Better late than no-waiver

Another batch of remands today. Kind of boring: 13 cases of applicants cancelling funding requests without meaning to. (OK, so some of the applicants are claiming that they never did cancel the request and it was all USAC's fault. Whatever.) Only two things struck me about the order.

First, while I doubt that this order will be used as a precedent in many cases, if it is, it will probably be referred to as the Jingoli Order. Not as good as Bishop Perry or Academia Discipulos, but it has a nice Jersey ring to it.

Second, while at least one of the appeals (Nemaha) was filed over 4 years ago, one was received as recently as May. It gives me hope that some of the appeals I have languishing over at the FCC will get a response this year.

Online BEAR: thumbs up!

Well, I feel like we've run a pretty good test of the Online BEAR, and it gets thumbs up around here. It's a solid Web app, probably USAC's best.

Things I like:

1. A surprising number of service providers were ready to use the system.
2. I can use the browser Back button.
3. The list of invoices is great, and having the invoice numbers be hyperlinks is good.
4. Having the name of the certifiers be a link providing contact info is sublime.
5. You can right-click on a link and pop it open in a new window, cut and paste back and forth, etc., and the thing doesn't break.

Things I don't like:

1. The validation subroutine should be robust enough to strip out commas, dollar signs, spaces, etc.
2. You can't cancel an invoice once you've submitted it.
3. You can't amend an invoice once you've submitted it.
4. Service providers can't amend an invoice before approving it.
5. The notification emails are useless. All notifications should include FRN, BEN and SPIN at the very least. It would be nice to have applicant and service provider name, as well as the amount. It would also be nice if the "View BEAR Form" link at the bottom of the email actually worked. [I've heard that some people see the login screen when they click that link, but I just get redirected back to the SLD main page. Why log in? Is a completed BEAR some kind of secret? As I griped in items 3 and 4, no one can change the form once it's submitted. Shouldn't John Q. Public be able to see it at that point?

Numbers 3 and 4 should be on the list of features for the next upgrade. As it stands now, I end up cancelling a lot of invoices because the service provider doesn't agree with my numbers. They should be able to send me a note saying, "Cut the pre-discount by $5," then I change and resubmit. Even better, the SP should be able to change the pre-discount amount, certify, and bounce it back to me to re-certify.

But let's hope that before the next upgrade, this silly SP certification of BEARs goes away.

Bells and whistles I'd like to see:

1. After I log in and choose to start a new form, the first thing I see should be a list of FRNs which I might invoice. The list would show funding year, FRN, SPIN, service provider name, and funding available. I'd just type a pre-discount amount next to one of the FRNs, click a button, and poof, I get a form with everything filled in except the form identifier.
2. On the existing form, when the discount percentage pops in, so should the funding remaining in that FRN.

All in good time

It's official: this year's filing window will open on Nov. 7th and close on Feb. 7th. The USAC board approved a January 24th closing, but thank goodness, the closing has been returned to early February.

93 days! I think that's the longest window ever. Poor Mel (Blackwell): he wants a shorter window, and we're going the opposite direction. Of course, what Mel really wants is an earlier closing. In this case, I hope he doesn't get what he wants.

I, on the other hand, want a later closing for two reasons. The first is that forcing people to sign contracts for technology purchases at least six months before the purchase is made just isn't cost-effective. And forcing people to sign contracts and certify "secured" funding so far in advance of budget approvals puts applicants in an untenable position.

The second reason is based on one of the laws (well, one of my laws, anyway) of organization: a process will expand to fill the time allotted to it. So if the window closes at the end of April, the PIA process will shrink in order to process all those apps in two months. If the window closes in late December, the PIA process will expand to fill the extra weeks. So now let's have a show of hands: who wants an expanded PIA process? All right, I see a few hands up in the back, must be GAO or OIG observers. But I don't think even Catriona Ayer, the head of PIA, really wants to see the process go any further into the minutiae of funding requests.

Just imagine if PIA only had two months. I'll bet credits to navy beans that if your request was for Telecommunications Services, and less than $3,000 (which is about the median for the program), PIA review would consist of a spell-check. And you know what? The program wouldn't be any worse off: telecom is too highly regulated to be easily abused, and there's no point in trying to skim a percentage off $3,000. It's almost not worth it to do all the E-Rate paperwork for $3,000.

So the later the window closes, the more PIA will be forced to focus its effort on the areas that really deserve scrutiny, and leave in peace the 80% of applicants who just want a little help paying their measly phone bill.

Bring you Macs

Last week's News Brief had a little tidbit that surprised me: the System Requirements for USAC's online forms includes Mac OS 9. Last I knew, USAC didn't support Macs. What a welcome change. The online forms just keep getting better. Except, ironically, the "Submit a Question" application. I still get an error about half the time I use that dog.

And all the tips for completing forms were useful, too. One editing suggestion: they should have added spaces to the list of things to avoid when entering costs. Here's my tale of woe. When you copy and paste an Excel cell, depending on the formatting of the cell, the number sometimes goes in with spaces before and after the number. In the online BEAR, if you paste such a number into the Pre-Discount total field, then hit the "Tab" key, the discount amount calculates correctly. But then when you finish the rest of the form and hit the Submit button, you get an error message saying that the pre-discount amount has to be a number. And since you can't see spaces, the number looks just fine. I confess to saying unkind things about Mr. Kraft and the Solix development team until I figured that one out. But now I just delete the spaces and all is well.

This weekend?!

USAC has announced that in order to be ready for the opening of the 2008-2009 window a week from Wednesday, they will be performing maintenance on their systems this weekend. You've got to be kidding.

First of all, the announcement came out on Friday. I have a general beef with USAC taking its systems down with little or no warning. Did you know, for instance, that the Data Retrieval Tool is frequently unavailable from 9:00 to 11:00 p.m.? (It maybe every night; I haven't tested it.) I realize that the downtime does not affect normal users, and that it is a sad comment on my life that I am even aware of the outages. But putting aside whether the E-Rate has taken over too much of my life, my complaint is that when you're going to have a system outage, you give users notice. In the case of one-time, non-emergency outages like those planned this weekend, a week's notice would be fair, two weeks would be better. (OK, I know the FCC barely gave USAC any notice of the window opening, but the timing is hardly a shock.) In the case of routine outages like the DRT being out most nights, that information should be published on the USAC Web site somewhere.

Second, the timing is foolhardy. The announcement says, "any interruptions should be of minimal duration." In the IT profession, we call such statements "famous last words." Of course interruptions should be minimal, the same way that my kids should do as I say. But IT systems can be as unruly as my children. In any change to a system as complex as the USAC IT infrastructure, there will be unexpected results. I actually think that USAC has a pretty good record when they make system upgrades, but that means that the glitches are minor and quickly repaired, not that upgrades go off without a hitch.

In general, I have to question the choice of a weekend to do upgrades. If I (or any other sad individual unable to leave the E-Rate alone for a whole weekend) find a problem, my only option for reporting it is to use the incredibly lame "Submit a Question" (SAQ) application on the Web site. First problem: SAQ is finicky in the best of times, and if there's a system problem, it may become collateral damage. Second problem: if all goes well, my complaint goes into a Client Service Bureau (CSB) mailbox, where it will languish until Monday morning. My perception is that Solix (who seems to doing the systems work) does not have a big team of QA people testing the Web site after every change, so many glitches are discovered by users. That's OK with me, but only if the users have a way to report the glitches immediately.

So with two major deadlines coming up on Monday, I don't think this weekend is the optimal time to make system changes.

USAC creates more waivers

It's not on the USAC site yet, but a reliable source tells me that USAC has decided that the filing window will open November 7, 2007 and close January 24, 2008. Bad move. That early end date is a bad idea in the big picture, but especially bad for this year.

Big picture: If the FCC wants applicants to certify on the Form 471 that they have "secured funding" to pay the applicant share of costs, then the deadline for the 471 should be in late April or early May, when many applicants secure funding for the following funding year. (Some applicants don't secure funding until after July 1, but I don't know how to help them.) The earlier you move in the year, the earlier you move in the budget formulation process, the more meaningless that certification becomes.

For this year: USAC has been saying at the trainings that the window would close in early February. By closing it in the third week of January, they're going to cause a lot of people to file late. And you know those people are going to request a waiver from the FCC, and they're going to get it, only they won't get it until well into the funding year and it creates extra paperwork for everyone.

I hope the FCC is prepared for the wave of appeals coming.

Gentlemen, start your engines!

The Eligible Services List (ESL) for the 2008-2009 funding year has been released. I'll have comments on the list I'm sure, but probably not until after BEAR season ends. There don't seem to be any big surprises.

The big news with the actual release of the ESL is not eligibility, but timing. For the second straight year, the list was released on Oct. 19th. That's too late. When the FCC started the current ESL process (public comment and FCC approval of the list), they set a rule that the list must come out 60 days before the opening of the window. They have never even come close. This year, we got 19 days.

The 60-day waiting period is a good idea. A change in the ESL can make a change in an applicant's purchasing plans. That change may require an amendment to the technology plan, which has to done before filing the Form 470, which should be done 28 days before the opening of the window. With only 19 days, you can't even get a 471 filed at the start of the window unless you filed a 470 before knowing what would be eligible.

True, there is plenty of time within the filing window to file the 470 and then the 471, but that's not behavior that the FCC should be encouraging. Mel Blackwell has said that he'd like to shorten the filing window, since we all file in the last 2 weeks of the window, anyway. In order to make that change, applicants have to get used to filing the 470 before the window opens. The FCC is making that very difficult.

In the notice announcing the release of the ESL, the FCC authorized USAC to open the window on November 7th. Why? Didn't Mel Blackwell stand up and say that the window would start in mid-November and end in early February? Why open the window so early? I think there will be much wailing and gnashing of teeth if the window closes before, say, February 8th. That would give us a 93-day window. Mel said he wants to shorten the window, and we get this.

The FCC should have opened the window on November 26th. A shortened window would be best achieved in increments: cut it to 74 days this year, then 60 days next year, and so on. But part of the key is actually having the ESL come out 60 days before the window opens. Gradually, applicants will get used to filing the 470 before the opening of the window.

Plus, of course, the FCC would be modeling good behavior by meeting deadlines, instead of waiving its own rules every single year.