Around this time last year, Verlyne wrote about the “fun house procedure” that required third party validation for school’s internal data system for National School Lunch Program data.
In short, the commentary suggested that a third party should do an administrative procedure check of the third party validation process, as it appeared to be a waste of administrative dollars. Then, almost prophetically, questioned if USAC “[will] require the state to validate that schools are saving the required documentation that they certify to?”
While we have not seen any instances of USAC seeking third party validation on document retention (yet), they did invite more of their PIA checklist boxes to the party. To welcome a few of our “favorite” invitees to the Third Party Party, we put together the ultimate PIA playlist.
In an Introduction to Psychology course, a professor asked for a volunteer and then proceeded to inform the volunteer that they were “crazy”. The volunteer then had to explain why they were not crazy and try to prove their case to the professor and their peers. The strange thing was that even though the other students knew that the volunteer was not crazy, the more the volunteer tried to prove that they were not crazy, the crazier they sounded. Such is like the task of proving a negative.
This year’s PIA has a similar “prove you’re not crazy” question with a Third Party twist. We have seen numerous requests where the reviewer is asking for the school to provide third party documentation that a school did not close.
The funny thing about this line of questioning is how it catches the applicants so off guard. The school is still open, students are still in class, and there have not even been talks of closing the site. Where in the world did USAC hear that the site was closing?
USAC won’t say.
So here is an applicant needing to prove that something didn’t happen based on information that seems to have appeared ex nihilo. And to add to the frustration of trying to prove a negative, they now have to bring someone else outside of the school system in to prove that something that did not happen actually did not happen.
A contact at a school district summed up the frustration best stating, “Here’s the school’s phone number. Tell [USAC] to call them and when the school answers, USAC can serve as the third party.” Zing.
Back in July, Eric Jester wrote a commentary about third party validation creeping into other areas of PIA. When PIA began to pick up for funding year 2013, we began to see a rise in schools needing to provide third party documentation to prove anticipated growth.
I won’t rehash Eric’s thorough and enjoyable write up on the subject, but as these requests continue to come in, there is a need to reiterate some of the main points.
Why does USAC think that a service provider (or any other third party), who has limited, if any, knowledge of the schools growth, would be in any kind of position to validate an estimate made by school officials?
The numbers associated with anticipated growth are not arbitrarily thrown together based on feelings. They often come after careful analysis and approval by an authoritative body such as a school board. The idea that a service provider can speak on these matters is unfortunate, as they were most likely not included in any of the growth discussions.
Why does USAC think that Service Providers have authority to speak on behalf of a school’s anticipated plans?
Principal-agent problem. Google it. In fact let’s develop a new motto: “Google: It’s not just for finding rumors about school closings anymore.”
Why does USAC think that this will discourage waste/fraud/abuse?
The only waste is wasted time by having the schools reach out to a third party. That being said, if applicants are not afforded the ability to anticipate growth on the application, could they force growth and apply for more services, equipment, etc., than they need in order to ensure that enough funds were available?
Along with the need to have third party validation on NSLP, school closings, school openings, NIFs, anticipated growth, etc., there is an even bigger problem with providing third party validation –
USAC doesn’t know what third party validation is.
Scenario 1: To provide third party documentation that a sight is opening in funding year 2013, the applicant provided reviewer #1 a snapshot of a news article from a major metropolitan newspaper’s website. The snapshot included the newspapers name and the link so that the reviewer could go and see it on the original site for themselves.
No good. Why?
The title of the article was something to the affect of “School Board Approves New Sites” and reporting information from a school board meeting did not meet the definition of third party validation.
Scenario 2: To provide third party documentation that a sight is opening in funding year 2013, the applicant provided reviewer #2 a snapshot of a news article from a major metropolitan newspaper’s website. The snapshot included the newspapers name and the link so that the reviewer could go and see it on the original site for themselves. Because we are quick learners, it did not include anything about the school board in the article’s title.
No good. Why?
The information is superfluous. Why not just provide the minutes from the school board as third party validation.
Two different reviewers and two different answers as to what constitutes third part documentation. One does not even want to see the words “school board” associated with third party documentation, while the other wants school board minutes as third party validation.
What does it mean to be “third party” and what can meet the requirements? Ask The Beach Boys.
As much as I would like to end this article with a pithy little paragraph that includes some exaggerated hypothetical, Verlyne’s attempt last year is looking more and more like a legitimate possibility and less like a hyperbole.
With that being said, we will hunker down for the back-to-school PIA onslaught that comes every September and hope that some third parties take a close look at these validation requirements and some kind of improvement happens to the process before funding year 2014.