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A suggestion on gaming, or its prevention, involves having the right sort of panel reviewing applications against the criteria.
The community is rightly concerned about the possibility that a fee waiver program or grant support would be prone to gaming. Experience has shown that if there is a loophole to be exploited for profit, someone in the ICANN community will find a way to do so.
The proposal put forward by the JAS WG recommends that a parallel process be setup to determine eligibility based on the guidelines they have provided in their milestone report. A Support Application Review Panel (SARP) could be setup to review applications for the partial fee waivers and financial grants.  One method by which this could happen is that applicants  would be required to post an application for fee reduction simultaneous with creating their TAS registration and paying their $5000 USD TAS fee. They would present all of the necessary documentation to the Support Application Panel at the time of applying the partial fee waiver.  The SARP would be responsible for reviewing the applications  before the beginning of the initial evaluation period. In those cases where the application for fee reduction was rejected, the applicant could receive a refund of their TAS application fee.
In order to make sure that the Support Application Review Panel does not get fooled and allow any gaming, it should be composed of volunteers from ICANN community who are knowledgeable on gTLD processes, gaming patterns and development country needs and capabilities.  The recommendation is that the process used to establishing AOC review panels be used to staff this Support Application Panel coming from the diversity of ICANN community participants. Any expenses required by this panel for its operations should be covered by the contingency portion of the fees paid and repaid using auction fees.
To insure that issues such as development sensitivity and gaming be covered a number of experts could be invited to joint the SARP as advisors.
A suggestion on gaming, or its prevention, involves having the right sort of panel reviewing applications against the criteria.

The community is rightly concerned about the possibility that a fee waiver program or grant support would be prone to gaming. Experience has shown that if there is a loophole to be exploited for profit, someone in the ICANN community will find a way to do so.

 This is the case with any set of criteria, though some criteria may make this easier than others.

The proposal put forward by the JAS WG recommends that a parallel process be setup to determine eligibility based on the guidelines they have provided in their milestone report. A Support Application Review Panel (SARP) could be setup to review applications for the partial fee waivers and financial grants.  One method by which this could happen is that applicants  would be required to post an application for fee reduction and other assistance simultaneous with creating their TAS registration and paying their $5000 USD TAS fee. They would present all of the necessary documentation to the Support Application Review Panel at the time of applying the partial fee waiver and other assistance.  The SARP would be responsible for reviewing the applications  before the beginning end of the initial evaluation application period. In those cases where the application for fee reduction was rejected, the applicant could receive a refund of their TAS application fee.

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To insure that issues such as development sensitivity and gaming development sensitivity, financial evaluation and other specific specialties be covered a number of area experts could should be invited to joint the SARP as advisors.