A Modest Proposal

After a conference call today listening to normally circumspect people throwing rocks through the filing window, it occurred to me that instead of extending the filing window, we should reset it.  Instead of acting like it's just a little extra hassle this year, USAC and the FCC should acknowledge that the current status of the forms is unacceptable, and close down the window, reopening when the forms are ready.

Does that seem extreme?  Well, consider a statewide consortium.  The number of entities on their Form 470 is autofilled by the system, based on the data in each of the billed entities in the consortium.  So until every entity has created an Account Administrator and corrected the hash of related entities (which did not import into the new system correctly for a large number of applicants), checked parent/child relationships, converted BENs to annexes as necessary, etc., etc., the consortium can't file a correct 470.

And there are elements of the system that worked last week, but don't work this week.

It's just not fair to ask applicants to use a filing system that isn't even stable, much less complete.

So let's open the window when the forms are complete and stable.

We wouldn't need as long a window, since applicants will have prepared once already.  But the FCC has hinted that they want 60-day bid periods for complex fiber builds, and we should allow those applicants to have 2 weeks to review proposals, so we need a 75-day window.

So there's my suggestion: finalize the application system, then open the window for 75 days.  I'm guessing we're a month or two away from a stable, complete application system, so we probably wouldn't be able to close the window before the start of the funding year, but that doesn't seem as bad to me as asking applicants to use a broken system.

Freedom is the open window

In case you hadn't heard, the filing window for FY 2016-2017 has been set: February 3rd to April 29th.

Here's my annual spreadsheet of window history:

FY	ESL release	Window announced	Days to announce	Window open	60 days?	Window close	Window days
2005	10/14/2004	11/5/2004	22	12/14/2004	61	2/17/2005	65
2006	11/22/2005	11/23/2005	1	12/6/2005	14	2/16/2006	72
2007	10/19/2006	10/20/2006	1	11/14/2006	26	2/7/2007	85
2008	10/19/2007	10/28/2007	9	11/7/2007	19	2/7/2008	92
2009	11/21/2008	11/24/2008	3	12/2/2008	11	2/12/2009	72
2010	12/2/2009	12/3/2009	1	12/3/2009	1	2/11/2010	70
2011	12/6/2010	12/10/2010	4	1/11/2011	36	3/24/2011	72
2012	9/28/2011	11/22/2011	55	1/9/2012	103	3/20/2012	71
2013	9/27/2012	11/13/2012	47	12/12/2012	76	3/14/2013	92
2014	10/22/2013	11/20/2013	29	1/9/2014	79	3/26/2014	76
2015	10/28/2014	12/19/2014	52	1/14/2015	78	3/26/2015	71
2016	9/11/2015	1/25/2016	136	2/3/2016	145	4/29/2016	86

It's a whole new ballgame!  Other than the date the ESL was released and the length of the window, everything is unprecedented.

My dream of a compressed PIA review period is coming true.

Just like last year, you can complete and pay for Category 2 purchases before you file the Form 471 for those purchases, since the filing window closes after the April 1 start date for C2 installation.

Eligible vs. fundable

Here's the sort of thing I think about in the shower:

So let's say you're a district with a 40% discount looking for a VoIP/Internet bundle for FY 2016-2017.  Well, next year 40% schools will have stepped down to 0% for voice, so you're only getting funding for the Internet portion.  When you create your evaluation, only the price of the Internet should be considered in the most-heavily-weighted Price criterion, right?

Not so fast.  The rule says that "you must include the price of the eligible products and services as a factor and that factor must be weighted more heavily than any other single factor."  Well, voice is an eligible service.  Yes, your discount for that service is 0%, but that doesn't make it ineligible.  "Not funded" is not the same as "not eligible."

So even though you won't get funding for the voice, don't you have to include the cost of voice in the price of eligible services?

That's good news for applicants, since it lets you choose the overall cheapest option.  And if you get 2 bids, both for $1,000, but one of them says it's $500 Internet+$500 voice and the other says $800 Internet+$200 voice, you can choose the latter, which gets you an extra $120/month in funding.

Bonanza!

Once again, I am Chicken Little.  Back in May when the FCC decided to use the entire $1.6 billion surplus for FY 2015-2016, I predicted that the fund would get whipsawed in FY 2016-2017, as demand rose and the rollover shrunk.  Now it looks like I was wrong.

Yesterday, USAC told the FCC that it will have $1.9 billion in unused funds available to carry forward into FY 2016-2017.  Wow! An even bigger rollover than last year.

What does this mean for applicants?  It means that the fund will have $5.8 billion available for FY 2016-2017.  Even I think it's extremely unlikely that demand will exceed that number, so that means that once again, everyone will get C2 funding.

But you know I'm not going to make it all the way through a blog post without finding a little rain cloud where everyone else just sees sun.

Where did that huge carryover come from?  I don't know, but I guess part of it is the extra $2 billion that the Chairman identified back in March 2014.  He promised an extra $1 billion/year for 2 years.  So looking ahead to FY 2017-2018, the rollover might be much smaller.  And one of the reasons that demand has not been higher is that most school districts had upgraded their Wi-Fi networks for the PARCC and SBAC tests in FY 2014-2015.  Assuming a 3-year replacement cycle, 2017-2018 could see a surge in demand.  Surge in demand, drop in funding.

And looking further out on the horizon, there is a big black storm cloud, but it probably won't hit us: ADA.  The Chairman didn't say where the extra $1 billion was coming from, other than some mention of "better accounting practices," which I took to mean leveraging the fund.  That's great and efficient all, but it's not the way government operates.  The Anti-Deficiency Act says that the government can't commit to spend money that it doesn't have.  Government is not allowed to leverage.  Except the USF has an exemption from the ADA, and the Universal Service Antideficiency Temporary Suspension Act keeps getting extended, so all is well.  And the current extension doesn't run out until...[sound of record scratching]

The current ADA exemption runs out in 9 days.

Not to worry, the House is on the job, and has included an extension until 2020 in H.R.2583, which has been passed by the House and sent over to the Senate, where it's been read and referred to committee.  But H.R.3675, a pretty identical bill, got that far last year before dying in committee.

I'm not a legislative expert, so I feel like I've missed something.  Anybody know how we're going to avoid the program grinding to a halt in 9 days?

Or should it be spelled E-Moji?

Nick Shipley over at Funds for Learning is a genius.  Why?  Well, not only has he noted the unbelievable Form 470 2,000-word-lockout, but he has proposed a solution that is both ingenious and hilarious: emojis.

You should visit his blog post to see his proposed emojis.  Of course, I am inspired to add my own:

	Self-provisioned fiber
	Filing window
	Funding wave
	Form 470
	Form 471
	Form 486
	Form 472
	Form 474
	Entity
	Billed entity
	Organization
	Consultant
	Good Samaritan
	USAC
	PIA review
	Selective Review
	Cost-effectiveness review
	Audit
	Code 9
	the change applicants expected when they heard the fund had grown to $3.9 billion
	the change that applicants have actually experienced
	the change that applicants will continue to experience
	hraunfoss
	COMAD
	Data Retrieval Tool
/	Free/reduced lunch
/	Urban/rural
	Wi-Fi
&	M&C
	Axillary use (you try finding an emoji for "ancillary")
	ADA
	EPC (OK, it's not an emoji, but the E-Rate portal is every bit as difficult to navigate; now if only EPC had a humorous computer mastermind)

And here are some terms I haven't developed emojis for yet:

	Category 1
	Category 2
	WFA
	NIF
	$150-in-5
	2-in-5
	Tennessee test
	Item 21 Attachment
	Basic conduit Internet access
	Document retention
	Invoice deadline extension
	Recovery of Improperly Disbursed Funds
	Operational SPIN change
	FCC
	Service substitution
	State master contract
	Red Light status
	Remand
	CSB
	FRN
	SPIN
	Block 1
	Block 3
	Block 4
	Block 5
	Block 6
	CIPA
	Duplicative services
	ESL
	Allowable contract date
	Internal connections

Pixels are the new pink

What's got my dudgeon up today?  Envelopes.

This week's BEAR Notification Letters showed up in half-page-sized envelopes which had transparent windows taking up almost the whole front.  No complaints, there, really.  The postage franking had to be on the back of the envelope, since the paper frame around the window on the front was too narrow to accommodate the postage meter's stamp.  But that's no skin off my nose.

Meanwhile, 486 Notification Letters showed up in big 9"x12" envelopes, with largish transparent windows.  The flat mailing is nicer for us, since we don't have to unfold the letters, avoiding my folding complaints of the past.  But an envelope that's over 6.125" tall costs an extra $0.49 to mail (maybe more if you count the extra weight from the larger envelope).

The large windows make it easier to see color of the paper, which is good, but I've been begging for USAC to bring back colored envelopes since they did away with them in 2006.  Of course, BEAR notifications have always been white, so colored envelopes are out of the question.

You know what I'm thinking?  If applicants have to retain documents for 10 years, shouldn't they're be a 10-color cycle?  And how about pastel colors for C1, and neon versions of the same color for C2?

For those who are curious, here is the cycle of colors:

Year (old style)	FY	Dates for Recurring Services	Color
Year 1	FY 1998	1/1/98 - 6/30/99	White
Year 2	FY 1999	7/1/99 - 6/30/00	White
Year 3	FY 2000	7/1/00 - 6/30/01	Yellow
Year 4	FY 2001	7/1/01 - 6/30/02	Pink
Year 5	FY 2002	7/1/02 - 6/30/03	Blue
Year 6	FY 2003	7/1/03 - 6/30/04	Yellow
Year 7	FY 2004	7/1/04 - 6/30/05	Pink
Year 8	FY 2005	7/1/05 - 6/30/06	Blue
Year 9	FY 2006	7/1/06 - 6/30/07	Yellow
Year 10	FY 2007	7/1/07 - 6/30/08	Pink
Year 11	FY 2008	7/1/08 - 6/30/08	Blue
Year 12	FY 2009	7/1/09 - 6/30/10	Yellow
Year 13	FY 2010	7/1/10 - 6/30/11	Pink
Year 14	FY 2011	7/1/11 - 6/30/12	Blue
Year 15	FY 2012	7/1/12 - 6/30/13	Yellow
Year 16	FY 2013	7/1/13 - 6/30/14	Pink
Year 17	FY 2014	7/1/14 - 6/30/15	Blue
Year 18	FY 2015	7/1/15 - 6/30/16	Yellow
Year 19	FY 2016	7/1/16 - 6/30/17	Pink

Will we ever see pink notifications again?  USAC's EPC goal is to do away with paper.  Will electronic RNL and RAL messages for FY 2016 have pink backgrounds?  I'm betting no.  I was happy to be getting rid of paper, but suddenly, I'm feeling nostalgic.

C2 Budget Anschluss

This week's headache?  "Annex."  The latest USAC News Brief includes a new type of entity: the Annex.  In the past, I have whined about the peculiar status of single schools with multiple locations. Having to create a separate BEN for those locations was unnecessary and an added complication.  Apparently someone at USAC agreed that it was unnecessary, but felt the complication was insufficient, so now we have even more complication.  Now we get another type of entity.

At this point, USAC should abandon "entity" and just adopt the term "thingy," because an annex doesn't get a BEN, and does not exist separately from the main school location, so it's not really an "entity."

I'm all for clarity, but this new thingy does not clear things up.

Let's say my little private school bought the house across the street, and put an art studio on the first floor, where all the kids go to art, and a music room on the second floor, where some kids go for band practice.  Last year, it was an entity, with its own BEN.  This year, the main location does an Anschluss, and it's an annex.  What if they get tired of moving kids across the street, and put the development office into the art studio?  Is it still an annex?  Some kids do go in there during the day.  The development office gets tired of the screeching violins, and the band practice gets moved across the street.  Can it stay an annex?  What if the band practices there, but only after school? The description of annex that we got in the News Brief does not mention a classroom requirement, so maybe it still qualifies as an annex.  Of course, it also qualifies as a NIF, so that's probably what you have to make it, which means you need a BEN for that thingy.  Why?  What is the difference in how a NIF is treated versus how an annex is treated?  It boils down to this: if you want to get some C2 funding for an annex, go ahead, but if it's a NIF, you can only get C2 funding if the C2 gear serves the school across the street.

(Side NIF rant.  What is a NIF?  Here's the definition (from this page): "School NIFs are school buildings or buildings on school property that generally don't contain classrooms...."  Then the next sentence says, "...school NIFs that contain classrooms do not have Category Two budgets."  A NIF with classrooms?  That is a building that doesn't contain classrooms that contains classrooms.

But it simplifies the application process right?  Not so much.  The News Brief says I don't have to get a BEN for the annex.  Yeah, except I already have a BEN for it, because last year we needed one.  And this year, I have to create a new thingy with the same information that is in the existing BEN.  And when I import last year's Block 4, I'll have to go back in and yank out the BEN, because now that thingy is an annex, so it doesn't get listed separately.  So it's just more work for me this year.

And then comes PIA.  Since I'm creating a new thingy that is actually a thingy from last year, PIA is going to have to somehow associate the two thingies (which are actually one thingy, but have to be treated as two thingies now), in case I spent some C2 budget on the thingy back when it had its own BEN.  Annexes can't have C2 budgets, so any C2 funding I got for the thingy when it had a BEN can't be transferred to the annex.  (Wait, would it be a transfer, since we're talking about the same thingy?  Oh, my aching head.)  Somehow USAC is going to have to kludge the former-BEN-now-annex's C2 funding into the main location's BEN's C2 budget.

At first, I felt a little schadenfreude glee that the C2 budget for a BEN-become-annex will be a bigger headache for USAC than for me.  But based on past experience, I expect that the kludge will not exist when PIA reviews start, delaying my clients' applications, and when the procedure for shoehorning a BEN-become-annex's C2 funding into a main location's budget will require a lot of extra work for me.

And why?  Now that we have district-wide discounts, the only reason to list thingies in the "Discount Calculation" section of the 471 (née Block 4) is so that C2 funding can be allocated to those thingies that have C2 budgets.  It would really simplify the program if we had C2 budgets that were district-wide (or private-school-wide or library-system-wide).  (I would call for "organization-wide" C2 budgets, but alas, USAC is now using "organization" as a euphemism for "entity," so "organization-wide" could mean "district-wide" or "school-wide" or "campus-wide" or "bookmobile-wide.")   Location-specific budgets are a bad idea.  Attach C2 budgets to FEINs, and we no longer need NIFs, annexes, C2 cost-allocations, etc., etc., etc.

Yes, having BENs for annexes was an unnecessary complication, but as usual, the reaction is not to remove the complication, but to create a whole new set of rules.