Well, they did ask

 Want to give Congress a piece of your mind about the E-Rate program? Now's your chance.

The Congressional Universal Service Fund (USF) Working Group has put up a form to submit comments. (You can also email comments to USFWorkingGroup@fischer.senate.gov.) The questions are pretty wide open, so you can let Congress know how you feel on any USF-related topics.

For me, nothing springs to mind for the questions in the Effectiveness section, but the Reforms section has my mind whirring.

The first question:

What reforms within the four existing USF programs would most improve their:
- Transparency;
- Accountability;
-Cost-effectiveness;
- Administration; and 
- Role supporting universal service?

Transparency: How about making public the 700-page book of procedures for handling applications?

Cost-effectiveness: Cut the top discount rate to 65%.

Administration: Stop making applicants go out to bid for $1,000-a-month Internet. Wait, what am I saying? Get the FCC entirely out of the business of regulating the purchasing practices of local government entities.

Role supporting universal service: Triple the C2 budget for applicants. The current level is completely inadequate.

Second question:

 What reforms would ensure that the USF contribution factor is sufficient to preserve universal service?

Expand the revenue base; most of the increase in the contribution factor is due to a decrease in the contribution base. ISPs are the main beneficiaries of the E-Rate program, so they should be paying into it. I mean, voice service isn't even eligible any more, so why should voice service alone pay into the fund? Let's toss in big edge providers, too, who benefit mightily from school children learning to use the Internet.

 

Third question:

What reforms would reduce waste, fraud, and abuse in each of the four USF programs? 

Looking just at the E-Rate, getting the FCC out of regulating purchasing would help cut waste by allowing schools to have service providers suggest configurations before going out to bid; applicants could choose the most cost-effective configuration, not just the only configuration they happen to know of.  I think requiring electronic deposits for reimbursements has made fraud much more challenging. To cut fraud further, require that applicants use an E-Rate management professional; since E-Rate is all we do, we can spot shady deals, and since our entire livelihood is the E-Rate, we steer well clear of fraud. To cut abuse (and waste), cut the top discount to 65%.

Fourth question:

What actions would improve coordination and efficiency among USF programs and other FCC programs, as well as broadband programs housed at other federal agencies? 

Oh no, don't tell me overbuilding is going to come up in Congress, too. Seriously, I can't think of any efficiencies to be gained by coordinating the E-Rate with the other USF programs. 

Sixth question (I skipped #5):

Is the USF administrator, the Universal Service Administrative Company (USAC), sufficiently accountable and transparent? Is USAC’s role in need of reform? 

According to the FCC's response when I made a FOIA request, USAC's routine processing of applications is a law enforcement action, so their procedures are secret. Make those procedures public.

That's enough ranting for now.