Duplicativicity

Early reports indicate that USAC has misunderstood what they asked for on the Item 21 Attachments, and PIA is going to be asking about "duplicative services" over and over.

See, if your ISP provided the circuit from your district hub to the ISP's POP, you were expected to describe that as "Internet and Transport" instead of "Internet only."  (I believe the thinking was that the information could then be used to better compare Internet pricing if you knew whether it was just the Internet port or port+circuit.)  Of course, then you'd also have a WAN providing Transport from the district hub to the other locations in the district.  So now you have Transport twice for each of the non-hub locations, so it looks duplicative.

And PIA is going to ask about it.  It's not duplicative, of course, which I hope PIA will understand quickly, but it creates a lot of extra work.

Meanwhile, you can't really draw any conclusions about the price of an "Internet and Transport" FRN, because you're allowed to dump your WAN (a telecommunications service) into an Internet Access FRN (a kludge that was created to allow statewide/regional networks and ESAs, which are not telecom providers, to provide WAN connections to individual schools).

Ironically, the warning that duplicative services are not eligible was removed from the 2015 Eligible Services List because the FCC wanted to "streamline" the ESL.  The FCC apparently feels that if you wanted to get $3,000 in funding for your school, it is your responsibility to find, read and retain the information in paragraphs 22-24 of the Second Report & Order (written in 2003).

In short, now that the duplicative services rule is well hidden, PIA is going to try to enforce it using misinformation from a system which had to be weirdly designed to allow grey-market sales of telecommunications services by states, ESAs, et al.

Get her!

I opened USAC's Annual Report when it first came out, but then the filing window got in the way, so I'm finally getting back to it.  If you're looking for a reasoned summary, you should know better than to look here.  As usual, it's just going to be a waggish look at whatever pops out at me.

My first laugh: the "Interactive PDF" version was OK, but the first three pages of the vanilla PDF version says:
MOVING FORWARD
TO GET
HER
Alas, I guess someone noticed and now the USAC PDFs both have two-page-wide layouts, so "TOGETHER" is no longer split, but the FCC retains the old, threatening version.

Staying with the snark, here's part of the USAC CEO's opening statement:
"In 2014, the FCC continued to pursue an aggressive modernization agenda for the universal service programs.... These changes have created a dynamic and exciting environment for our organization...."
Translation:
"Holy crap!  Did you have to change everything in one year?!"

"High Cost Program"?  I thought it was renamed the Connect America Fund.  That change should happen now, because "High Cost" is a terrible name for a government program.

"Lifeline Program"?  When did the Low Income Program get a name change?

The Service Providers Participating by Funding Year graph on page 13 is interesting for a couple of reasons:

1. The graph only shows the last five years, so it ignores that there were once over 8,000 service providers in the program.
2. The number of service providers dropped by 10% from 2013 to 2014.  Meanwhile, P2 demand dropped by only 3.6%.  Why would that be?  I'm guessing that every year, a new batch of P2 providers thought they'd found the Promised Land, but left the program in dejection, to be replaced by an eager new crop every year, and after 15 years, there aren't any naive P2 vendors left to replace the dejected ones that are leaving.

I expect a large drop in the number of service providers in 2015, with so many services cut out of the program.

Here's an incorrect statement on page 12: "USAC paid nearly 98 percent of invoices within 30 days of receipt."   Do a little math on the invoicing numbers on page 16, and you'll see that 6% of invoices were rejected.  And it's not clear whether that includes "pass zero" invoices, where the invoice is approved, but for $0.00, so nothing is paid.  So USAC paid at most 94% of invoices.

Page 16 has a chilling blast from the past: "internal controls."  Years ago, that was PIA's way of saying "mind your own business" whenever you tried to find out why you were being asked all these questions.  Now we have the secret 700-page tome of PIA "procedures," and "internal controls" means that USAC is keeping track of its money.

Ooh, let's play with the application processing numbers on page 16.  The FY 2014 numbers don't look too bad: by the end of 2014, half way through the funding year, only 5.7% of applications remained undecided.  Not bad.  About 53.1% of applications were approved before the start of the funding year, which seems low unless you know the recent history of the program.

The FY 2013 numbers aren't so pretty.  At the end of the funding year (2Q 2014), 5.7% of the applications were undecided.  At the end of 2014, six months after the end of the funding year, the undecided percentage was down to 4.7%.  At that rate, they'll finish up sometime in 2018.

The percentage of applications rejected seems pretty steady around 17%.  Wait, what is a "rejected" application?  A 471 that was rejected before looking at individual FRNs (for example, an application filed outside the funding window, or never certified)?  A 471 on which all FRNs were denied (perhaps en masse due to, for example, not having a 470, or each dismissed on its own (lack of) merits)?  A 471 on which at least one FRN was denied?

I find I don't have much patience for the financials, but let's see what catches my eye.  Looks like USAC is holding almost $8.5 billion to cover future payouts under "Assets held for the Federal USF."  That's up from $7.7 billion in 2013 (and $5.4 billion in 2006).  Is this where the Chairman is going to get his extra $1 billion/year?  I'm betting it's just the CAF reserve that the FCC started building at the end of 2011.

I am tempted to do some analysis of the table on page 43, but I did that analysis last year, and I doubt much has changed.

How was that new form?

Well, I'm finally recovered from the filing window, so I thought I'd give some feedback on the new online form.  All of these observations were made in the heat of filing, and I'm unwilling to go back and verify them, so they're a little suspect.  They're also in no particular order. I'll divide them into pluses and minuses, but otherwise they're just pretty much in the order in which I was nettled by them.

Pluses:

1. The "Back" button saves whatever you've put in.  Sometimes.  In the old days, "Back" meant "discard everything I just typed in and go to the previous page." 
2. The countdown clock still shows the seconds ticking away.  I just love that.
3. If you paste in a number with extraneous spaces, the spaces are stripped out.
4. On the last couple of days, I didn't notice any significant slowdown or failure.
5. Some errors are automatically fixed (like if you put in a Service End Date outside the Funding Year on a Month-to-Month FRN).

Minuses:

1. Item 21 is a pop-up in front of the browser window (the browser window is grayed out).  If you click outside the pop-up but inside the browser window, it makes the pop-up vanish, and any info you put in vanishes.  So if you've completely filled the attachment, but you want to switch to the vendor's bid to check the price of one of the items, when you click back in the browser window, beware!  Click on the grayed-out part of the window, and you have to start over again.  On a big Category 2 FRN, it's an easy way to lose a half hour's work.
2. Why do I have to make a selection under Burstable Bandwidth for an FRN that's just POTS lines?  [Perhaps the programmers thought Burstable POTS was a clever shout-out to Legend of Zelda?]  At least you can leave the bandwidth fields empty.
3. You can't paste in an amount if it has a dollar sign or comma in it.  You don't get an error message, it just acts like you never pasted.  After pasting 3 times and seeing nothing happen, I figured something was up and starting stripping out punctuation.
4. It's tedious to have to fill out several pages where you used to have only one.  Block 1 used to be one page, now it's several pages.  Simpler pages, but still.  And Block 5 is a dizzying array of pages, popups and buttons.  But I guess most of the extra Block 5 pages are the result of the amazing increase in the complexity of Block 5.
5. If you import Block 4 from a Category 1 application into a Category 2 application, it doesn't fill in the enrollment in the Budget Calculation section, even though the enrollments are right there in the Discount Calculation Worksheet.
6. Chrome autofill doesn't work.  Not a big deal for normal applicants, but I was grinding my teeth every time I had to type my Consultant ID again.
7. If an Item 21 item has only one entity, you have to check that services are shared equally among all entities.  I want it to say "shared equally among all entity."
8. Item numbers are gone.  No longer can I say: "Whatever you do, don't check Item 23f" or "The person in Item 6a should be the person who will answer application reviewers's questions."  It was handy shorthand for us E-Rate geeks.
9. We still have "Item 21 Attachments," even though there is no Item 21 any more.  It was unfortunate jargon before, but now it's just inscrutable.
10. Tab order is messed up.  For example tab from Item 23d and you end up at the "Certify Online" button, which is definitely not where you want to be, because you still have to check all those certifications.
11. Why force people to check all those boxes in Block 6?  Why not just one big fat certification?  It would streamline the process to have applicants ignore one big certification rather than having to ignore a dozen little ones.
12. You can't tab from checkbox to checkbox on the Certifications page.  Block 6 used to be: click the first box, tab, space bar (which checked the box), tab, tab, space, tab, type in some number for 23d, tab, tab, space, tab, space, tab, space, tab, space, tab, space, tab, space, tab, space, tab, space, tab, space, tab, space, tab, space, tab, space, tab and then you're filling in certifier information.
13. Those certification checkboxes are too small for a man of my age to click in reliably.  When my laptop wasn't docked to a big screen and mouse, it was taking me 2 or 3 attempts using the trackpad and the little screen.
14. Why do I have to give a bandwidth for dark fiber?  It's dark; it doesn't have a bandwidth.
15. Some of the fixes are too automatic.  If you put a date outside the funding year for a Month-to-Month service, the system automatically fixes it.  That's great, except maybe you checked MTM by mistake, and if a message popped up saying "Hey, you put in the wrong date, but it's fixed now."  Actually, an error message does appear for a moment, but it vanishes instantly as the form fixes the date for you.
16. And sometimes those autofixes are weird.  When you type a date into the contract expiration date box in Block 5, if you type two digits for the year, it automatically adds the "20"; cool!  But wait, it changed to "6/30/16" to "6/29/2016."  And if you click in there and try to change "29" to "30," you end up some time in the year 2199.  So check it out: type in "6/31/16," and it will become "6/30/2016."  I spent way too much time trying to imagine what algorithm would unintentionally cause that behavior.
17. In Block 5, if you check "Yes" under "Is every entity on this application receiving the product or service in this line item?" then go back to Block 4 and add a new entity, unbeknownst to you, the box unchecks itself, and the new entity is not part of any funding request.  Seems to me if you checked Yes to every entity sharing, that should include entities added later.  And even if it doesn't, you should get a warning that adding an entity in Block 4 changes Block 5.
18. Sometimes if you make an error in a pop-up window, the window goes away, and you think you've accomplished whatever you were in that pop-up to do, when in fact you need to go back and do it over.
19. If you aren't ready to put numbers in the Discount Calculation Worksheet, for God's sake don't click in there.  Once you've clicked there and opened one of those text boxes, you can't do anything else until you put a number in there.  You can't even log out of the application. I was stuck in that box when the system logged me out for inactivity, and I was completely locked out, looking at a grayed-out window (with the countdown clock ticking away) and a pop-up saying: "Number of Students Attending this School as their Home School is required." I had to close the browser window.

Overall, the form was better than I expected, and less quirky, but any new form will have its oddities.

I was disappointed that we didn't find any new Stupid 471 Tricks, but we'll keep looking.