The FCC OIG’s audit concluded that FCC was compliant with respect to 10 Phase 1 programs and one Phase 2 program. However, FCC was non-compliant with PIIA overall because for two of the 13 assessed FCC programs (the USF-LL and the USF-HC Legacy programs), FCC complied with nine of the 10 required PIIA criteria. The FCC OIG issued three findings and offered eight recommendations to improve FCC’s PIIA reporting.
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 2 | No | $0 | $0 | ||
| Direct USAC to conduct an in-depth root cause analysis for IPs related to missing or insufficient documentation used to support the carriers’ submission of continuing property records and depreciation/amortization information for USF-HC Legacy. USAC should continue to engage with carriers to understand systemic issues contributing to these types of IPs. USAC should develop targeted corrective actions based on the findings. | |||||
| 3 | No | $0 | $0 | ||
| Enhance oversight of the USF-HC Legacy program by increasing the frequency of monitoring and reviewing carrier-reported data. For example, implement interim random sampling of payments or use AI to identify and detect patterns of non-compliance. | |||||
| 4 | No | $0 | $0 | ||
| Develop a phased reduction target plan for the USF-HC Legacy program with clear milestones and accountability measures to ensure it is realistic and achievable based on past performance and current challenges. | |||||
| 6 | No | $0 | $0 | ||
| Implement a more rigorous internal review process for IP reporting to include performing quarterly validation reviews to detect and prevent errors in identified IP amounts before reports are finalized. Further, all quarterly validation reports should be reconciled against the final annual report to identify and resolve discrepancies prior to the data call submission. | |||||
| 7 | No | $0 | $0 | ||
| Introduce a secondary review or correction window between FCC and USAC before finalizing reports for the OMB data call. | |||||
| 8 | No | $0 | $0 | ||
| Revise the outstanding categories in the FY 2025 data call submission to reflect the correct recovery audit amounts outstanding. | |||||