The attorneys of Marashlian & Donahue, PLLC, The CommLaw Group’s USAC Compliance, Audit Preparation and Defense practice cordially invite you to attend a webinar sponsored and hosted by TeleStrategies!
Learn the “in’s and out’s” of the USAC Audit process. Learn how your company can not only survive an audit, but also significantly reduce the likelihood USAC opens up an audit in the first place! And learn how implementing Operational Best Practices and working with a compliance vendor that takes a “Regulatory Fees First” approach to regulatory and tax compliance reporting may be the most important decisions your business can make, if the goals are to Avoid and/or Survive a USAC Audit!
Date: September 22, 2020; 1:00 – 2:15PM EST
You must pre-register for the live webinar. Registration link.
The live webinar is open to past attendees of any TeleStrategies Taxation Conference, current 2021 registrations or online subscribers.
(CommLaw Clients & Guests eligible for FREE registration – Contact Us for CODE)
Over the past decade, ensuring compliance with the ever-changing rules surrounding the federal Universal Service Fund (“USF”) program has, without question, become the communications industry’s greatest regulatory challenge. Technological advances, the proliferation of novel service delivery methods, and consumer shifts away from traditional forms of telecommunications continue to outpace the Federal Communications Commission’s ability to keep up. Despite being in catch-up mode at all times, the FCC remains steadfastly committed to upholding its statutory duty to ensure adequate funding for universal service; indeed, the FCC has been known to stretch the bounds of reasonableness in what has become an “ends justify the means” approach to ensuring the stability and sufficiency of the USF. The FCC is heavily reliant on USAC, the USF Administrator, to achieve these goals through compliance reviews, contributor audits and pseudo-enforcement activities. A panel of experienced telecommunications attorneys who have been in the trenches representing clients in USAC audits and their subsequent appeals to the FCC will provide tips to help your company survive (or better yet, avoid) the regulatory meat grinder.
The USF webinar series is suited for experienced telecommunications tax personnel involved with USF regulatory compliance activities, as well as new entrants offering (or looking to offer) telecommunications services and VoIP services.
Basic information that any filer should have on hand
- Why me? How does USAC determine which entities to audit?
- Best practices to prepare for an audit include maintaining documentation to support reported revenue (five years)
- Respond completely, but only within the scope of the audit; review objectives and scope carefully
The site visit
- Be sure key employees understand the purpose of the Form 499 and the company’s USF contribution obligation
- Prepare in advance to provide access to employees and records and explain reporting methodology
- Key topics and records reviewed:
- Completeness of revenue
- Block 3 reporting
- Classification of products
- Jurisdiction allocation
- USF recovery charges and reporting
Field work – Follow-up questions can continue for weeks and months following the site visit
Course corrections along the way
- Pay attention! Correct misunderstandings along the way. Keep lines of communication with the audit team open throughout.
- Communicate clearly and review preliminary indications of potential findings carefully
- Common audit findings
- The draft — Filers have the opportunity to provide a written response to findings and other matters
- Once final, if a filer wishes to appeal an adverse audit finding, first appeal to USAC within 60 days
- If not, revise the 499 in accordance with the audit findings
- Appeal to FCC (but no longer protected by automatic confidential treatment)
“Gotchas”, “Pitfalls” and the “Operational Best Practices”
- USAC ISSUE notices and triggering “Red Flags” in the E-File System: How a seemingly innocuous email can spiral into a full blown audit, reclassification of revenue and even referral to the FCC Enforcement Bureau
- How avoiding the “garbage in/ garbage out” revenue reporting trap is the single best practice for those seeking to minimize the likelihood and/or economic pain of a USAC audit
Q&A, discussion and open Issues
Be sure to test your system before the webinar at: https://telestrategies.com/Webinars/FAQ.html
For details on pricing, access to online content, registration for webinars and important terms/conditions, please visit the online pricing page.