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E-rate: it's not paranoia if they're really out to get you. (The View from the Top Left Corner).

We've applied for E-rate funding for 5 years now. Things certainly have improved on the technical side. The debacle of crashing servers and "page not found" errors of Year 1 has been replaced by an online process that is mostly stable. You can even "sign" your verification form online these days. That's good. It's easier.

However, all is not well at the Schools and Libraries Division (SLD). While filling out 471 forms this January, I noticed an unusual amount of verification activity by SLD. It would ask for past bills to prove we were asking for the right amount. It got to the point where I wondered if we were under some sort of undeclared audit, so I went out on a couple of discussion lists and solicited input. Was it just us?

What I received back were dozens of letters telling of E-rate horror stories. You are not going to believe some of this. I must make these stories anonymous, by request, because those folks out there doing this are genuinely frightened that holding up their hands in protest will earn them even more scrutiny by SLD. They are frightened for themselves and for their institutions. This aura of fear kind of amazes me, but it is there. I'm even cutting the names off the letters I have so that even I don't know where they came from. They remain on file, anonymously.

Now, before we get too deep into this I have to say that I approve of an auditing process to ensure that E-rate funds are distributed in an equitable manner and that everyone follows all the rules. When the people at SLD read this, the first thing they're going to say is, "We have a duty to the American taxpayer to make sure everyone is following the rules, and therefore we have an audit process, blah, blah ..." I know all that. You know all that. America absolutely must protect itself against nefarious and underhanded public libraries and school districts that are out to defraud the American public. That's not right and by God, we had better put a stop to it! I just want this process to be accomplished with some intelligence, because the stories I hear show an amazing ineptitude. Personally, I feel as if I'm communicating with a slightly stupid robot that doesn't quite understand what I am saying.

Our 'Unofficial Audit'

It all started when said robot sent me a vaguely threatening form letter asking for verification of our "Telecirc" bills. Telecirc is our own slightly stupid robot that calls people and tells them their hold books are available. There are several hundred long distance calls every month, so the cost is in the hundreds of dollars. The folks at SLD apparently noticed this was a pretty expensive line, so they wanted to know what this was. I told them, and then I was asked for a bill. I faxed off a summary of a typical bill and they said that it did not justify the amount I was asking for.

"Hmmm," says I. Let's see if I've got this straight. SLD is asking me to use a past bill to justify potential expenditures in Year 5 that haven't happened yet. Sometimes Telecirc makes 7,000 calls per month, sometimes 6,000. It varies. Indeed, it is especially rare for a POTS (Plain Old Telephone Service) bill to ever be the same from one month to the next. So I sought verification. Did they want the whole bill? Did they want a year's worth of bills? I couldn't really tell, and they never really answered me. They always said, "Your prompt attention to this matter is appreciated." I informed my interrogator that each bill was 40 pages long. Did he really want all 480 pages from the last year faxed to him? Eventually I faxed over a whole month's worth. I haven't heard back on the issue.

Next, they picked another POTS line for me to verify. I sent a bill in. They said it couldn't justify my request. It was for $5 less per month than I was asking for, $60 per year on a request of over $3,000. So I sent them another month that showed $5 per month more than I requested. It all averages out, but there is no indication these guys understand that. The thing is, I cannot get reimbursed for more than I spent regardless. I get reimbursed for actual expenditures. If I estimate greater than I actually spend, I don't get that money. If I estimate less than actual expenditures, I don't get reimbursed for the greater cost because I'm locked into the lower amount. It's as if SLD is telling us "Heads I win; tails you lose." It's a good-faith estimate, SLD. Why don't you understand that?

Third, the Schools and Libraries Division decided I needed to justify the percentage discount by sending in, promptly, a letter on school district letterhead verifying that this is the amount of discount. I have always received this information from the State Office of the Superintendent of Public Instruction (SPI) Web site. These figures change every year and it's always a struggle to actually find them. The State Library usually helps us out.

I called up SPI for some help. The fellow I talked with had the information for 1999, 2000, and 200l, then he told me a story. He said last year, the people at SLD called him up and said his figures were wrong. He said he thought they were supposed to use the latest figures available. SLD's figures were a year behind, so they said the state had to use the older figures because that's what matched their database.

Despite this absurdity, it revealed that SLD has a database of figures that it uses. In which case, why is it sending us on a yearly snipe hunt for these figures when it already has them? SLD could just as well feed them into the forms automatically, however inaccurately, so at least the figures would be coming from them. In any case, I want SLD to stop this harassment: Tell us all what year statistics you have in your own database and what year figures we are supposed to use. This is not a place to be coy; be forthright!

The Horror Stories Pour In

It was then that I asked for input from my colleagues and opened a floodgate. Here's a good one:

SLD and a library were arguing over the percentage discount rate. SLD said the appropriate rate was a couple of percentage points lower than the library claimed. They went back and forth a few times, and then SLD lowered the rate dramatically. It decided the state prison in the district was a "school district" on the grounds that the school district had contracted with the prison to provide classes for prisoners. Prisoners, of course, are not eligible for the Free and Reduced School Lunch program (FRL). All their food is free. It is effectively the richest school district in the nation with no poverty at all, which lowers the discount. The library protested and SLD basically said too bad, but those are the rules. Perhaps when Congress is looking for fraud and abuse it is this kind of example that should be brought forward.

This is the first time I've heard of SLD making up school districts to lower the percentage. I received many stories of SLD asking a library to prove it existed. In one case several member libraries in a consortium were said not to exist because they didn't happen to appear in the Yahoo! Yellow Pages, SLD's source for reality. In another case a main library was asked to prove its existence. How do you do that? Letterhead can be faked. Do I take a picture of the building and have a notary public stamp it? In a third case, after 4 years of funding, SLD decided a form couldn't be processed because several branches weren't "in the state's data-base and entities." I guess this is common. My father-in-law had a hard time proving his existence because he was born on the campus of West Point, which wasn't used to delivering babies, so he didn't have a birth certificate. The guy retired as a colonel in the U.S. Army, but he couldn't prove his citizenship.

In another case, someone at SLD changed a funding request from a POTS request to the type "internal connections." Internal connections are funded when the FSL rate is very high. It is for wiring and equipment, not for telephone bills. It was denied until a 6-month appeal finally set the record straight. In another case the library sent its signature page by mail with a return receipt requested. It didn't get its discount because SLD claimed it hadn't returned its signature page. It took months of phone calls and back-and-forth letters to resolve the matter, and the library had the proof the whole time. It's like showing a creditor a canceled check and having him still say you didn't pay.

No Reward Is Worth This!

These incredible hassles over points of minutiae have resulted in people who have to deal with this saying, "It's not worth it." Many of my correspondents said they didn't bother to challenge an SLD ruling, such as a lowering of the discount rate, because it was such a frustrating procedure. So libraries are leaving dollars on the table that they very likely deserve because of the bureaucratic tangle imposed by SLD.

Comments include the word "frustrated" a great deal. Other quotes: "A nightmare to administer." "Outrageous." "Frustrating to the nth degree." "The bureaucratic paperwork is enough to keep me from participating for the paltry sum we received." "Catch-22 in a nutshell." "The return is hardly worth the paperwork." And "It wasn't worth my time to send the tons of documents." And my absolute favorite:

"I have a theory that when the people who could not adopt the new 'customer service' attitude at the IRS were fired, they were snatched up at SLD as the perfect fit for their employee profile."

This brings up what I suspect is underlying a lot of the frustrations in the field, and that is a lack of response from SLD. It's difficult to get a dialogue going or to get a resolution to the tiniest issue, in one case a 75-cent charge on a bill. You're never sure you get through to SLD. You're never told when your response is adequate or inadequate. Your e-mail goes into this black hole. Your voice messages simply disappear. When you do get a response, my impression is that SLD front-line employees don't really understand the process that well. Phone calls to the help desk, for example, frequently result in SLD reading the answer from a Web page that you have open before you already. One person said she considered installing a recording device to document the different answers she received to the same question. I don't sense much cognition going on there. I suspect it's a "would you like fries with that?" kind of existence where there is a script to follow and only certain boilerplate responses are availab le. They must certainly be very, very busy. I imagine a Call Center or boiler room operation, everyone with a cubicle, a CRT, and a headset.

As one person said, "The thing that's so unnerving is that SLD can set rule after rule for compliance by the applicants, but they don't even have to abide by the rules of logic or common sense...." As a result, you kind of want to knock them on the head and ask: "Hello? Is anyone home in there?"

What I would like to see from SLD is very simple. I want it to stop treating us as suspects. I want it to stop hiding data it has from us while asking us to get it for ourselves. School district discount percentages: Share them please. What year are they from? Why are you using figures that are out-of-date? Explain to us your auditing procedure. What is the rule demanding precision when using a bill from last year to justify expenditures that will happen a year from now?

And please, can you do better than Yahoo!?

Michael Schuyler is the systems librarian for the Kitsap Regional Library System in Bremerton, Washington. His e-mail address is
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Author:Schuyler, Michael
Publication:Computers in Libraries
Article Type:Column
Geographic Code:1USA
Date:May 1, 2002
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