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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.

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