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Service Certifications-System Flaw?

As many of you may know, a Service Certification is a randomly generated request from USAC to the service provider to ensure that the applicant has received services for which USAC is being billed. The service provider contacts the applicant and requests documentation that the services covered in the submitted invoice were delivered or installed, and that the applicants “share” has or will be paid. However, an applicant may also request that USAC generate a Service Certification which effectively allows the applicant to flag a specific invoice or FRN, prior to any invoices being paid.

Here’s the catch. In order to flag the invoice, an applicant must have filed a Form 486. The Form 486 notifies USAC that an applicant has begun or will begin receiving services and also opens the door for the service provider to seek reimbursement. So, technically a service provider can begin invoicing once the Form 486 is processed before an applicant even has a chance to flag that invoice. If a service provider were to do that, it gives the applicant no recourse to be able to flag the invoice.

What’s the point in allowing the applicant to file a service certification if a service provider can get paid prior to the applicant requesting the service certification? Perhaps USAC should consider the consequences of an applicant’s inability to certify accuracy of a Service Providers invoice before it’s paid.

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