Somehow this one seems to have snuck up on everyone. You know all those terrible audits? The ones where CPAs who hadn't known of the existence of the E-rate until a month or two before they arrived at school sites to sit around for a couple of weeks dreaming up ways to look busy? Well, for the most part, they're history.
As Mel Blackwell promised last year, the audits are looking much better this year. In fact, they aren't even calling them audits. IPIA requirements will be met by the Payment Quality Assurance (PQA) Program, and it feels more like a Selective Review than an audit. No on-site visit, fewer ridiculous document requests.
There will still be audits, but not by the hundreds (I hope).
It's time to celebrate!
Tuesday, August 17, 2010
Tuesday, August 10, 2010
Hate the new PIN
Anyone else notice that the system for assigning PINs has been out of commission for quite a while? Well, it's finally unstuck, which is good news.
The bad news? The new PINs are more secure, which means they're much less catchy. PINs used to be a 6- or 7-letter word, with a special character like & or + at the beginning or end. I already mentioned that some of combinations seemed oddly apt for the particular applicant.
But the new PINs are random combinations of letters, numbers and special characters. Sure, it's more secure, but it looks like someone ate alphabet soup and vomited. Except I don't think alphabet soup includes @ or & (maybe Campbell's makes a cyberalphabet soup these days).
Just another example of simple elegance giving way to paranoid functionality.
The bad news? The new PINs are more secure, which means they're much less catchy. PINs used to be a 6- or 7-letter word, with a special character like & or + at the beginning or end. I already mentioned that some of combinations seemed oddly apt for the particular applicant.
But the new PINs are random combinations of letters, numbers and special characters. Sure, it's more secure, but it looks like someone ate alphabet soup and vomited. Except I don't think alphabet soup includes @ or & (maybe Campbell's makes a cyberalphabet soup these days).
Just another example of simple elegance giving way to paranoid functionality.
Saturday, May 29, 2010
FCC for breakfast
The E-rate is seeping further into my life. I'm making pancakes for the kids this morning, listening to "On the Media" on NPR, which is usually snarky commentary on journalistic ethics or the sorry state of print journalism, and this piece about the FCC's new direction for Internet regulation comes on. Even my Saturday morning is not safe from E-rate (I'm feeling anarthrous today).
And a colleague sent me the agenda for the FCC's next meeting, which is going to be all about whether Internet access is going to become a "telecommunications service" or remain an "information service." The three directions they are considering:
And a colleague sent me the agenda for the FCC's next meeting, which is going to be all about whether Internet access is going to become a "telecommunications service" or remain an "information service." The three directions they are considering:
- Leave it an information service.
- Make it a telecommunications service.
- Make it a telecommunications service, but then waive most of the regulations that apply to telecommunications service.
I know which direction I'm betting on. The FCC has not been very consistent on most things, but they are generally consistent on this: if there is a simple solution and a complex one, they'll take the complex one.
As far as I can see, the two big questions for E-rate:
- Will the Internet Access category on the Eligible Services List vanish?
- Will Internet service providers be forced to pay into the Universal Service Fund?
I'm guessing that IA will vanish. Apparently digital transmission can be offered under IA, and since 2006 so can voice (VoIP), so the distinction is becoming meaningless.
My crystal ball says that all broadband providers will have to start paying into the fund.
Thursday, May 27, 2010
COMADness
OK, now this appeal gets my goat. Some little library is getting a little funding for their phone line, and USAC drops an audit on their heads, and then COMADs them for not being able to document the number of bids received.
First of all, who says the district has to create documentation of the number of bids? If the FCC wants to have that information, then it should be on the Form 471. I know, it would make the form more complex, but it wouldn't make the application process more complicated. It just makes it obvious how complicated the process is.
Second, the recovery amount is $486. How did an applicant this small get audited in the first place? And how about we have a bid threshold like government purchasing law at every other level of government everywhere? Making a purchase under $1,000? No bid necessary. At least the FCC seems to be moving in that direction with the NPRM. And what is the de minimis level on COMADs? Because I guarantee that this COMAD has already cost more than $500, and now that it's been appealed to the FCC, the cost is going into the thousands.
What a waste of everyone's time.
First of all, who says the district has to create documentation of the number of bids? If the FCC wants to have that information, then it should be on the Form 471. I know, it would make the form more complex, but it wouldn't make the application process more complicated. It just makes it obvious how complicated the process is.
Second, the recovery amount is $486. How did an applicant this small get audited in the first place? And how about we have a bid threshold like government purchasing law at every other level of government everywhere? Making a purchase under $1,000? No bid necessary. At least the FCC seems to be moving in that direction with the NPRM. And what is the de minimis level on COMADs? Because I guarantee that this COMAD has already cost more than $500, and now that it's been appealed to the FCC, the cost is going into the thousands.
What a waste of everyone's time.
FCC jetty
Just when it seemed the FCC would waive anything as long as there was no waste, fraud or abuse, they've found a deadline it won't waive without a compelling reason: the deadline for filing an appeal. Yesterday they denied 104 appeals that were filed late.
That seems like a reversal of precedent to me, but I'm too lazy to go back and try to find late appeals that were granted in the past.
On the one side, it seems odd to say that you can file a Form 471 late for no good reason, but you can't file an appeal late.
But I think the FCC may have been forced into this, because the appeals thing was getting out of hand. Some of the appeals that they denied were filed years after the appeals deadline, because applicants saw the about-face that the FCC made with Bishop Perry, and realized that under the new kinder/gentler FCC, they could win an appeal. And I have seen pitches from consulting companies offering to remedy past mistakes by appealing to the FCC well after the fact.
That seems like a reversal of precedent to me, but I'm too lazy to go back and try to find late appeals that were granted in the past.
On the one side, it seems odd to say that you can file a Form 471 late for no good reason, but you can't file an appeal late.
But I think the FCC may have been forced into this, because the appeals thing was getting out of hand. Some of the appeals that they denied were filed years after the appeals deadline, because applicants saw the about-face that the FCC made with Bishop Perry, and realized that under the new kinder/gentler FCC, they could win an appeal. And I have seen pitches from consulting companies offering to remedy past mistakes by appealing to the FCC well after the fact.
Tuesday, May 25, 2010
PIA peeve
OK, I just can't hold this one in any more:
When you do an online Item 21 Attachment, on the Line Item Detail screen, there is a link that brings in the dollar amounts from the 471. That's really handy, but in past years you always had to remember to click that link first, because it erased everything else. This year there is a new "feature": you can't click that link until you've selected the service type from the drop-down. But of course when you click the link, it erases the service type you just had to select, and you have to select it again.
How did they not catch that during testing?
When you do an online Item 21 Attachment, on the Line Item Detail screen, there is a link that brings in the dollar amounts from the 471. That's really handy, but in past years you always had to remember to click that link first, because it erased everything else. This year there is a new "feature": you can't click that link until you've selected the service type from the drop-down. But of course when you click the link, it erases the service type you just had to select, and you have to select it again.
How did they not catch that during testing?
Thursday, May 20, 2010
Christmas in May
I just got the new NPRM from the FCC, and have only had a chance to skim a few parts of it so far. My initial reaction: "Holy crap!"
This is real reform.
A few standouts so far:
"We propose to...eliminate E-Rate technology plan requirements for priority one applicants...."
"we propose to eliminate the requirement that applicants for priority one services file an FCC Form 470...."
"One option would be to allocate funding for internal connections based on a per student cap...."
"Eliminate the 2-in-5 rule...the 2-in-5 rule has not served its intended purposes."
I feel like a kid on Christmas morning.
There are proposals I'm not so hot on (the suggested wording of the codification of competitive bidding is rather Grinchy), proposals I'll have to think about (making all Basic Maintenance ineligible; Scroogey?), and proposals that are mostly great, but need some tweaking (the equipment disposal rules). But those are like getting socks from Aunt Martha: disappointing, but they don't spoil the holiday.
This is real reform.
A few standouts so far:
"We propose to...eliminate E-Rate technology plan requirements for priority one applicants...."
"we propose to eliminate the requirement that applicants for priority one services file an FCC Form 470...."
"One option would be to allocate funding for internal connections based on a per student cap...."
"Eliminate the 2-in-5 rule...the 2-in-5 rule has not served its intended purposes."
I feel like a kid on Christmas morning.
There are proposals I'm not so hot on (the suggested wording of the codification of competitive bidding is rather Grinchy), proposals I'll have to think about (making all Basic Maintenance ineligible; Scroogey?), and proposals that are mostly great, but need some tweaking (the equipment disposal rules). But those are like getting socks from Aunt Martha: disappointing, but they don't spoil the holiday.
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