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Common Audit Findings: Lifeline Program

In USAC’s continuing efforts to ensure carriers are successful at implementing Federal Communications Commission (FCC) rules and program requirements, we have put together a list of some of the problem areas identified during audits and Payment Quality Assurance (PQA) reviews.

For more information about the audit process, review the Beneficiary and Contributor Audit Program (BCAP) page of our website, which includes a checklist for carriers of documentation to maintain for audit purposes. Using all of this information will help to expedite the audit process and should reduce or eliminate audit findings in the future. Also, please visit our Lifeline Rules & Orders page to stay informed about Lifeline program rule changes.

Audit Findings

For each common audit finding, we have outlined a description of the finding, and some ways to prevent a finding like this in the future. We’ve also, where possible, provided some examples.


Lifeline program non-compliance is most often caused by an inadequate knowledge or familiarity of program rules. In addition, carrier’s internal procedures are often insufficient to support program compliance.

FINDING: Inaccurate FCC Form 555 Reporting
FINDING: Lack of or Inadequate Documentation
FINDING: Improper Qualification Criteria
FINDING: Improper Recertification Process
FINDING: Improper Advertising Methods and/or Materials
FINDING: Improper Eligibility Documentation
FINDING: Improper Certification and/or Recertification Documentation Disclosures
FINDING: Inaccurate FCC Form 497 Reporting
FINDING: Duplicative Support
FINDING: Subscribers Outside of Service Area