One of my favorite parts of Funds For Learning’s blog was the Fantasy Football Friday series. For those unfamiliar with the posts, each week the Client Process Management team would submit their picks for fantasy football and select the winners of three marquee games (for reasons explained here.)   

What set this Fantasy Football advice column apart from the millions of fantasy football sites is that our “experts” had very little, if any, knowledge on the subject and hilarity often ensued.  Regardless of whether we were laughing with the CPM team or at them is beside the point. The fact of the matter is that their lack of authority to give advice on fantasy football coupled with their lack of first-hand knowledge (or second hand for that matter) on a player’s abilities, or even availability, was evident from week to week. But no harm, no foul. It is highly unlikely that anyone actually heeded their advice and most everyone had a good laugh.

So what does Funds For Learning’s fantasy football blog have to do with PIA? Apparently they both like to seek input from parties that have little, if any knowledge on the subject.

Over the past few weeks, we have seen more than one instance of PIA reviewers requesting vendor documentation to validate anticipated growth at a school. They want the service provider, who has limited, if any, knowledge of the schools growth to validate an estimate made by school officials.

In one situation, a reviewer wanted service provider validation that the schools anticipated growth was enough to validate an increase in the number of cellular phones at the school. The number of phones in question was…wait for it…two. The school was considering moving from one cell phone to two. It would be funny if it wasn’t so sad.

The way the current program is set-up, applications for a given funding year are filed months before the actual beginning of that funding year and given the fact that additional costs due to increase in services cannot be recouped if not included on the Form 471, applicants have to anticipate their needs for potential increase to the current service and make a good faith estimate. I would hope that increasing the total number of cellular devices to two, would fall soundly into a good faith estimate.

This new area of inquiry is potentially problematic for a few reasons:

Service Providers should not have authority to speak on behalf of a school’s anticipated plans.  This isn’t just a principal/agent problem. It’s an all-around problem.

Discouraging “anticipated growth” may discourage actual growth. There are some applicants that treat anticipated growth requests like they are Priority Two requests - that is, they do not act on the increase in service until a FCDL is issued.  In these cases, eliminating additional funds for anticipated growth is as good as eliminating the growth all together.

Does not discourage waste, fraud and abuse. I would like to think that growing from one cell phone to two cell phones would not trigger a W/F/A inquiry (though the PIA could be seen as a waste of time). However, I would be concerned that if applicants were not afforded the ability to anticipate growth on the application, that they might force growth and apply for more services, equipment, etc., than they need in order to ensure that enough funds were available. That would be wasteful.

We would like to see this line of questioning kicked to the sidelines, or at least be reviewed for what USAC needs to see to validate a request and who is in the best position to answer it.