On September 12th, the FCC released a Notice of Inquiry (NOI) that sought comments from stakeholders on ways to improve the "management, administration, and oversight of the Universal Service Fund". Many stakeholders including USAC submitted comments.
- USAC argues they have already taken many steps to strengthen the administration and oversight of the Universal Service Fund;
- Many of the administrative and operational improvements have led to earlier and more detailed funding decisions, faster payments and improved appeal processing time. Specifically, USAC reported for “…Funding Year 2007, USAC issued $1.2 billion in funding commitment decisions by September 1 compared to $627 million for Funding Year 2006 (See Funds For Learning March 2008 Report of SLD Funding Commitment Rate for additional analysis, /docs/2008/03/CommitmentsandUtilizationFasterThanYearsPast.pdf)…USAC reduced invoice processing time to five days for over 95% of submitted items.
- USAC continues to work with the FCC on conducting further audits. Hundreds of schools and libraries have already been audited and USAC is about to launch the third round. USAC hired 11 auditing firms to conduct 650 audits starting in November 2007 for Round 2 which included Schools and Libraries and High Cost Program beneficiaries with a cost of $92.8 million;
- USAC’s administrative costs have escalated mainly because of the further oversight and the audit program they have implemented with the FCC. However, USAC suggests that their administrative expenses still remain low when compared to similar programs, non-profits and other agencies;
- USAC has expanded training, outreach and educational activities
- Down below are recommendations for program changes:
- USAC does not believe additional document retention requirements are necessary at this time;
- USAC proposes the standard for debarment would be a “pattern of substantive rule violations demonstrating a substantial pattern of misconduct…” This expands the current rule that only if someone has been convicted or held civilly liable for certain acts arising from their participation in the E-rate program they could be debarred;
- USAC recommends regulating consultants by having them register with USAC and having them identified on an applicant’s application;
- USAC recommends making fewer services and products “conditionally eligible” as they believe that is one of the primary causes of program complexity;
- USAC proposes to eliminate the pilot eligible products database due to many services being “conditionally eligible”, low manufacturer participation and rapid changes in technology;
- USAC recommends making significant changes to the Form 500 and suggests that service substitutions, changing service providers, requesting deadline extension requests, invoicing extensions, notifying USAC of equipment transfers and other post-commitment changes
The USAC FCC Comments can be viewed here.