Is third party validation some sort of bureaucratic fun house? You know, the kind with the mirrors that distort your face and trick you into running into a wall? Let me explain.
If you are an E-rate applicant, you may be asking yourself why the FCC has been so insistent that USAC enforce third party validation of your school’s internal data system for National School Lunch Program data.
Many schools have a dedicated department that makes it their business to gather Free and Reduced forms, which are reviewed, tallied, and validated with various integrity checks. This department is typically the Nutritional Service Department within a school district, and their data is maintained in professional school data systems which are subject to multiple validation and verification procedures. The NSLP and enrollment data is gathered for each school site and then submitted to the state Department of Education.
When an E-rate application is submitted, applicants are instructed to calculate their discount rate using free & reduced/enrollment data as of October 1 (or more current). Lately, Form 471 applications have not been due until March of the following year. In many cases, a school district will use the most current and accurate data from within the October -February time period. When USAC reviews the 471 application, it is compared to the data reported by the state Department of Education or the National Center for Education Statistics. This information frequently reflects data from a different timeframe than the applicant’s E-rate funding application. It also may be lacking data for school sites that do not serve meals to students.
During PIA, USAC requires that a school provide third party validation (from a source outside the school district) of site discount rates that do not match the state or NCES data. The most common source of third party validation is the State E-rate Coordinator. Frequently, the State E-rate Coordinator then asks or sends a written request to the school requesting they certify that their data is accurate. The state then turns around and validates the data for USAC.
Are you keeping up with this? Here is the fun house scenario: the school certifies its data and makes this certification on the Form 471. The school sends claim forms and any requested information to USAC to support the data as reported. USAC does not accept this data, and does not accept the schools certification of its own data. Instead, USAC requires the State to confirm the school data. The State then promptly asks the school to confirm its data in order that the state can confirm it to USAC.
The school does, then the state does, then USAC accepts it.
Someone should do an administrative procedure check of the third party validation process, because this is a ridiculous fun house procedure and waste of administrative dollars. Next, will USAC require the state to validate that schools are saving the required documentation that they certify to?
