EDUCATIONAL ADVISORY: How to Avoid Having a Simple E-mail from USAC Spiral into an Audit Nightmare


It is through our firm’s experience dealing with aggressive USAC auditing and representing clients through lengthy (seemingly endless) FCC appeals of adverse audit findings that we now seek to educate clients about the tools USAC uses to collect information regarding USF contributors – and through that information collection, identify non-compliance with USAC’s understanding of the FCC’s rules.  While USAC does not make its internal processes public, and many of the tools USAC uses are not explicitly addressed by FCC regulations, through our experience representing clients, we have witnessed how USAC uses the many tools at its disposal to build its audit decisions.  We have also witnessed the mistakes clients sometimes make in responding to USAC requests for information quickly and without consulting counsel.