Largest Lifeline Providers Subject to New Biennial Audit

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The FCC’s Wireline Competition Bureau (Bureau) has released the final version of the Lifeline Biennial Audit Plan.  It requires every Lifeline provider that receives $5 million or more annually in the aggregate, on a holding company basis, in Lifeline reimbursements from the universal service fund to undergo a third-party biennial audit of compliance with Lifeline regulations.  Based on disbursements for calendar year 2013, 29 Lifeline providers will be subject to the first Lifeline biennial audit.

Each Lifeline provider’s independent auditor will carry out the biennial audit by collecting specific documents and completed questionnaires, inspecting such documents, and conducting fieldwork testing.  The audit period covers January 1 through December 31.  Auditors will focus on a provider’s corporate-wide compliance rather than its performance on a specific day in a particular study area.  The final step is the preparation and submission of final attestation reports, which must be submitted within one year after release of the final audit plan, which is April 2, 2015 for the first biennial audit.

The final version of the Lifeline Biennial Audit Plan contains revisions to the proposed plan that was released for comment in September 2013.  These revisions include lengthening the audit period, establishing a 30-day window for providers to comment on draft attestation reports, changes to the process for requesting confidentiality of information, changes to the process for sampling subscriber data, and changes to the fieldwork testing procedures.  Further details of the new Lifeline Biennial Audit Plan are available in the attachments and appendices to the Bureau’s Public Notice.

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