Universal Service Fund – Lifeline

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Program level Payment Integrity results

Sponsoring agency: Federal Communications Commission

View on Federal Program Inventory

PROGRAM METRICS

$855 M

in FY 2021 outlays, with a

84.1%

payment accuracy rate

PROGRAM METRICS

$607 M

in FY 2022 outlays, with a

93.9%

payment accuracy rate

PROGRAM METRICS

$527 M

in FY 2023 outlays, with a

97.8%

payment accuracy rate

PROGRAM METRICS

$785 M

in FY 2024 outlays, with a

94.0%

payment accuracy rate

PROGRAM METRICS

$830 M

in FY 2025 outlays, with a

90.9%

payment accuracy rate

  • Improper payment estimates over time
    View as:

    Chart toggle amounts:
    Proper payments
    Overpayment
    Underpayment
    Technically improper
    Unknown

Payment Integrity results

  • FY 2021 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    01/2020 - 12/2020


    Confidence interval:

    >95%


    Margin of error:

    +/-3.97

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $0.0 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $117.36 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $117.36 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.0 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0.0 M

Unknown Payment Details

The unknown payments exist in Texas and California where both states have opted out of using the National Verifier. The National Verifier increases program integrity by applying a consistent eligibility standard for Lifeline Program participants. For most Lifeline participants living in opt-out states, eligibility determinations are processed by a state agency or its administrator.

The amount of payments that could either be proper or improper but the agency is unable to determine whether they were proper or improper as a result of insufficient or lack of documentation is $18.33 M


Cause of insufficient or lack of documentation & why the documentation is needed for determination of payment type
Payment cause Amount Description of the documentation that was not provided and explanation of why the program is unable to conclude whether the payment is proper or improper without that documentation

Evaluation of corrective actions

The Lifeline program will continue to find ways to identify effective methods to reduce improper payments.

Future payment integrity outlook

Universal Service Fund – Lifeline has established a baseline.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $927.8 M
Current year +1 estimated future improper payments $125.25 M
Current year +1 estimated future unknown payments $18 M
Current year +1 estimated future improper payment and unknown payment rate 15.44 %

The program's current year improper payment and unknown payment rate of 15.87 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

The Lifeline Program has the internal controls, human capital, information systems, and other infrastructure it requires to reduce IPs to the targeted levels.

Additional programmatic information

  • FY 2022 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    01/2021 - 12/2021


    Confidence interval:

    90% to <95%


    Margin of error:

    +/-3.64

Overpayments

The FCC and USAC launched the National Verifier in all states and territories by the end of 2020. The National Verifier increased program integrity by applying a consistent eligibility standard for Lifeline Program participants.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $1.93 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $1.93 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $35.28 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $35.28 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0 M

Unknown Payment Details

Evaluation of corrective actions

USAC’s Lifeline Program Integrity team continue to conduct detailed analysis of Lifeline subscribership data to identify potential instances of non-compliance. Based on the analysis, the Lifeline Program integrity team perform targeted program integrity reviews of high-risk areas. The results of these reviews are used to address compliance gaps and enhance preventative controls with the goal of reducing improper payments.

Future payment integrity outlook

Universal Service Fund – Lifeline has established a baseline.

Every year USAC reviews the improper payment rates and determines the reduction targets based on 3 year performance in conjunction with the payment quality assurance (PQA) exceptions.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $905.4 M
Current year +1 estimated future improper payments $55.23 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 6.1 %
Current year +1 estimated future improper payment and unknown payment reduction target 6.1 %

The program's current year improper payment and unknown payment rate of 6.13 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

The Lifeline program has the internal controls, human capital, information systems and other infrastructure it requires to reduce improper payments to the targeted levels.

The program did not identify additional resources needed to improve the overall structure of the lifeline program in its most current budget submission. USAC continues to work with the Commission to determine the gaps in its overall requirements.

Additional programmatic information

  • FY 2023 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    01/2022 - 12/2022


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-1.12

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Training
    Outreach includes updates to the website training materials, conducting webinar(s) focused on common audit findings, prior PQA reviews and communicating best practices based on the observations. USAC provides annual training and implemented an Online Training Library to provide program participants with tools that they can access at their convenience. USAC and its manual review vendor have robust quality assurance processes and continuously update training materials and resources for manual reviews.
    FY2023 Q1
    Completed
    Cross Enterprise Sharing
    Through USAC's Risk Management Council meetings, the different USF program teams discussed strategic initiatives and risk that may impact USAC’s goals. The Risk Management Council meetings provide an opportunity to analyze and respond to identified changes and related risks to maintain an effective internal control system as well as effective enterprise systems management.
    FY2023 Q1
    Completed
    Audit
    Monthly meetings are held between USAC’s Audit and Assurance Division (AAD) and USAC leadership to discuss findings identified by AAD. During these meetings, corrective actions are discussed to prevent similar findings in the future.
    FY2023 Q1
    Completed
    Training
    USAC will continue to conduct outreach which includes updates to the website training materials, conducting webinar(s) focused on common audit findings, prior PQA reviews and communicating best practices based on the observations. USAC provides annual training and implemented an Online Training Library to provide program participants with tools that they can access at their convenience.
    FY2024
    Planned
    Cross Enterprise Sharing
    Through USAC's Risk Management Council meetings, the different USF program teams discussed strategic initiatives and risk that may impact USAC’s goals. The Risk Management Council meetings will continue to provide an opportunity to analyze and respond to identified changes and related risks to maintain an effective internal control system as well as effective enterprise systems management.
    FY2024
    Planned
    Audit
    Monthly meetings are held between USAC’s Audit and Assurance Division (AAD) and USAC leadership to discuss findings identified by AAD. During these meetings, corrective actions are discussed to prevent similar findings in the future.
    FY2024
    Planned

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $0 M

Overpayments are outside of agency control because documentation is not required to receive payment. Carriers are required to retain documentation and to make it available upon request. to demonstrate how it evaluates the usage of its subscribers. USAC depends on the carrier to follow Commission rules related to non-usage. The collection of documentation in advance would prevent timely payment and would be cost prohibitive.
Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $11.5 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $11.5 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Outside Agency Control Financial $11.5 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0 M

Unknown Payment Details

Evaluation of corrective actions

USAC and its manual review vendor have robust Quality Assurance processes and continuously update training materials and resources for manual reviews. The Lifeline Program will review the root cause of the errors identified in the assessments and will perform updates to training and materials related to the review of eligibility documentation and provide individual coaching for reviewers. The current improper payment of 2.18% is the lowest rate in the past eight years. From FY2016 through FY2022, the improper payment rate had fluctuated from 2.93% to 21.93%. Four of the years with a rate over 10%. The Lifeline program continues to develop approaches to address the root cause of the improper payment which result in an improper payment reduction.

Future payment integrity outlook

Universal Service Fund – Lifeline has established a baseline.

The reduction target is calculated using a three year average of the improper payment rate. After the average has been established, we review to determine if there are variables that may affect the calculated average.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $912.4 M
Current year +1 estimated future improper payments $19.16 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 2.1 %
Current year +1 estimated future improper payment and unknown payment reduction target 2.1 %

The program's current year improper payment and unknown payment rate of 2.18 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

The Lifeline program has the internal controls, human capital, information systems and other infrastructure it requires to reduce improper payments to targeted levels. USAC will continue to expand internal controls as necessary and will develop the human capital to ensure it meets its goals.

The program did not identify additional resources needed to improve the overall structure of the Lifeline program in its most current budget submission. USAC continues to work with the Commission to determine gaps in its overall requirements.

Additional programmatic information

  • FY 2024 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    01/2023 - 12/2023


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-2.78

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Training
    USAC's Lifeline Program team continues to develop multiple outreach activities, including updates to the website training materials, conducting webinar(s) focused on common audit findings, prior PQA reviews and communicating best practices based on the observations. USAC provides annual training and implemented an Online Training Library to provide program participants with tools that they can access at their convenience.
    FY2024 Q1
    Completed
    Cross Enterprise Sharing
    Through USAC's Risk Management Council meetings, the different USF program teams discussed strategic initiatives and risk that may impact USAC’s goals. The Risk Management Council meetings provide an opportunity to analyze and respond to identified changes and related risks to maintain an effective internal control system as well as effective enterprise systems management.
    FY2024 Q1
    Completed
    Audit
    Monthly meetings are held between USAC’s Audit and Assurance Division (AAD) and USAC leadership to discuss findings identified by AAD. During these meetings, corrective actions are discussed to prevent similar findings in the future.
    FY2024 Q1
    Completed
    Training
    USAC will continue to conduct outreach which includes updates to the website training materials, conducting webinar(s) focused on common audit findings, prior PQA reviews and communicating best practices based on the observations. USAC provides annual training and implemented an Online Training Library to provide program participants with tools that they can access at their convenience.
    FY2025
    Planned
    Cross Enterprise Sharing
    Through USAC's Risk Management Council meetings, the different USF program teams discussed strategic initiatives and risk that may impact USAC’s goals. The Risk Management Council meetings will continue to provide an opportunity to analyze and respond to identified changes and related risks to maintain an effective internal control system as well as effective enterprise systems management.
    FY2025
    Planned
    Audit
    USAC will continue to hold monthly meetings between USAC’s Audit and Assurance Division (AAD) and USAC leadership to discuss findings identified by AAD. During these meetings, corrective actions are discussed to prevent similar findings in the future.
    FY2025
    Planned

Overpayments

USAC continues to work with states and territories to implement additional automated connections to eligibility databases. Where a consumer’s eligibility cannot be confirmed automatically, USAC manually reviews appropriate documentation to confirm that a consumer is eligible to participate in the Lifeline program and is not receiving duplicative support. USAC and its manual review vendor have robust Quality Assurance processes and continuously update training materials and resources for manual reviews. The Lifeline Program will review the root cause of the errors identified in the assessments and will perform updates to training and materials related to the review of eligibility documentation and provide individual coaching for reviewers.
Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $46.33 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $46.33 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Overpayments are outside of agency control because documentation is not required to receive payment. Carriers are required to retain documentation and to make it available upon request. To demonstrate how it evaluates the usage of it's subscribers. USAC depends on the carrier to follow Commission rules related to non-usage. The collection of documentation in advance would prevent timely payment and would be cost prohibitive.
Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.57 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.57 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.0 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Outside Agency Control Financial $0.57 M
Overpayments Within Agency Control Receiving Benefits from Other Sources $46.33 M

Overpayment type Mitigation strategies taken Mitigation strategies planned
Overpayments within the agency’s control Audit, Cross Enterprise Sharing, Training Audit, Cross Enterprise Sharing, Training

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.0 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0 M

Unknown Payment Details

Evaluation of corrective actions

USAC and its manual review vendor have robust Quality Assurance (QA) processes in place. Based on the results of the review, the team will perform updates to training and materials. In addition, individual coaching is provided to review agents for effective error detection. The QA process has also been used to perform a trend analysis. Identifying the trends will provide a proactive approach to addressing common errors. The Lifeline Program team will continue to review the root cause of the errors identified in the QA process.

The most impactful corrective actions are focused on focused on the robust Quality Assurance process to confirm eligibility. USAC manually reviews appropriate documentation to confirm that a consumer is eligible to participate in the Lifeline program and is not receiving duplicative support. The Lifeline Program will review the root cause of the errors identified in the assessments and will perform updates to training and materials related to the review of eligibility documentation.

USAC, in conjunction with the FCC, will continue to implement an Improper Payment Analysis. Through this process, USAC management performs an analysis of its improper payments to understand the root cause and to identify corrective actions to mitigate the issues. In collaboration with USAC management, the USAC’s Fraud Risk Group has developed a process to evaluate common root causes in an effort to identify the true root cause to determine if additional corrective action is needed.

During the Risk Management Council Meeting, management will continue to review the improper payments and prioritize the largest monetary impact findings accordingly. During the meetings, management has an opportunity to discuss effective improper payment mitigation strategies. USAC’s Fraud Risk Group has developed a process to evaluate common root causes of improper payments in an effort to identify the true root cause to determine if additional corrective action is needed. This process has enabled USAC management to institutionalize corrective actions as part of its program integrity efforts, which will prevent future instances of improper payments. USAC leadership is implementing a quarterly review process to discuss progress towards executing these corrective actions.

Future payment integrity outlook

Universal Service Fund – Lifeline has established a baseline.

The reduction target is calculated using a three year average of the improper payment rate. After the average has been established, we review to determine if there are variables that may may affect the calculated average.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $912 M
Current year +1 estimated future improper payments $42.86 M
Current year +1 estimated future unknown payments $0 M
Current year +1 estimated future improper payment and unknown payment rate 4.7 %
Current year +1 estimated future improper payment and unknown payment reduction target 4.7 %

The program's current year improper payment and unknown payment rate of 5.98 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

The Lifeline program has the internal controls, human capital, information systems and other infrastructure it requires to reduce improper payments to targeted levels. The FCC and USAC will continue to expand internal controls as necessary and will develop the human capital to ensure it meets its goals.

The program did not identify additional resources needed to improve the overall structure of the Lifeline program in its most current budget submission. The FCC and USAC continue to work to determine gaps in its overall requirements.

Additional programmatic information

Accountability for detecting, preventing, and recovering improper payments

The FCC works through it's program administrator, USAC to complete payment recapture audits known as Beneficiary and Contributor Audit Program (BCAP). BCAP audits are designed to identify overpayments that must be recaptured, assess compliance with FCC rules, and deter waste, fraud, and abuse. Further, the FCC works through USAC’s improper payment testing program known as Payment
Quality Assurance (PQA). Through PQA, USAC utilizes a statistical sampling methodology to estimate the annual amount of improper payments in the USF-HC, USF-LL, USF-RHC, and USF-S&L programs. The goal of the PQA assessment plan is to estimate an improper payment error rate based on non-compliance with FCC rules. To recover improper payments, the FCC and USAC have implemented an enterprise recovery policy to standardize the reporting and recovery of improper payments. All improper payments are deemed collectible and funding is either recovered or is in the process of being recovered.

  • FY 2025 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    01/2024 - 12/2024


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-7.37

Causes

The major causes of Lifeline improper payments are inadequate documentation related to eligibility and usage. The major causes make up 87% of the improper payment rate.

Inadequate documentation related to eligibility is caused when the documentation provided was not adequate to support the subscriber's eligibility (examples provided below):
? Benefit card was dated over a year from the enrollment date (e.g., BIC card)
? Document did not include the eligible program
? Eligibility documentation did not show the issuing authority or state
? Income documentation reviewed does not show three consecutive months
? PII on the eligibility documentation did not agree or was not listed
? Dated tax forms exceeding two years from enrollment were used to determine eligibility

Inadequate documentation related to usage is caused when documentation provided is not adequate to support the subscriber's continued eligibility to receive Lifeline benefits. An example is as follows: The documentation provided does not demonstrate qualified usage during the 30 days prior to the snapshot date.

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $21.47 M
Amount of overpayments outside the agency's control $54.16 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
Amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $21.47 M
Amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $54.16 M

Underpayment root cause Underpayment amount
Amount of underpayments $0.0 M

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

The amount that could either be proper or improper but the agency is unable to determine whether it was proper or improper as a result of insufficient or lack of documentation $0.0 M

Prevention

The major findings are caused by inadequate documentation related to eligibility and usage. To address usage inadequate documentation, Lifeline will 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's Lifeline Program team continues to develop multiple outreach activities,
including updates to the website training materials, conducting webinar(s) focused on common audit findings, prior PQA reviews and communicating best practices based on the observations. USAC provides annual training and implemented an Online Training Library to provide program participants with tools that they can access at their convenience. The training is developed on an ongoing basis throughout each fiscal year.

Through USAC's Risk Management Council meetings, the different USF program teams discussed strategic initiatives and risk that may impact USAC’s goals. The Risk Management Council meetings will continue to provide an opportunity to analyze and respond to identified changes and related risks to maintain an effective internal control system as well as effective enterprise systems management. The meetings are completed on an ongoing quarterly basis.

Monthly meetings are held between USAC’s Audit and Assurance Division (AAD) and USAC leadership to discuss findings identified by AAD. During these meetings, corrective actions are discussed to prevent similar findings in the future.
The webinars are completed on an ongoing annual basis.
USAC and its manual review vendor have robust Quality Assurance (QA) processes in place. Based on the results of the review, the team will perform updates to training and materials. In addition, individual coaching is provided to review agents for effective error detection. The QA process has also been used to perform a trend analysis. Identifying the trends will provide a proactive approach to addressing common errors. The Lifeline program team will continue to review the root cause of the errors identified in the QA process.

The most impactful corrective actions are focused on the robust Quality Assurance process to confirm eligibility. USAC manually reviews appropriate documentation to confirm that a consumer is eligible to participate in the Lifeline program and is not receiving duplicative support. The Lifeline Program will review the root cause of the errors identified in the assessments and will work with ETCs and opt-out state administrators.

Payment type Mitigation strategies taken Mitigation strategies planned
Overpayments Audit, Cross Enterprise Sharing, Training Audit, Cross Enterprise Sharing, Training

Eligibility element/information needed Description of the eligbility element/information
Financial The financial position or status of a beneficiary, recipient, or their family
Receiving Benefits from Other Sources Beneficiary or recipient is receiving benefits from an additional source

Additional information

Reduction target

9.0 %

The Lifeline program has the internal controls, human capital, information systems
and other infrastructure it requires to reduce improper payments to targeted levels.
The FCC and USAC will continue to expand internal controls as necessary and will
develop the human capital to ensure it meets its goals.

The Lifeline program did not identify additional resources needed to improve the overall structure of the Lifeline program in its most current budget submission. The FCC and USAC continue to work to determine gaps in its overall requirements.

The FCC works through it's program administrator, USAC to complete payment
recapture audits known as Beneficiary and Contributor Audit Program (BCAP). BCAP audits are designed to identify overpayments that must be recaptured, assess compliance with FCC rules, and deter waste, fraud, and abuse. Further, the FCC works through USAC’s improper payment testing program known as Payment Quality Assurance (PQA). Through PQA, USAC utilizes a statistical sampling methodology to estimate the annual amount of improper payments in the USF-HC, USF-LL, USF-RHC, and USF-S&L programs. The goal of the PQA assessment plan is to estimate an improper payment error rate based on non-compliance with FCC rules. To recover improper payments, the FCC and USAC have implemented an enterprise recovery policy to standardize the reporting and recovery of improper payments. All improper payments are deemed collectible and funding is either recovered or is in the process of being recovered.

$0 M