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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.

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