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Saturday, March 18, 2017

Index? What index?

At first, I thought, "Oops!"  Then I thought, "Wait a minute!"  Then I thought, "What the hell?"  Then I thought, "Holy crap!"

Earlier this week, I blogged about the increase in the $150-in-5 cap to $151.50 for 2017-2018 due to an inflation index, and whined about how the increase was lower than it should have been.  Then today, I read on Funds for Learning's site that the increase to $151.50 was for FY 2016-2017 (a 1% increase), and the FY 2017-2018 cap was increased to $153.47 for  (a 1.3% increase).  "Oops."

But "wait a minute," I was sure that wasn't what E-Rate Central said.  I checked, and while they have the correct information up now, they do have a footnote acknowledging that they had earlier had the info I used for my reckless blog.

"What the hell?"  Why are we finding out about this because E-Rate Central noticed that the Category Two Budget Tool was using $151.50 for FY 2017-2018?  The FCC has said nothing.  USAC has said nothing.  How is it that this change is being made without telling anyone?  How is it that this change was made last year without telling anyone?  Why are we forced to rely on E-Rate consultants to make this public?

"Holy crap!"  Why didn't anyone notice the increase for FY 2016-2017?  Because it didn't happen.  USAC used $150/student to calculate FY 2016-2017 C2 budgets, and forced applicants to reduce their funding requests to fit under $150/atudent.  Wow.  All those applications were incorrectly reduced.

But what now?  For most of those applications, it's been more than 60 days, so the reduction can't be appealed.  And technically, PIA didn't reduce the applications.  They just told the applicants that they were over budget, and made the applicant tell them what they wanted to remove from the request.

If USAC correctly handled requests that are over budget, the fix would be simple.  See, what PIA does now is say that if a request goes over $150/student, the excess is ineligible.  Wrong.  It's still eligible, just over cap.  It should be handled the way USAC handles invoices that are over the committed amount; you put the full amount on your invoice, and USAC just says, "Yeah, we're only giving you what you were approved for."  Likewise, in the case of a request that exceeds the $150/cap, the Committed Amount should just be reduced to the cap.  If USAC had just done that, they could now just say, "OK, we'll just up those FRNs to what the cap should have been."  That wouldn't be a complete solution.  Those applicants that reduced the size of their request before applying would still be screwed.  But at least some of the damage could be easily repaired.

By the way, I checked the Category Two Budget Tool, and it looks to me like it's currently using $150/student to create budgets.  Am I missing whatever E-Rate Central spotted, or did someone change the tool back?

I have complained about the secrecy in this program since 2006, but now we've reached a whole new level: rules so secret, even USAC didn't know.

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