Federal Communications Commission
In accordance with the Improper Payment Information Act (IPIA) of 2002, as amended by the Improper Payments Elimination and Recovery Act (IPERA) of 2010, Improper Payments Elimination and Recovery Improvement Act (IPERIA) of 2012, and the Payment Integrity Information Act (PIIA) of 2019, the Commission has made significant efforts to implement policies and procedures to strengthen internal controls that prevent improper payments. In addition, the Commission utilizes a payment recapture program that includes both audits and transaction testing to search for and recapture overpayments. Although the Commission has made strides to improve policies, procedures and controls over improper payments, there is still more work to be done. In FY 2024, the Commission successfully reduced the amount of phase 2 reporting from four programs to two programs that meet the reporting criteria: Universal Service Fund (USF)-Lifeline and USF-High Cost Legacy.
USF-High Cost Legacy: Although, USF-High Cost Legacy remains a complex program, the improper payment rate has decreased from 4.45% to 3.26%. This program remains a complex program. However, strides have been made to improve our efforts to reduce the improper payment rate. The Commission will continue to work on decreasing the amount of carriers using the incorrect depreciation method and inadequate documentation. These exception types remains a program issue that the Commission is actively working to address. The new compliance layer will be implemented by December 31, 2026. In the interim, corrective actions will continue to be taken such as using Risk Management Council Meetings to discuss strategic initiatives and risks, as well as conduct its annual Circle of Life webinars.
USF-Lifeline: Unfortunately, the USF-Lifeline program increased from 5.98% to 9.12%. The major causes of the improper payments are inadequate documentation related to eligibility and usage. The major causes make up 87% of the improper payment rate. The Commission and our Administrator, the Universal Service Administrative Company (USAC), the Lifeline program management continues to review the root causes of the usage errors and work with Eligible Telecommunication Carrier (ETC) and opt-out state administrators to improve non-usage compliance. To address eligibility inadequate documentation, Lifeline will analyze root causes related to eligibility documentation in California and work with California Public Utility Commission (PUC) to improve on issues identified. USAC continues to develop multiple outreach activities, including updates to the website training materials, conducting webinar(s) focused on common audit findings, prior program quality assurance (PQA) reviews and communicating best practices based on the observations.
The Commission and its components continue to make great strides when it comes to oversight, internal control updates and implementation of policies and procedures. Our ultimate goal is to bring all of our programs back to phase 1 reporting requirements although there is more work to be done in order to reach the goal. With the Commission leadership, we continue to make much needed improvements in all of our programs each year. The Commission takes seriously the recommendations provided by our OIG and its auditor so that our programs are in compliance with the guidance outlined in OMB M-21-19.
Agency level Payment Integrity results
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Payment accuracy rate
(Based on federal funding spent by programs determined by agencies as susceptible to improper payments)
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Improper payments rate
(Based on federal funding spent by programs determined by agencies as susceptible to improper payments)
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Unknown payments rate
(Based on federal funding spent by programs determined by agencies as susceptible to improper payments)
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Federal Communications Commission improper payment estimates over time
View as:
Chart toggle amounts:Proper paymentsOverpaymentUnderpaymentTechnically improperUnknown
Recovery information
Please note: Overpayment amounts recovered are reported in the year they were recovered, not the year they were identified. Therefore it is possible in some years to have a recovery rate greater than 100%.
| Overpayment amount identified through recovery activities | $14.46 M |
| Overpayment amount recovered through recovery activities | $12.67 M |
| Recovery activities recovery rate | 87.62 % |
| Overpayment amount identified through recovery audits | $3.72 M |
| Overpayment amount recovered through recovery audits | $50.61 M |
| Recovery audit recovery rate | 1,360.48 % |
| Overpayment amount identified for recapture | $18.18 M |
| Overpayment amount recovered | $63.28 M |
| Overpayment recovery rate | 348.07 % |
Conditions giving rise to improper payments identified in recovery audits, how those conditions are being resolved, and the methods used to recover those payments
There are a variety of conditions that arise during the audit process that require the recovery of funds. Some of these reasons include but are not limited to carrier/beneficiary not following or completely understanding the FCC's rules, invoicing errors, eligibility requirements, duplicate subscribers, usage, competitive bidding issues, inadequate documentation for assets, incorrect depreciation methods used, and equipment not used for the intended purpose. There are also various methods used by the FCC to recover funds. Some of these methods include but are not limited to demand letters, consent decrees, credit memos, offsets, and notice of apparent liabilities (NALs).
| Recovery audit amount identified this reporting period that remains outstanding | $2.41 M | ||||
| Recovery audit amount rate outstanding | 64.78 % | ||||
| Recovery audit amount this reporting period that remains outstanding for 0-6 months | $2.39 M | ||||
| Recovery audit amount identified this reporting period that remains outstanding for 6 months to 1 year | $0.02 M | ||||
| Recovery audit amount identified in this reporting period determined not collectible during this reporting period | $73.54 M | ||||
| Recovery audit rate identified in this reporting period determined not collectible during this reporting period | 1,976.88 % | ||||
Justification for the Determination that the recovery audit amount is not collectable
The FCC strives to recover all improperly paid funds no matter which year the improper payment takes place. At this time the Commission does not believe that there are any improper payments identified in recovery audits are not collectable at this time.
Intentional monetary loss improper payments are more commonly referred to as financial fraud and are overpayments that occur on purpose. This agency reported $0M of confirmed fraud in this reporting cycle.
Supplemental Information
The FCC has established several critical financial controls in place, including the US Treasury Do Not Pay (DNP) system. The agency utilizes DNP to verify the eligibility of payment recipients before disbursing funds as well as when onboarding new programs and vendors, thereby reducing the risk of improper payments. DNP is also used prior to making an award. For example, if a vendor does not have an active SAM.gov registration shown in the DNP system then the Commission will not issue the award.
The Working System has reduced/prevented improper payments:
The Working System strives to maintain accurate data. However, the past year, FCC has identified incorrect information in the Working System Monthly.
FCC was found non-compliant during the most recent PIIA compliance review.
Non-compliant programs:
Show full list of compliant programs
Compliant programs:
- FCC Affordable Connectivity Program (ACP)
- FCC Affordable Connectivity Program Outreach Grants
- FCC Emergency Connectivity Fund (ECF)
- FCC Secured & Trusted Communications Network Reimbursement Program (STCNRP)
- Federal Communications Commission Operating Expenses
- Telecommunications Relay Service
- Universal Service Administrative Company (USAC) - Administrative Costs
- Universal Service Fund - High Cost Modernized
- Universal Service Fund - Rural Health Care
- Universal Service Fund - Schools and Libraries
- Universal Service Fund – Cybersecurity Pilot Program
Actions recommended and planned to achieve compliance
The most recent FY 2024 PIIA Audit Report identifies three findings resulting in eight recommendations. The FCC is actively working to address these findings and implement the recommendations proposed form the FCC OIG and its auditor. The Commission remains committed to making the necessary improvements to its programs and will work with its partners and the OIG to ensure improvements in compliance with OMB M-21-19. The primary recommendation to address the USF-Lifeline Program finding is to direct our program’s Administrator to perform a cost-benefit analysis to identify and implement additional approaches. These approaches to reduce the IPR include, but are not limited to, implementing technology tools, increasing effective training and additional review layers. Additionally, the Commission aims to reduce the USF-High Cost Legacy IPR rate. The PIIA Audit Report includes recommendations to meet this goal such as addressing IP risk by conducting an in-depth root cause analysis for IPs related to missing or inefficient documentation. Another recommendation includes developing a phased reduction target plan with clear milestones and accountability measures. Finally, to implement improvements to the Commission’s IP reporting, the FCC plans to follow the recommendation to ensure applicable policies and procedures define how to identify, quantify, and report IPs. Also, to implement a more rigorous internal review process for IP reporting in the OMB Annual Data Call.
Official(s) accountable for the progress of the agency coming into compliance
Mark Stephens, the FCC Managing Director, is the official accountable for the progress of the agency in coming into compliance with PIIA.
Accountability mechanism tied to the success of the official designated in leading the efforts to come Into compliance
The FCC is committed to continually improving and strengthening the program integrity of its operations and the programs it oversees. The strategic goals outlined in the FCC FY 2026 Performance Plan and its FY 2026 – 2030 Strategic Plan have measurable performance indicators to ultimately reduce the improper payment error rates across FCC programs. Over the last several years the FCC has made numerous improvements in its programs to reduce improper payment rates. Although, the improper payment rates for Phase 2 programs are not under the 1.5% threshold yet, one of those program’s rates did reduce this year. In addition, we are actively working on a root cause analysis to determine how to further reduce these rates in the coming years.
| Program name | When was the last improper payment risk assessment conducted? | Likely to be susceptible to significant improper payments? | Substantial changes made to the assessment methodology used for the reporting cycle |
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| FCC Affordable Connectivity Program (ACP) | 2023 |
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| FCC Affordable Connectivity Program Outreach Grants | * | ||
| FCC Emergency Connectivity Fund (ECF) | 2023 |
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| FCC Secured & Trusted Communications Network Reimbursement Program (STCNRP) | 2025 |
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| Federal Communications Commission Operating Expenses | 2023 |
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| Telecommunications Relay Service | 2023 |
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| Universal Service Administrative Company (USAC) - Administrative Costs | 2023 |
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| Universal Service Fund – Cybersecurity Pilot Program | * | ||
| Universal Service Fund - High Cost Legacy | 2025 |
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| Universal Service Fund - High Cost Modernized | 2025 |
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| Universal Service Fund – Lifeline | 2025 |
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| Universal Service Fund - Rural Health Care | 2025 |
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| Universal Service Fund - Schools and Libraries | 2024 |
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* Assessment year is not displayed because one or more of the following statements is true:
- Not required to conduct a risk assessment under the Payment Integrity Information Act of 2019,
- Already assessed for improper payment risk under a different name in a prior reporting period, and/or
- New and planning to perform a risk assessment in the future.
The FCC will continue to conduct improper payment risk assessments in accordance with the three year cycle plan. This year the FCC made the proactive decision to determine that the FCC Secured & Trusted Communications Network Reimbursement Program (STCNRP) is subject to significant risk. For FY 2026, the FCC will perform risk assessments for at least four of its phase one programs, assuming the programs meet the outlays threshold. However, the Commission will perform an off-year risk assessment if circumstances warrant such actions.