In order to minimize the required efforts of applicants and avoid the on-site visits associated with audits, USAC has implemented the Payment Quality Assurance (PQA) Program. USAC is utilizing the PQA program to request information on specific payments in order to determine if these payments were made within program rules. While the PQA does defer on-site visits from auditors, it poses special challenges in terms of information required and associated time frames.
Applicants that are selected for a PQA will receive a letter and/or email from USAC notifying them of their selection, what information they must provide to satisfy the request and the timeframe in which the information must be returned to USAC.
According to USAC, the PQA can include (but presumably not be limited to) any document indicating the eligibility status, Technology Plan approval letter, service provider bills and Letter of Agency.
The preliminary requests we have seen have included these specific items:
- Audited financial statements applicable to the funding year identified on the notification letter
- A document indicating the applicant’s eligibility status
- List of endowments over $50 million, if applicable
- List of all entities that received goods and/or services associated with the BEN identified on the notification letter
- The Technology Plan Approval Letter for the FRN indentified on the notification letter, except for requests for VOIP or basic telephone services
- All bill statements associated with the SLC Invoice number identified on the notification letter
- For Consortia Only: Letters of Agency for entities listed on the Form 471 for the funding year identified on the notification letter. If your consortium does not require documentation/LOAs as a result of laws governing the mandatory participation of all schools and/or libraries in your consortium, provide a copy of the state statute of regulation in regards to the mandatory participation of the consortium in regards to the mandatory participation of the consortium member entities.
- Printed and Signed Confirmation Letter. (This confirmation letter is attached to the PQA Notification Letter.)
- The PQA requires that the above information be provided within 10 business days.
At this point, it is unknown if there will be multiple follow-ups to the PQA, or if it is a one-time request. Based on similar documentation requests from USAC, it is safe to assume that this initial request will result in follow-up questions. Upon submission and review of the PQA, applicants should receive notice of the results from USAC.
Given that the PQA program has only recently been applied to applicants, many of the details are still unknown. FFL will continue to monitor the situation and update our website as information becomes available.