Consult The Dictionary
What is a consultant? Long trusted Merriam-Webster’s dictionary defines a consultant as “one who gives professional advice or services.” In USAC’s October 28 Schools and Libraries News Brief, you will find that the definition of a consultant is “any non-employee of the entity applying for funding that assists in filing the application materials for a fee. Consultants can be organizations with one or more employees or they can be individuals.”
Why is USAC’s definition of a consultant so important? If you are a school or a library applying for E-rate discounts and received assistance from a contact that meets the definition above, you are required to verify that this contact has registered with USAC to obtain a Consultant Registration Number. But by this definition, it seems that if you receive application assistance on from a non-employee for “free” - or as part of another service - then a CRN isn’t necessary.
Does this mean that individuals providing application assistance who are not employees of the school such as a non-profit organization, state E-rate Coordinator, Educational Service Agency, or a service provider are not required to register? That is certainly the current interpretation of USAC’s definition.
What if the consultant doesn’t charge a fee for filling out the application materials, but provides that service for free as part of another service or for the purchase of other goods? The current definition of a consultant leaves many gaps in interpretation. One could further argue that the only information that USAC is gathering with the current registration rules is from honest consultants who would have previously provided USAC with Letters of Agency as required by program rules.
USAC should eliminate the gaps in interpretation and look back at the long trusted dictionary for the definition. A clearer definition of a consultant is any non-employee of the entity applying for funding that assists in filing the application materials regardless of if there is a fee directly associated with the application.