Schools and Libraries
About the Schools and Libraries Program:
- Overview of the Program
- Overview of the Process
- Outreach and Training
- HATS Outreach
- Filing Appeals
- Understanding Audits
Schools and Libraries Tools:
Beneficiary Audits - Auditors' Observations - IPIA Round 2
The 260 Improper Payments Information Act (IPIA) audits focused on Funding Years 2005 and 2006.
Following is a list of the most common auditors' observations:
Properly Applied Discount
- Entities did not apply the discount percentage to the appropriate pre-discount price
Document Retention
- Entities did not retain all documentation relating to participation in the E-rate program
- Documentation to support the discount calculation
- Copies of invoices utilized to complete FCC Form 472
Level of Poverty
- Entities did not retain documentation to support the student count and National School Lunch Program (NSLP) data as indicated on the FCC Form 471, Description of Services Ordered and Certification Form.
- Discrepancies existed in the total student and/or NSLP student count.
Ineligible Equipment and Services
- USAC was invoiced for ineligible equipment and services by both the applicants and service providers.
Asset listing either not maintained or not updated
- Asset listing did not reflect the transfer of equipment from one location to another.
- Entities did not maintain a comprehensive asset listing which included the model, location, installation date, and equipment identification number.
- Equipment was installed at locations other than those specified in the asset listing.
Equipment and services
- Entities transferred equipment in violation of Program rules.
- Equipment was not installed.
- Equipment could not be located.
- Services were ineligible.
- Services were substituted without authorization from USAC.
Payments
- Invoices from the service provider did not list the details of equipment and services provided.
- USAC was invoiced in excess of the amount billed to Billed Entity Number (BEN).
- Entities did not perform a reconciliation of eligible amounts billed to them by service providers to the requested reimbursement amounts on the FCC Forms 474, Service Provider Invoice (SPI) Form.
- FCC Form 472, Billed Entity Applicant Reimbursement (BEAR) Form, payment from service provider remitted to applicant after the deadline.
Entity not listed on Form 471
- Entities received discounted services at locations that were not listed on the Form 471.
Children's Internet Protection Act (CIPA) violation
- Internet safety policies failed to meet CIPA requirements.
Other issues
- Entities did not retain documentation of compliance with competitive bidding requirements.
- Entities did not have a draft Technology Plan at the time the Form 470 was filed.
- Consortium was missing Letters of Agency (LOA).
- Entities filed the Form 471 before entering into a contract with the service provider.
- Entities did not have a document retention policy.
