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When Life Imitates Art: Audit Pitfalls

You haphazardly toss the cardboard lid in the general direction of the file box you had spent the last hour searching. Hundreds of documents, thousands of pages, you continue to see the reoccurring names and numbers when you close your eyes.

You had spent the last week going through boxes just like this one. Box by box, page by page, you have desperately searched for a cabling contract the former IT director signed 4 years ago, but your efforts up to this point have been fruitless. But you haven’t been alone in your search. There has been a significant investment in manpower dedicated to the search. Personnel from accounting, procurement, IT, administration and legal have all been involved at some point and all to no avail.

You pick up the lid and place it firmly on the box before placing it back on the shelf and reaching for the next yellowed box. You notice that you are quickly running out of boxes to search, running out of time with the FCC, running out of hope.  You just needed to find this one document to satisfy the auditors that had camped out at the school for 5 weeks earlier this year.

How could one document signed before any of the current staff were employed by the school carry such a great cost? Why is the current staff the ones that are forced to bear the weight of the ramifications of a past administration? The potential monetary finding echoes through your mind, haunting you like an apparition; you stifle a sigh as you open another box.

Over $5 million.

This was going to hurt. Even during more prosperous times, $5 million would have been a challenging pill to swallow. But these are not prosperous times.  You had already seen the affects of budgetary shortfalls within the district. Schools had closed, teachers laid-off. This was going to make a difficult situation worse.

You open the lid to the box and peer inside to only be greeted with one more set-back. On top of the papers, a post-it note with a simple message: TRASH.

With nothing to lose, you grab the first stack in the box as the post-it note slides off the top page and down the side of the box and start to review.


You’re probably thinking that the above dramatization is obviously so over-stylized and hyperbolic in nature that examples such as this could never happen in real life.

They can and they do.

While the above story is loosely based on real events, it’s not unique. Every year schools are hit with monetary findings during audits resulting in the schools being forced to return the money to USAC.

There are proactive measures you can take during procurement season that can take some of the stress out of an audit. FFL has prepared the tips below to keep you ready as you prepare for FY2011.


The E-rate program is full of guidelines, deadlines, rules and regulations.  And more often than not, the rules differ year to year.  Before you certify, post, sign or do any number of irreversible things, stop for a moment. Did you wait the required 28 days after posting the Form 470 before entering into a contract? Did you mark the right service category for Dark Fiber? Did you have a second and possibly third set of eyes review this form for errors? A short pause can save you hours worth of troubles later.


In a previous audit post FFL posed two questions that you should consider as you navigate through the world of E-rate.

  1. Am I doing anything that is in violation of my local rules or E-rate rules?
  2. Am I lacking any of the necessary documentation to prove that I am in compliance with E-rate rules and regulations?

If you have to answer “yes” to either question at any time, you are at risk of being on the losing end of an audit.


During the procurement process, you are likely to receive and construct a great deal of E-rate related documentation. Save it. All of it.

E-rate requires that applicants maintain all of the documents associated with a funding commitment for a period of five years from the last date of service, so it should go without saying that certain documents should always be retained. Forms such as the 470 and 471, RFPs , technology plans, winning bids, losing bids, bid evaluation matrix, bid scoring criteria, NSLP Data, evidence of CIPA compliance  and signed contracts should always be archived and available in the case of an audit.

Even if the documents do not appear pertinent to the program, if it mentions E-rate or the procurement process, save it. This may include items such as e-mail correspondence with a service provider, meeting minutes, letters, etc.  The information therein and time stamp of this documentation may be enough to satisfy an auditors request.

It is important to remember that document retention doesn’t end with the procurement process. After you have filed your Form 471 and received your funding commitment decision letter (FCDL), you still need to maintain copies of correspondence with USAC and the SLD, invoices, BEARs, copies of checks, and deposit slips demonstrating that you deposited the checks from the service provider.

It is not possible to list specific examples of every possible item that you should retain, but if it involves E-rate and/or procurement, it is better to be safe than sorry.

Happy Ending

The real life story of the missing contract has a happy ending, as they find the contract in a box marked for the trash. But it could have easily had a darker, much sadder ending. Unfortunately, for many applicants, they are more familiar with the COMAD, than the last second save of finding a lost contract in a 7 year old box. However, the above tips can help you stay ahead of the auditors and compliant with E-rate rules.

For more information on E-rate compliance or the audit tools available in E-rate Manager, please contact Funds For Learning at 405-341-4140 or via email at

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