Common Audit Findings: Lifeline Program
In USAC’s continuing efforts to ensure service providers are successful at implementing the Federal Communications Commission (FCC) rules and program requirements, the Lifeline team compiled a list of problem areas identified during audits and Payment Quality Assurance (PQA) reviews.
For more information about the audit process, review USAC’s BCAP page. Visit USAC’s Lifeline Rules and Requirements page to stay informed about Lifeline specific rule changes.
Findings
Below is a list of common findings, descriptions of each finding, how to prevent the finding, and examples of the finding.
Causes
Lifeline program non-compliance is most often caused by an inadequate knowledge of program rules. In addition, service providers’ internal procedures are often insufficient to support program compliance.
Description of Finding
Lifeline service providers are required to:
1) Have an effective process for identifying subscribers that have not used their service within 30 consecutive days if the eligible telecommunication carrier (ETC) does not assess and collect a monthly fee from the subscriber.
2) Provide the subscriber 15 days notice, using clear, easily understood language, that the subscriber’s failure to use the Lifeline service within 15 days will result in service termination.
3) De-enroll subscribers that have not used their service in 45 consecutive days.
4) Retain documentation to demonstrate that an effective non-usage process is in place.
Examples: Improper Non-Usage Process
The service provider did not provide documentation to demonstrate the usage of its subscribers to determine whether the subscriber had used the phone service in 30 consecutive days.
How to Address or Prevent This Finding
The service provider must implement a system to retain documentation to demonstrate how it evaluates the usage of its subscribers to determine when the subscriber has not used the phone service in 30 consecutive days.
Description of Finding
Service providers may only claim subscribers for a particular data month that they serve as of the first of the following month in LCS. Service providers may not claim ineligible subscribers for reimbursement in LCS.
Example: Over-Reporting Subscribers for Reimbursements
Service providers inadvertently over-report subscribers for reimbursement in LCS or claim subscribers who no longer qualify or should have been de-enrolled from the program.
How to Address or Prevent This Finding
Service providers in National Lifeline Accountability Database (NLAD) states: Service providers may only claim subscribers for a particular data month that they serve as of the first of the following month in LCS.
Service providers in NLAD opt-out states: Ensure the data shared between the ETC and state public utility commission (PUC) is accurate and reflects actual Lifeline subscribers for which the service provider should receive reimbursement. As a reminder, service providers in NLAD opt-out states can only claim subscribers listed on the file in LCS provided by their state PUC.
All service providers: Maintain active subscriber listings to substantiate all subscribers in LCS, as required by the Lifeline rules. The auditor will ask for subscriber listings to substantiate amounts claimed in LCS. (See 47 C.F.R. § 54.407(a).)
Description of Finding
Service providers cannot claim support more than once for the same subscriber. The service provider did not have adequate processes in place to prevent providing more than one Lifeline benefit to the same subscriber and claiming these subscribers in the Lifeline Claims System (LCS).
This finding may apply to both National Lifeline Accountability Database (NLAD) states and NLAD opt-out states.
Example: Duplicate Subscriber
The same subscriber was listed more than once on the service provider’s subscriber listing.
How to Address or Prevent This Finding
Service providers review their subscriber listing and remove any duplicate subscribers prior to submitting their claims to USAC for reimbursement.