Those librarians have some good ideas

The ALA has created a nice sheet about what should be Delete!Delete!Deleted! from the E-Rate program. Let's see if I agree with their suggestions. 

Here's what they'd like to see deleted: 

1. FCC rules on competitive bidding
2. Form 486
3. Annual NSLP checks
4. Application window for C2
5. Inability to make service substitutions

To which I say:

1.  Oh, hell yes! I've been saying for years that the FCC should not be regulating the purchasing decisions of local governments. The arcane rules confuse applicants and conflict with local rules.
2. A solid yes. C'mon, FCC, you already did it for the Cybersecurity Pilot Program: move the CIPA questions to the 471 and scrap the 486.
3. The ALA is suggesting that NSLP percentages get checked once every 5 years, to coincide with the 5-year cycle for Category 2 budgets. I'm all for that. Treat it like the C2 budgets: fixed for 5 years, unless the district wants to change it (if the enrollment and/or NSLP percentage changes to the district's advantage).
4. Why only for C2? We never come close to the program cap these days, so why do we need a filing window? There's plenty of money to go around, and the filing window was created to deal with funding requests exceeding the program cap. Ban the filing window! Want to change your Internet bandwidth in December? No problem, just file a new application. One of your switches starting smoking in January? File an application right then. (Combine this with #1, and you don't even have to wait 28 to make the purchase.)
5. If #4 would come true, there would be no need for service substitutions. Just file a new application. It seems like it would be worse to have to do a 471 for the new service and a Form 500 for the old funding, but it only seems that way if you've never had to do a service substitution; those things are a real PitA. But assuming that we're stuck with the filing window, then yes, applicants should totally be able to increase bandwidth or whatever. Service subs are way too restrictive.

You know what would make service substitutions better? Get rid of FRN line items. Why does the request have to be broken down into a bunch of little buckets? Because whoever made the online form decided to handle things that way; from 5,000 feet up, it looks more efficient. But let me tell you, down here in the trenches, those line items are a major hassle. Just make one big bucket of money, and if you must, list all the equipment or services paid for by that bucket. Then just change the list of items, and don't bother with the size of the bucket of money. Because if the change in items makes the price go up, no prob: E-Rate online funds the original size of the bucket. And if the change makes the price go down, then that gets cleaned up by a Form 500. FRN line items add complexity to the process for no good reason, just because whoever created the online 471 thought they were elegant and cool. They aren't.