It sounds to me like the slush you refer to is at fault of the applicants for not keeping up with their statements and discounts.
Because of lax oversight there's little incentive to try and do it efficiently. -- "Fascism should more properly be called corporatism because it is the merger of state and corporate power." -- Benito Mussolini
And that's why I posted above that budgeting for audits has significantly increased this year. Again, I'm very familiar with the e-rate process and I feel your opinion may be different had you seen it from my perspective.