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SLD Discussses 2004 Performance Goals for Application Review

The prime contractor for the Schools and Libraries Division's application review processes July 19 outlined the goals it hopes to meet for the coming year.

John Perry, CEO of NECA Services Inc. (NSI), a new entity spun off of the National Exchange Carrier Association that does the bulk of application review, outlined to the Schools and Libraries Committee of the Universal Service Administrative Company the goals he is prepared to commit to as part of a performance agreement with USAC. Perry's organization is paid based on how well it meets the targets that are set in its contract with USAC. It can also be penalized if it fails to meet the targets.

Perry said that in the 2003 funding year, NECA had reviewed 80 percent of applications and 24 percent of the total value of funding requests by July 1. This year, he said, "55 percent of applications were ready for commitment and 42 percent of the total value of funding requests by that date. Program officials acknowledged that "ready for commitment" does not necessarily mean that the funding commitment can proceed if other issues have been identified.

Among the targets that Perry described were:

Finishing all the work it can on applications for the 2003 funding year by September 30, 2004. It was reported that funding commitment decision letters have not yet been distributed for about 1,000 applications; 600 of those are awaiting policy decisions from the Federal Communications Commission or the disposition of law-enforcement issues, and are thus beyond the control of NSI.

Completing his agency's review of all 2004 applications by December 30, 2004;

Reviewing appeals within 90 days. Perry reported that as of June 30, there were 36 post-commitment appeals that had been pending longer than 90 days, but no pre-commitment appeals that had been pending longer than that.

Perry said that additional performance targets related to quality would also be put in place.

George McDonald, vice president of USAC for the schools and libraries program, reported that although the productivity of the USAC's invoice review department had improved, it had not been able to keep up with the increased volume of line items it had to review. McDonald said that although the staff had achieved a 31 percent increase in productivity, they had seen a 64 percent increase in the number of line items they had to review. This, he said, had impacted USAC's ability to reduce its backlog of work in this area.

Perry said his organization's ability to meet its deadlines would depend on how quickly the FCC reviewed his procedures and information requests. He noted that for the 2004 funding year, this review was not completed until April 22, 2004, about 10 weeks before the start of the funding year.

Meanwhile, McDonald warned that the SLD's ability to start the 2005 filing window would depend on how quickly the FCC and the Office of Management and Budget can review the proposed new Form 470 and Form 471 application forms. The filing window cannot start, he said, until the Form 471 application is approved.

USAC Board Chair Frank Gumper noted that there were five categories under which applications could be excluded from being covered by the NSI targets, including applications that were held up because of audits or law enforcement investigations or those that had raised an issue that only the FCC could resolve. Gumper noted that persons whose applications had not yet been approved would not care what the reason was and "might take umbrage" if it was telegraphed that 100 percent of applications had been reviewed by NSI when they had not yet been funded.

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