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Monday, October 12, 2015

C2 Budget Anschluss

This week's headache?  "Annex."  The latest USAC News Brief includes a new type of entity: the Annex.  In the past, I have whined about the peculiar status of single schools with multiple locations. Having to create a separate BEN for those locations was unnecessary and an added complication.  Apparently someone at USAC agreed that it was unnecessary, but felt the complication was insufficient, so now we have even more complication.  Now we get another type of entity.

At this point, USAC should abandon "entity" and just adopt the term "thingy," because an annex doesn't get a BEN, and does not exist separately from the main school location, so it's not really an "entity."

I'm all for clarity, but this new thingy does not clear things up.

Let's say my little private school bought the house across the street, and put an art studio on the first floor, where all the kids go to art, and a music room on the second floor, where some kids go for band practice.  Last year, it was an entity, with its own BEN.  This year, the main location does an Anschluss, and it's an annex.  What if they get tired of moving kids across the street, and put the development office into the art studio?  Is it still an annex?  Some kids do go in there during the day.  The development office gets tired of the screeching violins, and the band practice gets moved across the street.  Can it stay an annex?  What if the band practices there, but only after school? The description of annex that we got in the News Brief does not mention a classroom requirement, so maybe it still qualifies as an annex.  Of course, it also qualifies as a NIF, so that's probably what you have to make it, which means you need a BEN for that thingy.  Why?  What is the difference in how a NIF is treated versus how an annex is treated?  It boils down to this: if you want to get some C2 funding for an annex, go ahead, but if it's a NIF, you can only get C2 funding if the C2 gear serves the school across the street.

(Side NIF rant.  What is a NIF?  Here's the definition (from this page): "School NIFs are school buildings or buildings on school property that generally don't contain classrooms...."  Then the next sentence says, " NIFs that contain classrooms do not have Category Two budgets."  A NIF with classrooms?  That is a building that doesn't contain classrooms that contains classrooms.

But it simplifies the application process right?  Not so much.  The News Brief says I don't have to get a BEN for the annex.  Yeah, except I already have a BEN for it, because last year we needed one.  And this year, I have to create a new thingy with the same information that is in the existing BEN.  And when I import last year's Block 4, I'll have to go back in and yank out the BEN, because now that thingy is an annex, so it doesn't get listed separately.  So it's just more work for me this year.

And then comes PIA.  Since I'm creating a new thingy that is actually a thingy from last year, PIA is going to have to somehow associate the two thingies (which are actually one thingy, but have to be treated as two thingies now), in case I spent some C2 budget on the thingy back when it had its own BEN.  Annexes can't have C2 budgets, so any C2 funding I got for the thingy when it had a BEN can't be transferred to the annex.  (Wait, would it be a transfer, since we're talking about the same thingy?  Oh, my aching head.)  Somehow USAC is going to have to kludge the former-BEN-now-annex's C2 funding into the main location's BEN's C2 budget.

At first, I felt a little schadenfreude glee that the C2 budget for a BEN-become-annex will be a bigger headache for USAC than for me.  But based on past experience, I expect that the kludge will not exist when PIA reviews start, delaying my clients' applications, and when the procedure for shoehorning a BEN-become-annex's C2 funding into a main location's budget will require a lot of extra work for me.

And why?  Now that we have district-wide discounts, the only reason to list thingies in the "Discount Calculation" section of the 471 (née Block 4) is so that C2 funding can be allocated to those thingies that have C2 budgets.  It would really simplify the program if we had C2 budgets that were district-wide (or private-school-wide or library-system-wide).  (I would call for "organization-wide" C2 budgets, but alas, USAC is now using "organization" as a euphemism for "entity," so "organization-wide" could mean "district-wide" or "school-wide" or "campus-wide" or "bookmobile-wide.")   Location-specific budgets are a bad idea.  Attach C2 budgets to FEINs, and we no longer need NIFs, annexes, C2 cost-allocations, etc., etc., etc.

Yes, having BENs for annexes was an unnecessary complication, but as usual, the reaction is not to remove the complication, but to create a whole new set of rules.

Wednesday, October 07, 2015

An entity by any other name smells as sour

Time for the annual running of the entities.  Once again, USAC's News Brief tries to clarify the muddled meaning of "entity."  I've been griping about this at least since 2007: instead of trying to draw an inconsistent distinction between "billed entity" and "entity," start using "organization" and "location."

And when I log into EPC: happiness!  Right there at the top: "Organizations."  Yes!  Now please tell me that they consistently separated "organization" from "location."  No, alas, they just sometimes substitute the word "organization" for "entity."  So if you want to search for a school, you have to go to "Records" then click on "Applicant Entities."  At least you can filter by entity type to see only schools (unfortunately, while "school" means "location" for districts, for private schools, it might mean organization, location or both).

A worse sin: if you open the record for a school, right at the top, it says "Organization."   No!  Likewise, if you bring up a school district's record, then click on "Related Entities," you get a list of schools under the heading "Organizations."  When USAC used the vague term "entity," they could apply it to anything, but a school is not an organization.  It's a location.

So instead of clarifying things, they've just started using "organization" as an occasional euphemism for "entity."  Just look at the "Applicant Entities" page: you can filter by "Organization status" or by "Entity type."  Could you at least be consistent on two headings that are right next to each other?

Ugh.  So the situation is even worse.  Instead of a distinction between organizations and locations, we just get another word for "entity."  And I have to think that it's too late to overhaul EPC, so the muddle will just go on.

The News Brief makes clear that if your school district's main location is an administrative building (NIF), then you need to have a BEN for both the district and the admin building.  Two BENs, one address.  Hey, that's good: USAC is finally trying to make a distinction between the organization and the location where it's headquartered.  And for school districts with no separate admin building, the distinction has always been there: if the district office was located in the high school, there were separate BENs for the district and the high school.  The distinction even existed for one-building districts, though I see a lot of them mistakenly using the school's BEN in Block 1, where the district's BEN should go, or the district's BEN in Block 4, where the school's BEN should go.

But libraries and private schools are not treated the same.  A single-location library or private school has only one BEN, so it is used for both organization and location.  And in the case of libraries with more than one branch and private schools with more than one campus, the main location's BEN is used as the organization BEN covering all the locations.  Shouldn't USAC be requiring libraries and private schools to get either a new BEN for the organization or a new BEN for the main location?

Alas, the entity mess goes on.

Thursday, October 01, 2015

The view from the top

If you're big enough E-Rate geek to read this blog, you've certainly seen Mel Blackwell's Letter to the Field.  I think that, as usual, he strikes a pretty good balance between being positive and being frank.

While he notes that USAC very nearly hits its goal of processing all the "workable" apps by Sept. 24th (well, there was a big batch of FCDLs that came out Sept. 25th, but that's close enough for government work), he does note that 6,000 applications are "unworkable," and expects that most will be processed within 90 days.  "Most" means at least 3,000, so it's possible that close to 3,000 applications will be languishing 90 days from now, which is half-way through the funding year.  And Mel admits that the remaining applications tend to be larger than average.

What is "workable" anyway?  The E-Rate Modernization Order gives us this definition:
“Workable” means that a funding request is filed timely and is complete, with all necessary information, to enable a reviewer to make the appropriate funding decision, and the applicant, provider, and any consultants are not subject to investigation, audit, or other similar reason for delay in a funding decision. Funding requests from applicants that decline to respond to USAC inquiries over the summer may be considered “unworkable” for purposes of this performance goal, though USAC will process these applications as quickly as possible when school staff return for the year. 
Doesn't "...with all necessary information, to enable a reviewer to make the appropriate funding decision..." exclude most applications?  It would seem that if PIA needs to request information from the applicant, the application is unworkable.  Unless they streamline PIA procedures dramatically, most applicants will have to supply additional information to PIA, in part because even though the Form 471 is more detailed than it used to be, it still does not collect all the information that PIA needs.  It seems to me that if the Form 471 doesn't collect the necessary information to allow 6,000 applications to be processed, the form has some serious shortcomings.

But back to the letter.  We get promises about how much better EPC will make our lives, but also acknowledgement that the roll-out has not been flawless.  I particularly appreciate Mel saying, " the accelerated timing of the deployment did not allow for adequate user testing."  I think that more could have been done to bring the applicant and service provider community into planning meetings, but I guess they can't let anyone look behind that curtain, since the FCC considers the application process to be a law enforcement activity whose workings need to be kept secret from the public (and the people going through the process).

But here's some good news: "We are committed to...user testing for the new EPC-based FCC Form 471 filing process."  Where do I sign up?