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Commitment Adjustments/Recoveries

At times, USAC may conduct the following types of reviews and audits:

  • Program Integrity Assurance (PIA)
  • Audits
  • Payment Quality Assurance (PQA)
  • Invoicing
  • Appeals
  • Heightened scrutiny (e.g., competitive bidding, cost-effectiveness, special compliance, and other post-commitment reviews)

As a result of these reviews/audits, USAC may discover that certain funds were committed and/or disbursed in error. The Federal Communications Commission (FCC) requires USAC to rescind commitments and recover funding that has been improperly disbursed. USAC refers to this process as the Commitment Adjustment or “COMAD” process.

Commitment Adjustment (COMAD)

If a COMAD action is necessary, USAC will provide both the applicant and the service provider with a Commitment Adjustment Letter (CAL) containing an Adjustment Report which lists the Funding Request Number(s) (FRNs), FCC Form 471 Application Number, Billed Entity Number (BEN), and Service Provider Identification Number (SPIN) affected by the COMAD action, as well as an explanation.

If a party wants to appeal the decision, information on how to prepare and submit an appeal is included in the letter.

For Funding Year (FY) 2016 and later funding years, applicants and services providers receive CALs in the E-Rate Productivity Center (EPC) News feed. For FY2015 and previous funding years, USAC emails the CAL to the contact person designated in EPC.

If the amount of funds disbursed to date exceeds the adjusted funding commitment amount, FCC rules require USAC to recover the funds disbursed in error. In these cases, USAC will send the CAL to the responsible party (service provider, applicant, or both parties). USAC will copy the other affected party on the CAL.

If the amount of funds disbursed to date is less than the adjusted funding commitment amount, USAC will continue to process valid invoices up to the adjusted funding commitment amount. If funds need to be recovered, USAC will seek recovery from the party responsible for the COMAD action or rule violation.

Recovery of Improperly Disbursed Funds (RIDF)

When USAC discovers that funds were disbursed in error but the decision to commit the funds was correct, USAC will seek recovery of the improperly disbursed funds (RIDF). For example, if USAC paid an invoice that included ineligible products or services along with the approved products and services, USAC would seek recovery for the costs of the ineligible items. The commitment may not need to be adjusted when it is determined that a RIDF action is necessary. Once the improperly disbursed funds are returned to USAC, USAC will resume paying invoices submitted for that FRN that are for approved, eligible products and/or services.