The primary purposes of audits are to ensure compliance with Federal Communications Commission (FCC) rules and program requirements and to assist in program compliance.
When selected for an audit, the carrier's designated contact person will be contacted by a member of the USAC Internal Audit Division. In addition, an announcement letter will be sent detailing the purpose and scope of the audit, identifying the personnel who will be performing the audit, making a request for company data, and stating the date upon which the data is due.
USAC's random sample selection includes various types of carriers (incumbent and competitive carriers) from various states. Each audit is designed to examine the carrier's specific eligibility and data submission requirements.
A)
How does USAC conduct audits?
1.
Ensure carrier is eligible to receive Low Income support
a.
Properly designated by state commission or FCC
b.
Evidence of advertising availability of Lifeline
2.
Attest to the accuracy of Lifeline, Link Up, and Toll Limitation Service subscribers
a.
Obtain a detailed subscriber listing
b.
Obtain documentation (e.g., bills) to support that discounts were passed through to subscribers
c.
Obtain documentation (e.g., certifications) to support a subscriber's eligibility to receive discounts
d.
Obtain documentation (e.g., tariffs) to support rates charged to eligible low-income subscribers
B)
Reporting Results
At the conclusion of the audit, USAC's Internal Audit Division management will review the audit file to ensure that workpapers are properly documented and the conclusions reached are properly supported. For any exceptions noted, a Detail Exception Worksheet (DEW) will be prepared and sent to the carrier for review. It will contain background information, the audit step performed, and the exception noted as well as the basis for which the exception is noted (e.g., FCC rule).
The carrier is given an opportunity to provide a response to explain their agreement/ disagreement with the exception noted. USAC Low Income management will review the exception as well as the carrier's response and will prepare a response to address the exception and note any corrective action as necessary. USAC refers any novel questions or issues involving rule interpretation to the Commission for guidance.
Both the carrier and USAC Low Income management responses will be incorporated into the draft report and submitted to the USAC Board of Directors to be deemed final. The USAC Board of Directors may request USAC management to reassess any aspect of the report prior to the report becoming final. Once finalized, both the carrier and the FCC will receive copies of the audit report. The final report may be made available to the public upon request.
C)
How can you help?
1.
Provide requested documentation in a timely manner
2.
Ask questions to ensure that you are providing adequate documentation
3.
If the amounts noted on the subscriber listing do not agree to the amounts reported on the Form 497, provide a reconciliation and an explanation to substantiate the information provided
4.
Maintain documentation for data submitted to USAC
If you have any questions, please contact USAC's Internal Audit Division via e-mail.
