Transcript E-rate Audits - State Library of Iowa

E-rate Audits/Reviews
Be prepared!!
Prepared by Judy Jones, State
Library of Iowa
E-rate Audits
This is meant to provide information about what
may be expected if your library were selected for
an audit of e-rate funding. There are various
audits and reviews and various agencies that do
these reviews. Anyone receiving e-rate funds
could expect to be audited for past years’
processes and receipts. This is meant only as
an aid in order that you be prepared with the
correct documentation. The key is, do not throw
anything away. More information can be found
on the Schools and Library Division web site:
http://www.sl.universalservice.org/reference/
Fifth Order – Record Retention
• Keep GOOD RECORDS
• Keep records for five years after last date
of service
• This is now a rule and non-compliance can
mean return of funds
• http://www.sl.universalservice.org/referenc
e/BestPractices.asp
Record Retention – keep all the
following:
• Technology Plan and plan approval letter
• Three year technology plans may require longer
retention
• RFPs, documents describing the bid evaluation
criteria and weighting
• Bid evaluation worksheets
• Winning bids, non-winning bids
• Written correspondence from bidders
• Board minutes with info re: bids, why you chose
certain vendor
Record Retention - continued
• Contracts
• All application forms
• Documents used to support discount
percentage (on file at the State Library or
your individual worksheets)
• Documents used to prepare Item 21
attachments
Record Retention - continued
• Inventory records of equipment purchased and
verify location (internal connections)
• All invoices and records showing payment of
invoices
• Record of BEAR payments and deposits or proof
of payment
• Budget information that supports that you had
the money for non-discounted amount, plus
equipment maintenance, software and staff
training.
Types of Audits/Questions
• Problem Resolution
• Program Integrity Assurance (PIA) Review
• Selective Review
– Certification 25
– Technology Plan
– CIPA
• Beneficiary Selective Review
• USAC Site Visits
E-Rate Questions – Problem
Resolution
First questions you may receive about your
application
Necessary to get missing data on initial
applications because your form does not meet
minimum standards
Mostly for those that apply manually
E-rate Questions – PIA Review
(Program Integrity Assurance)
Necessary to make sure you comply with
the rules:
You are eligible entity
You applied for only eligible services
You made eligible use of those services
You followed competitive bid process
You have a written technology plan
E-rate Audits – various types of audits can
be done by the following:
•
•
•
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USAC Internal Reviews
USAC External Auditors, i.e. KPMG
FCC/Office of Inspector General
Special Investigations – result of whistleblower
hotline
• Can be either random or selected
E-rate Audit - Selective Review
• You are lucky; you have been selected!
• Focus is on the Item 25 certification and competitive
bidding process - can you support this certification?
• Can you prove you had the money to pay for the nondiscounted share when you filed 471?
– They will check your budget and check against the nondiscounted amount required
• Can you prove the service provider did not provide
applicant’s share either directly or indirectly?
• Are you using grant money? Can you prove it was
secured before 471 filed?
More Selective Review
• You must demonstrate you have computers to connect to
the network connections being requested (internet)
• You must demonstrate you have necessary (ineligible)
hardware to fully use the requested services – such as
printers, phone sets (Internet and telecommunications)
• You must demonstrate you have software on hand to run
on the computers to meet the goals of the technology
plan (Internet)
• You must demonstrate that there is sufficient electrical
capacity to run the computer and/or telecommunications
network
More Selective Review
• You must demonstrate staff are/will be trained on
how to use equipment sought (Internet,
telecommunications as Centrex)
• You must demonstrate resources ($$) are in
place to maintain equipment and train staff
• The following site provides additional
information:
– Program Compliance and Checklist
http://www.sl.universalservice.org/reference/dcpr.asp
E-Rate Audit - Beneficiary
• Selected recipients - Looking for waste, fraud
and abuse in discounted services
• Checking to make sure you complied with FCC
rules and reasonable business practices
• Auditors go back to previous years
• Have completed ‘98, ’99, ‘00
• Done by Program Integrity Assurance USAC
Internal or by
• KPMG – group hired by USAC
E-Rate Audit - CIPA
• This audit is done after submission of 486
• The specific purpose is to check
compliance of CIPA certification
• You must be able to produce documents to
show: Internet Safety Policy, adoption of
Internet Policy, date and copy of minutes
of public hearing regarding Internet Policy,
copies of application forms
E-Rate Audit – Technology Plan
• Common findings on completed audits
– Insufficient budget to cover non-discounted
amount
– Approval letter not available
– Plan does not cover time period of funding
– Goals & objectives not monitored
– Missing a required section
– No evaluation done
– No plan or certification available
USAC Site Visits - Random
• 1,000 per year/ 84 per month
• Physical site review for waste, fraud and
abuse
• Enhanced outreach to school & library
community
• Gather information on: procurement,
deployment, technology re: e-rate
• http://www.extendedoutreach.com/www/
E-rate Audits – Summary
• Be prepared with good documentation
• Do not throw away any paperwork related
to your application or receipt of funds
• Be prepared to pull out budget information
• If selected for audit, contact Judy Jones,
State Library 1-800-248-4483