearly where only a "billed entity" (organization) should go.

This was all just a cute muddle until 2004, when the FCC's Fifth Report & Order changed the rules to "require all entities that participate in the schools and libraries universal service support mechanism to obtain an FCC Registration Number."  USAC interpreted that to mean that each location ("entity") needed an FCCRN.  The problem is that each FCCRN is tied to a FEIN (corporations get FEINs instead of the Social Security Number given to "natural persons" (I love that phrase)).  Locations don't get FEINs; organizations (corporations and the like) get FEINs.  So USAC told school districts to create an FCCRN for each school.  Since the district has only one FEIN, districts were actually just creating duplicate FCCRNs.  After thousands (tens of thousands?) of duplicate FCCRNs had been issued, the FCC noticed and clarified that when they said "entity," they meant "entity," not "entity."

Now comes the E-Rate Modernization Order, and removes one quirk of the "entity" issue, while making the definition of "entity" mean serious money.

The quirk it removes?  Well, when you're calculating discount for each location and a weighted average for the district, you can combine or split locations to change the district discount.  In many districts, the Junior High and High School are on one campus, but often have separate addresses, individual NSLP counts, and are considered by the state to be two schools.  Is that one "entity"?  Who knows?  What about a district that runs three academies out of one building?  If combining the entities will nudge the aggregate NSLP percentage over a threshold (a junior high with 80% of kids on NSLP combines with a high school with 73% NSLP, and the combined NSLP is 75%: 90% entity!).  But if the aggregate percentage in the above scenario was 74% (which would give you an 80% discount), obviously you want split them to get a discount of 84% or whatever the weighted average gives you.

The EMO did away with that by building district-wide discount calculations.  The definition of "entity" no longer matters for determining discounts.  (OK, it still does for consortia, but I hate consortia, so I'm ignoring them.)

But then the FCC perversely made the $150-in-5 budgets building-specific.  Aside from being a nightmare to keep track of (the need to track this budget for each location (and then contribute some of the budget to a piece of equipment at another location if that equipment will serve the location in question) has really increased the demand for my services as applicants finally throw up their hands), the budget now makes it important what an "entity" is.

Here's a real-world example.  A high school with 1500 students sits across the parking lot from a pre-school with 200 children.  If they're two separate entities, then the high school gets $225,000 and the pre-school gets $30,000.  But that pre-school doesn't need any new network gear, since no one is letting 4-year-olds roam the Internet, and pre-K teachers are interacting with children, not smartboards.  A couple of hand-me-down 802.11g APs is enough for the teacher's iPads.  So if they are separate entities, that $30,000 goes largely unused.  The high school, meanwhile, needs a wired network and two wireless networks (one for school devices, one for BYOD), and those kids are going to want 802.11ac speeds, so $225,000 is nowhere near enough.

The district will be tempted to make "entity" mean "campus" instead of "building," so they can have an extra $30,000 to spend on the high school.

If you're going to hand out money on a per-entity basis, shouldn't you say what an "entity" is?

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