United States Government Accountability Office

GAO Report to the Chairman, Subcommittee 

on Telecommunications and the 

Internet, Committee on Energy and 

Commerce, House of Representatives 

February 2008 TELECOMMUNICATIONS 

FCC Has Made Some 

Progress in the 

Management of Its 

Enforcement Program 

but Faces Limitations, 

and Additional 

Actions Are Needed 

 

GAO-08-125 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2008

TELECOMMUNICATIONS

FCC Has Made Some Progress in the Management of 

its Enforcement Program but Faces Limitations, and 

Highlights of GAO-08-125, a report to the Additional Actions Are Needed 

Chairman, Subcommittee on 

Telecommunications and the Internet, 

Committee on Energy and Commerce, 

House of Representatives

The Federal Communications 

Commission (FCC) annually 

receives about 100,000 complaints

from individuals and companies.

FCC has the authority to

investigate these complaints and 

take enforcement action if it finds a 

violation of the 

telecommunications laws and

rules, which are designed to

ensure, for example, that

individuals have access to 911

services and a wider affordable

range of communication services. 

As requested, this report reviews

FCC’s enforcement program and 

(1) summarizes the number and 

type of complaints received, 

investigations conducted, and 

enforcement actions taken by FCC 

from 2003 through 2006; (2) 

discusses how FCC assesses the 

impact of its enforcement program; 

and (3) discusses challenges FCC 

faces in providing complete and 

accurate information on its 

enforcement program. To address 

these objectives, GAO analyzed 

FCC’s databases, interviewed FCC 

officials, telecommunications 

executives, and experts. 

What GAO Recommends

The Chairman, FCC, should 

improve FCC’s data collection and

analysis to help it better manage its 

enforcement efforts and develop 

and implement performance goals 

and outcome measures for its 

enforcement program. FCC said it 

has already implemented measures 

that address both 

recommendations; however, the 

actions it identified do not fully 

address our recommendations. 

According to GAO’s analysis of FCC data, between 2003 and 2006, the number 

of complaints received by FCC totaled about 454,000 and grew, from almost 

86,000 in 2003, to a high of about 132,000 in 2005. The largest number of 

complaints alleged violations of the do-not-call list request and telemarketing 

during prohibited hours. FCC processed about 95 percent of the complaints it 

received. FCC also opened about 46,000 investigations and closed about 

39,000; almost 9 percent of these investigations were closed with an 

enforcement action, and about 83 percent were closed with no enforcement 

action. GAO was unable to determine why these investigations were closed 

with no enforcement action because FCC does not systematically collect 

these data. FCC told GAO that some investigations were closed with no 

enforcement action because no violation occurred or the data were 

insufficient. 

FCC assesses the impact of its enforcement program by periodically reviewing 

certain program outputs, such as the amount of time it takes to close an 

investigation, but it lacks management tools to fully measure its outcomes. 

Specifically, FCC has not set measurable enforcement goals, developed a welldefined enforcement strategy, or established performance measures that are 

linked to the enforcement goals. Without key management tools, FCC may 

have difficulty assuring Congress and other stakeholders that it is meeting its

enforcement mission. 

Limitations in FCC’s current approach for collecting and analyzing 

enforcement data constitute the principal challenge FCC faces in providing 

complete and accurate information on its enforcement program. These 

limitations make it difficult to analyze trends; determine program 

effectiveness; allocate Commission resources; or accurately track and monitor 

key aspects of all complaints received, investigations conducted, and 

enforcement actions taken. 

Disposition of FCC’s 39,000 Closed Investigations, Calendar Years 2003 through 

2006

Source: GAO analysis of Enforcement Bureau’s databases.

Investigation closed; action taken

Investigation closed with no enforcement

action taken; unable to determine reason

why from databases

Investigation closed; unable to determine

if enforcement action was taken

8%

83%

9%

To view the full product, including the scope 

and methodology, click on GAO-08-125. 

For more information, contact Mark Goldstein 

at (202) 512-2834 or goldsteinm@gao.gov. 
Contents 

Letter 1

Results in Brief 3

Background 7

Complaints Received by FCC Have Increased and the Majority of 

Investigations Have Not Resulted in Enforcement Actions 14 

FCC’s Enforcement Bureau Assesses Some Program Outputs, but 

Lacks Key Management Tools to Measure Outcomes and Manage 

Its Program 25 

FCC’s Enforcement Bureau Has Not Fully Defined Its Strategy and 

Has No Specific Goals or Performance Measures 27 

An Inadequate Data Management System Challenges the 

Enforcement Bureau’s Ability to Carry Out Its Responsibilities 31 

Conclusions 34

Recommendations for Executive Action 36 

Agency Comments and Our Evaluation 36 

Appendix I Scope and Methodology 42 

Appendix II Comments from the Federal Communications 

Commission 47 

Appendix III GAO Contact and Staff Acknowledgments 53 

Tables 

Table 1: Divisions and Responsibilities of FCC’s Enforcement 

Bureau 9

Table 2: Summary of Enforcement Bureau’s Approximately 39,000 

Closed Investigations, Calendar Years 2003 through 2006 21 

Figures 

Figure 1: Number of Complaints Received and Processed by the 

Consumer and Governmental Affairs Bureau, Calendar 

Years 2003 through 2006 15 

Page i GAO-08-125 Telecommunications 
Figure 2: Top 10 Complaints Received by the Consumer and 

Governmental Affairs Bureau, Calendar Years 2003 

through 2006 17 

Figure 3: Number of Years Consumer and Governmental Affairs 

Bureau Complaints Were Pending, as of December 31, 

2006 18

Figure 4: Number of Investigations Opened, Closed, and Pending 

by the Enforcement Bureau, Calendar Years 2003 through 

2006 19

Figure 5: Disposition of Enforcement Bureau’s 39,000 Closed

Investigations, Calendar Years 2003 through 2006 20 

Figure 6: Amount of Monetary Forfeitures Assessed and Payments 

Negotiated through Consent Decrees, Calendar Years 

2003 through 2006 23 

Figure 7: Number of Years FCC Enforcement Bureau Investigations 

Were Pending, as of December 31, 2006 24 

Abbreviations 

CGB Consumer and Governmental Affairs Bureau 

FCC Federal Communications Commission 

FTC Federal Trade Commission 

GPRA Government Performance and Results Act of 1993

OMD Office of the Managing Director 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page ii GAO-08-125 Telecommunications 
United States Government Accountability Office

Washington, DC 20548 

February 15, 2008 

The Honorable Edward J. Markey 

Chairman 

Subcommittee on Telecommunications 

and the Internet 

Committee on Energy and Commerce 

House of Representatives 

Dear Mr. Chairman: 

The Federal Communications Commission (FCC) is responsible for 

enforcing the Communications Act of 1934, as amended (the Act), and 

Commission rules and orders. Each year, FCC receives approximately 

100,000 complaints from consumers and companies. FCC has the authority 

to investigate complaints and to take enforcement action if it finds that 

there have been violations of the various telecommunications laws and 

Commission rules that are designed to protect the consumer, ensure 

public safety, and encourage competition. Thus, it is important that FCC 

have a strong and effective enforcement program that allows it to act on 

these complaints in an efficient and equitable manner. 

Within FCC, two bureaus—the Consumer and Governmental Affairs 

Bureau (CGB) and the Enforcement Bureau—have responsibility for 

handling the hundreds of thousands of complaints that FCC receives from 

individuals and companies. CGB is primarily responsible for processing 

the majority of the complaints that FCC receives from individuals. The 

Enforcement Bureau is the primary bureau within FCC that is responsible 

for enforcing the Act’s provisions and FCC’s rules and orders. 

You requested that we review FCC’s enforcement program. This report (1) 

summarizes the number and types of complaints received, investigations 

conducted, and enforcement actions taken by FCC during calendar years 

2003 through 2006; (2) discusses how FCC assesses the impact of its 

enforcement program; and (3) discusses challenges FCC faces in providing 

complete and accurate information on its enforcement program. 

To provide information on the number and types of complaints received,

investigations conducted, and enforcement actions taken by FCC from 

2003 through 2006, we analyzed data entirely from FCC’s six databases for 

Page 1 GAO-08-125 Telecommunications
calendar years 2003 to 2006.1

 We primarily focused our analysis on the 

approximately 46,000 investigations that FCC conducted during this time 

period. We did not review the paper case files that FCC maintains. Our 

focus was on the database systems for FCC’s enforcement program. To 

assess the reliability of FCC’s databases, we performed a separate 

assessment of each of the five databases and of CGB’s database. We 

identified the degree of missing, duplicate, and invalid records and 

analyzed certain data fields to assess the quality of the data. We found 

some inconsistencies and limitations in the databases, which we reported 

to FCC. We also reviewed FCC’s procedures for handling complaints, 

conducting investigations, and taking enforcement actions. While we 

discuss limitations of the data in this report, we determined that the data

were sufficiently reliable for us to present some general information 

regarding the number and types of complaints, investigations and 

enforcement actions. 

To identify the challenges FCC faces, we interviewed officials at FCC and 

15 companies that are subject to FCC’s enforcement, and five experts in 

telecommunications. We selected the companies based on the type of 

telecommunications services provided (radio and television broadcasting,

cable and satellite, wireless and wireline telecommunications services) 

and FCC and industry data for 2006. To assess how FCC measures the 

impact of its enforcement program, we reviewed the agency’s Strategic 

Plan for 2006 through 2011, Fiscal Year 2006 Performance and 

Accountability Report, Fiscal Year 2006 Congressional Justification of

Estimates, and the FCC’s enforcement manual to identify enforcement 

goals and performance measures. We also interviewed FCC officials about 

performance goals and measures and compared FCC’s efforts with 

performance management practices identified in prior GAO reports. We 

conducted this performance audit from November 2006 through December 

2007 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. See appendix I for a more 

detailed explanation of our scope and methodology. 

 1

We initially requested data from CGB and the Enforcement Bureau’s databases for 

calendar years 2000 through 2006 but were told that information from CGB was only 

available for calendar years 2003 through 2006. Thus, to be consistent in reporting the 

results of our review, we are reporting data from 2003 through 2006. 

Page 2 GAO-08-125 Telecommunications
Overall, FCC received and processed hundreds of thousands of 

complaints, conducted tens of thousands of investigations, and took a 

limited number of enforcement actions during calendar years 2003 through 

2006. According to our analysis of FCC’s CGB database for 2003 through 

2006, during this period, the number of complaints received by FCC’s CGB 

totaled 454,000 and grew, from almost 86,000 in 2003, to a high of about 

132,000 in 2005. The CGB processed about 95 percent of these complaints

by sending a letter of acknowledgment to the complainant and, where 

appropriate, referred them for resolution to the company that was the 

subject of the complaint. The largest number of complaints alleged 

violations of the Telephone Consumer Protection Act (TCPA),2

 including 

violations of the do-not-call list request and telemarketing during 

prohibited hours. As of December 2006, about 23,000 complaints remained 

open, with 16 percent of them open from 1 to 4 years. In addition, based 

on our analysis of FCC’s Enforcement Bureau’s databases, from 2003 

through 2006, FCC’s Enforcement Bureau conducted about 46,000 

investigations. These investigations were in response to complaints that 

the Enforcement Bureau received directly, complaints received by CGB,

audits and inspections, and self-initiated inquiries. As of December 2006,

the Enforcement Bureau had closed about 39,000 of the 46,000 

investigations. Based on our analysis of FCC’s Enforcement Bureau’s 

databases for 2003 through 2006, about 9 percent, or almost 3,400, of these

investigations were closed with an enforcement action, and approximately 

83 percent, or about 32,200, were closed with no enforcement. We were 

not able to determine whether enforcement actions had been taken in the 

remaining 3,200 closed investigations or to determine why investigations 

were closed with no discernible enforcement action because the 

Enforcement Bureau databases did not collect this information 

systematically. However, Enforcement Bureau officials told us that some 

investigations may be closed with no enforcement action for such reasons 

as insufficient information or a determination that no violation occurred.

Our analysis of FCC’s Enforcement Bureau databases for 2003 through 

2006 shows that when FCC took an enforcement action, it generally issued 

an admonishment or notice of violation, sometimes assessed a fine, and

rarely relied on more serious enforcement actions. For example, FCC did

not issue any order to cease and desist during this period. As of December 

2006, about 7,200 investigations remained open and almost 1,400 (about 19 

Results in Brief 

 2

In 1991, Congress enacted TCPA to address a growing number of telephone marketing 

calls and certain telemarketing practices thought to be an invasion of consumer privacy 

and, in some cases, costly to consumers. See 47 USC 227. 

Page 3 GAO-08-125 Telecommunications
percent) were open for 1 to 4 years. According to FCC officials, from 2003 

through 2006 the Commission assessed $73 million in fines and payments 

negotiated through consent decrees, of which about $53 million, or 72 

percent, has been collected. 

While FCC assesses the impact of its enforcement program by periodically 

reviewing certain program outputs, it lacks the management tools needed 

to fully measure its outputs and manage its program. Specifically, FCC’s 

Enforcement Bureau has not set specific enforcement goals, developed a 

well-defined enforcement strategy, or established performance measures 

that are linked to the enforcement goals. FCC measures outputs, such as 

the extent to which it takes enforcement action within its statute of 

limitations requirement for assessing fines or the time it takes to close 

investigations, but it does not measure outcomes such as the effects of its 

enforcement actions on levels of compliance in certain areas. Without key 

management tools, FCC may have difficulty fully assuring Congress and 

other stakeholders that it is meeting its enforcement mission of protecting 

the consumer, ensuring public safety, and encouraging competition. 

Limitations in FCC’s current approach for collecting and analyzing 

enforcement data constitute the principal challenge FCC faces in 

providing complete and accurate information on its enforcement program. 

These limitations make it difficult to conduct trend analysis, determine 

program effectiveness, allocate Commission resources, or accurately track 

and monitor key aspects of all complaints received, investigations 

conducted, and enforcement actions taken. Currently, the Enforcement 

Bureau uses five separate databases and manually searches tens of 

thousands of paper case files to track and monitor the extent to which 

each of its divisions takes enforcement action within its statute of 

limitations requirement for assessing fines or the time it takes to close an 

enforcement case. Consequently, we could not use the Enforcement 

Bureau’s databases to obtain bureauwide information on the 1-year statute 

of limitations for imposing monetary forfeitures, the speed with which the 

Enforcement Bureau closed an investigation, the reasons for closing 

investigations with no enforcement action, or the amount of the fines FCC 

assessed. Our past work has shown that when data management systems 

are not integrated and compatible, excessive use of resources and 

inconsistent analysis of program results can occur. 

To develop a more efficient and effective approach to enforcing 

communications laws and Commission rules and orders, we recommend 

that the Chairman of the Federal Communications Commission 

Page 4 GAO-08-125 Telecommunications
• improve how FCC collects and analyzes data on complaints received, 

investigations conducted, and enforcement actions taken to help it 

better manage and understand the outcomes and net results of 

enforcement efforts and provide Congress and stakeholders with 

timely and accurate information that can be used to hold FCC 

accountable for accomplishing its enforcement mission under the 

Act; and 

• develop and implement performance management practices for the 

Enforcement Bureau, such as a well-defined strategy that includes 

specific goals and performance measures, in order to assess the 

effectiveness of FCC’s enforcement program. 

We provided a draft of our report to FCC for review and comment. FCC 

commented that it has already implemented measures that address both of 

our recommendations. In addition, FCC disagreed with our methodology 

and several of our findings. FCC’s comments appear in appendix II. FCC 

also provided over 100 pages of attachments in its comments. Because 

these attachments cover time periods that are after the scope of our audit

and are voluminous, we have decided to characterize the attachments 

rather than include them in their entirety.3

 FCC also provided technical 

and legal clarifications, which we incorporated as appropriate. We also 

clarified our methodology for analyzing FCC’s databases. These technical 

and legal changes did not affect our findings, conclusions, or 

recommendations. 

We are pleased that FCC is moving in the direction suggested by our 

recommendations, but we disagree with FCC that it has already fully

implemented them; we also disagree with FCC’s criticisms of our 

methodology and findings. We believe that our report provides an accurate 

and sufficient overview of FCC’s processes for handling complaints, 

conducting investigations, and taking enforcement actions and the results 

of FCC’s efforts to enforce telecommunications laws and the 

Commission’s rules from 2003 through 2006, the latest year complete data 

was available. We also exercised caution in writing our report to ensure 

that we explained that the results of our analysis are based entirely on 

FCC’s databases. In our view, FCC’s concerns about the accuracy of our 

findings stem from (1) the challenges FCC faces in not having a data

 3

GAGAS does not require us to print in its entirety responses submitted by an agency in 

connection with our reports and allows us to characterize responses where suitable and to 

include or not to include them as appropriate.

Page 5 GAO-08-125 Telecommunications
management system that will allow it to systematically collect and analyze 

information about complaints, investigations, and enforcement actions 

and (2) the Commission’s use of an approach that differs significantly from 

ours. We discuss the challenges posed by FCC’s data management system 

in our report and point out that without improvements, such as we 

recommend, FCC cannot readily analyze trends, determine program 

effectiveness, allocate Commission resources, or accurately track and 

monitor key aspects of all complaints received, investigations conducted,

and enforcement actions taken. In addition, the Commission’s use of data

for 2007 and data from the thousands of paper case files, both of which 

were outside the scope of our analysis, necessarily led to findings that 

differed from ours, but these differences do not affect the appropriateness 

of our methodology or the accuracy of our findings. 

FCC disagreed with our methodology and our findings, conducted its own 

analyses, and included the results of these analyses in attachments to its 

comments. We believe that our methodology meets generally accepted 

government auditing standards which require that we plan and perform 

the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings, conclusions, and recommendations. However, while 

FCC did not provide its methodology, its overall approach differs 

significantly from the approach we used. In its comment letter, FCC 

acknowledged that it had to review about 46,000 paper case files and use 

its databases to determine the reasons why investigations were closed 

with no enforcement action. FCC also acknowledged that it conducted a 

manual review of a variable in its database that we could not use because

of reliability concerns. As noted in our report, the data that we used for 

our analyses are derived directly from FCC’s databases. We did not review 

the 46,000 paper case files that FCC maintains. Our focus was on the 

database systems for FCC’s enforcement program. 

FCC also disagreed with our finding that 83 percent of its investigations 

were closed with no enforcement action and that there were no

justifications for these closures in its databases. In its comments, FCC 

stated that based on its analysis of its databases and paper case files, 85 

percent of its investigations were closed with no enforcement action and 

96 percent of these closures were due to findings of compliance or 

insufficient information from the complainant. To determine the reasons 

why investigations were closed, we attempted to identify a reliable 

variable in FCC’s enforcement database that clearly categorized the 

justifications for closing an investigation with no enforcement action. No 

such variable exists. As an alternative, FCC referred us to open-ended text 

variables. We reviewed these variables, and in June 2007, told FCC 

Page 6 GAO-08-125 Telecommunications
officials that we could not use these variables because they are frequently 

blank or, if completed, contain varying amounts of text to justify the 

actions or lack thereof. While such information may be useful to the FCC 

analysts working on the complaints, they are not usable for management 

information purposes. In addition, as FCC acknowledged in its comments, 

to determine the reasons why its investigations were closed with no 

enforcement action, it had to review approximately 46,000 paper case files. 

As noted in this report, the data that we used for our analysis are derived

entirely from FCC’s databases. We did not review the 46,000 paper case 

files that FCC maintains. Our focus was on the database systems for FCC’s 

enforcement program. Our understanding is that FCC analysts reviewed 

the information from its databases and paper case files and categorized 

the reasons for approximately 46,000 investigations in response to our 

initial analysis. We believe that FCC should have data management 

systems that allow it to generate this type of information automatically, 

reliably, and regularly. Consequently, we stand by our recommendation 

that FCC needs to improve how it collects and analyzes data on 

complaints received, investigations conducted, and enforcement actions 

taken to better manage its enforcement program. 

Two bureaus within FCC—CGB and the Enforcement Bureau— have

responsibilities for developing and implementing procedures for 

processing complaints, conducting investigations, and taking enforcement 

action if appropriate. CGB has primary responsibility for processing the 

majority of the complaints that FCC receives and for responding to other 

consumer complaints and inquiries.4

 For example, some of these 

complaints allege that (1) common carriers may have violated

telecommunications laws and FCC rules; (2) television and radio 

broadcasters may have violated indecency rules; and (3) nonregulated 

entities, such as telemarketers, may have violated some aspects of the 

TCPA, such as the do-not-call list request. CGB may also receive 

complaints and inquiries about consumer issues from congressional 

offices and FCC Commissioners. Under CGB’s process, complaints are 

logged upon receipt into CGB’s database, and acknowledgment letters are

sent to the complainants notifying them that FCC received the complaint.

Complaints against common carriers are processed according to the 

Background 

 4

FCC refers to the complaints it receives as formal and informal; however, for purposes of

this report we are not making that distinction. 

Page 7 GAO-08-125 Telecommunications
procedures outlined in FCC’s regulations, which require FCC to forward 

the complaint to the carrier that allegedly committed the violation and ask 

the carrier to respond to the complainant and FCC.5

 If the common carrier 

responds to the complainant by, for example, issuing a refund or 

explaining the charges, then CGB takes no further action. However, if the

company does not respond, then CGB initiates additional contact after 30 

days and, again, after 60 days, to get the complaint resolved. A CGB 

official told us that CGB also receives a copy of the carrier’s response to 

the complaint. According to FCC, voluntary action by the carrier to 

achieve consumer satisfaction is the expected outcome for most of the 

complaints CGB receives. However, if this outcome is not achieved, the 

complainant may pursue the matter by filing a formal complaint with 

FCC’s Enforcement Bureau.6

 CGB responds to other complaints, such as 

those concerning junk faxes, by acknowledging receipt of the complaint 

and then closing the case. 

Formed in November 1999, the Enforcement Bureau consolidates the 

enforcement functions of FCC’s policy bureaus, which formerly carried 

out their own investigations and enforcement activities.7

 The areas of 

enforcement that are handled by the Enforcement Bureau are consumer 

protection, local competition, and public safety. The Enforcement Bureau 

has four divisions and 25 field offices in three geographic regions. These 

five divisions are responsible for conducting investigations and taking 

enforcement actions, if appropriate (see table 1).8

 5

47 C.F.R. § 1.717. 

6

47 C.F.R. § 1.717-1.718. Special rules apply to the handling of informal slamming 

complaints. See 47 C.F.R. 1.719. 

7

Other FCC bureaus continue to handle some enforcement issues. For example, 

enforcement issues related to licenses are handled by the relevant licensing bureau. 

8

For purposes of this report, we are including the 25 field offices as one of the Enforcement 

Bureau’s five divisions. 

Page 8 GAO-08-125 Telecommunications
Table 1: Divisions and Responsibilities of FCC’s Enforcement Bureau

Division Primary responsibilities

Investigations and Hearings Investigates and takes or recommends enforcement action against (1) broadcast licensees for 

violations of nontechnical Commission rules concerning issues, such as indecency, enhanced 

underwriting, unauthorized assignments and transfers of control of licenses; (2) wireless 

licensees for violations of nontechnical rules involving such issues as auction collusion and 

unauthorized assignments and transfer of control of licensees; (3) common carriers in cases 

involving alleged or suspected misconduct; and (4) in cases involving suspected violations of 

the laws and rules governing universal service. This division also serves as trial staff in formal 

hearings. 

Spectrum Enforcement Investigates and takes or recommends enforcement action for violation of public-safety related 

and other technical rules, such as those governing interference, tower marking and lighting, the 

Emergency Alert System, 911, Enhanced 911, and compliance with operational provisions of 

licenses. This division also handles enforcement action in the areas of unauthorized 

equipment, network reliability or network outages, and digital television, among others. 

Telecommunications Consumers Investigates and takes or recommends enforcement action for violations of consumer-related 

obligations of common carriers and other telecommunications entities, such as slamming, junk 

faxes, and prohibited calls to do-not-call list request subscribers, and adjudicating formal 

complaints filed against telecommunications entities that raise consumer issues and 

proceedings on the accessibility of telecommunications services and equipment to persons with 

disabilities. 

Market Disputes Resolution Resolving complaints by market participants, entities, or organizations against common carriers 

for alleged violations of the Act that are filed under section 208 of the Act; resolving complaints 

filed by cable operators, telecommunications carriers, utilities, and other parties relating to the 

reasonableness of rates, terms, and conditions for pole attachments as stated under section 

224 of the Act; and facilitating settlements of disputes by engaging the parties in mediation. 

Field Offices Responding to spectrum and homeland-security-related safety of life and public safety matters, 

investigating interference complaints, inspecting FCC-regulated entities, and taking or 

recommending enforcement action for violations of public safety and technical rules. 

Source: FCC

The Enforcement Bureau generally investigates alleged violations of 

telecommunications and Commission rules in response to complaints 

received directly from an individual or an entity or from complaints it 

selected from CGB’s database. After a complaint is received, Enforcement 

Bureau staff review it to determine whether it meets FCC’s sufficiency of 

evidence and jurisdictional requirements. If a complaint does not meet 

these requirements, an investigation is not conducted. While Enforcement 

Bureau officials told us that FCC’s enforcement work is primarily 

complaint-based, the bureau does initiate a few investigations in response 

to audits or observations made during the normal course of agency

business, such as research during other investigations. If a violation is 

found during an investigation, then the Enforcement Bureau may take 

enforcement action. 

Page 9 GAO-08-125 Telecommunications
Once a violation is found, the Commission may impose a range of 

enforcement actions. According to FCC, potential enforcement actions 

include the following:9

• Admonishment. A notice that serves to inform the subject that its 

action violates the Act or Commission rules, orders, or terms and 

conditions of authorizations and allows the Enforcement Bureau to 

establish a record of enforcement action in cases where a forfeiture is 

not warranted. 

• Cease and desist order. An order requiring a person to cease and desist 

from violation of the Act or Commission rules.10

• Citation. Provides notice to parties who do not ordinarily conduct 

business with FCC (i.e., persons not holding or applying for 

Commission authorizations) that their actions violate the Act or FCC 

rules and could subject them to a monetary forfeiture. A forfeiture may 

not be issued for the subject of a citation but may be imposed for 

subsequent violations. 

• Consent decree. An agreement between FCC or the Enforcement 

Bureau and the party of an investigation that sets forth the terms and 

conditions of accepted behavior to which that subject must conform in 

exchange for closure of the investigation or forfeiture proceedings. A 

consent decree generally includes a compliance plan and a voluntary 

contribution to the U.S. Treasury. 

• Criminal and civil penalties. The Act provides for a fine of not more 

than $10,000 or a criminal penalty of imprisonment for up to 1 year for 

a first-time conviction of willfully and knowingly violating the Act (47 

USC § 501). A second conviction for violating any provision of the Act 

is punishable by a fine of not more than $10,000 or imprisonment for up 

to 2 years. FCC has no authority to initiate a criminal action against a

subject for violation of the Act; instead, FCC must refer such a matter 

to the Department of Justice. 

 9

According to FCC, besides enforcement actions, investigations may also result in denials,

dismissals, or a determination that a party complied with relevant rules. 

10According to FCC, a cease and desist order can only be issued by the Commission or an

administrative law judge following a hearing. 

Page 10 GAO-08-125 Telecommunications
• Debarment.

11 FCC’s debarment rules establish procedures to prevent 

persons who have been convicted of or held civilly liable for attempting 

to commit or committing a variety of offenses from engaging in 

activities with or related to universal service mechanisms. The offenses 

covered by the rule include criminal fraud, theft, embezzlement, 

forgery, bribery, falsification or destruction of records, making false 

statements, receiving stolen property, making false claims, and 

obstruction of justice or other fraud or criminal offense arising out of 

activities associated with or related to universal service mechanisms, 

such as the schools’ and libraries’ support mechanisms. 

• Equipment seizure (In Rem seizure). Primarily used in cases 

involving unlicensed or pirate radio stations where FCC field agents, in 

conjunction with the U.S. Marshal Service and the U.S. Attorney’s 

Office, seize radio transmitting equipment. 

• Monetary forfeiture. A fine assessed for violation of the Act or FCC 

rules, orders, or terms and conditions of an authorization. The Act 

provides two methods by which FCC may assess monetary forfeitures. 

The most commonly used method is to issue a notice of apparent 

liability. This notice, which is a proposed action, informs the subject 

that FCC believes that a violation has occurred and that a forfeiture in 

a specified dollar amount is warranted. The other method is the 

issuance of a notice of opportunity for hearing. This hearing process is 

typically used in application hearing designation and revocation 

proceedings and entitles the subject to a full hearing before an

administrative law judge.

• Notice of violation. A notice generally issued by an FCC field office to 

an FCC-regulated entity concerning a violation of laws or rules that is 

identified during an inspection. The notice requires the subject to 

respond to the allegation and, based on the response, additional action

may be taken. 

• Revocation of license. Reserved for the most egregious violations of 

the law that raise serious questions about a licensee’s basic 

qualifications to be and remain a licensee. Such offenses include 

misrepresentation, lack of candor, and repeat violations of the Act or 

Commission rules and orders.12

 1147 CFR § 54.8. 

12According to FCC, as with cease and desist orders, a revocation of license can only be

issued by the Commission or an administrative law judge following a hearing. 

Page 11 GAO-08-125 Telecommunications
The Commission may assess a monetary forfeiture for violations of the 

Act, the Commission’s rules, a Commission order, or terms and conditions 

of an authorization. The Commission’s general legal authority can be

found in Section 503 of the Act.13 Section 503 of the Act sets forth 

maximum forfeiture amounts for violations by licensees or regulated 

entities. Section 503(b) of the Act requires that the Commission take into

account the nature, circumstances, extent, and gravity of the violation and, 

with respect to the violator, the degree of culpability, any history of prior 

offenses, ability to pay, and any other such matters as justice may require.

These requirements are implemented by FCC rules.14 In 1997, to help 

implement these criteria, the Commission adopted Guidelines for 

Assessing Forfeitures.

15 These guidelines are used to help determine the 

amount of a forfeiture for a specific violation and to provide a base 

forfeiture amount for most of the common violations. The base amount 

can be adjusted up or down, depending on the existence of factors 

meeting the adjustment criteria, such as a history of prior violations. 

Although the guidelines represent the general method for assessing 

forfeitures, the Commission has discretion to depart from them when 

appropriate.

Section 503 (b) of the Act also limits the time within which FCC may 

assess a monetary forfeiture. For common carriers and all other entities 

except broadcast licensees, the notice of apparent liability or notice of 

opportunity for hearing is required to be issued within 1 year of the 

violation. For broadcast licensees, the notice of apparent liability or 

notice of opportunity for hearing may be issued if the violation occurred 

during the current license term or within the last year, whichever is 

earlier. 

 13Other forfeiture amounts or other sanctions are established in other sections of the 

Communications Act of 1934, as amended, including sections 202(c); 203 (e); 205(b); 

214(d); 219(b); 220(d); 364(a)-(b); 386(a)-(b); and 634. 

14See 47 C.F.R. § 1.80 for current maximum forfeiture amounts. In accordance with the

inflation adjustment requirements contained in the Debt Collection Improvement Act of 

1996, Pub. L. 104-134, Sec. 31001, 110 Stat. 1321, the Commission has twice implemented an

increase of the maximum statutory forfeiture amounts.

15See Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to 

Incorporate the Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087 (1997) 

(“Forfeiture Policy Statement”), recon. denied, 15 FCC Rcd 303 (1999); 47 C.F.R. § 

1.80(b)(4), note to paragraph (b)(4).

Page 12 GAO-08-125 Telecommunications
After a fine is assessed, information on the fine is sent to the Office of the 

Managing Director (OMD) for tracking and monitoring of payment. OMD 

has responsibility within FCC for keeping track of what fines have and 

have not been paid. The Enforcement Bureau receives reports from OMD 

and has access to OMD’s database to monitor payment, as well. Although 

the Enforcement Bureau and the Commission have the legal authority to 

impose fines, the U.S. Department of Justice has the authority to collect 

unpaid fines. Thus, when a case is past due, the Enforcement Bureau 

refers the case to its Office of General Counsel, which then determines 

whether or not to refer the case to the U.S. Department of Justice for 

collection. Once the U.S. Department of Justice receives a referral from 

FCC’s Office of General Counsel, it can decide whether or not to pursue a 

case or to collect a fine.

Companies have several opportunities to respond to FCC’s assessment of 

a monetary forfeiture. For example, after a notice of apparent liability is 

issued, a company may submit information, including financial 

information, and request that the fine amount be reduced or cancelled. If 

FCC decides to move forward with the fine (whether the original amount 

or a reduced amount) and the company disagrees with the fine, then the 

company can ask for the fine to be reviewed. Companies may request that 

the Commissioners review the fine by filing a petition for reconsideration 

of an Enforcement Bureau forfeiture order or submitting an application

for review of a fine issued by the Commission. 

At any point during an investigation or after a fine has been assessed, a 

company may request to settle with FCC and enter into a consent decree. 

A consent decree terminates the investigation or forfeiture, and the 

subject of the investigation agrees to certain terms and conditions but 

typically does not admit or deny any wrongdoing. The terms and 

conditions usually include specific steps to correct the violation and 

ensure future compliance, as well as a voluntary monetary contribution to 

the U.S. Treasury. 

In commenting on a draft of this report, FCC disagreed with our 

description of its process for responding to consumer complaints and said

that during the course of our review it began responding to 100 percent of 

consumer complaints. Our description of FCC’s process for responding to

consumer complaints is based on information it provided to us during the 

course of our review. During the course of our review, FCC stated that it

planned to change its process for responding to consumer complaints. 

However, in the 100 page attachment to its letter FCC did not provide any 

documentation explaining how or when the process changed. Thus, we 

Page 13 GAO-08-125 Telecommunications
were not able to evaluate any changes that FCC may have made to it 

process for responding to consumer complaints. As part our routine 

recommendation follow-up work, we will inquire about FCC’s progress in 

this area. 

Overall, FCC received and processed hundreds of thousands of complaints 

and conducted thousands of investigations but took a limited number of 

enforcement actions from 2003 through 2006. The number of consumer 

complaints received by CGB totaled about 454,000 and increased by about 

40 percent during this period. As of December 31, 2006, about 95 percent 

of these complaints were closed. In addition, the Enforcement Bureau 

conducted about 46,000 investigations and closed about 39,000, of which 

almost 3,400 resulted in an enforcement action and about 32,200 did not 

result in an enforcement action. About 7,200 investigations remained open. 

According to FCC, it has collected about 72 percent of the $73 million in 

monetary forfeitures and payments associated with consent decrees 

issued from 2003 through 2006. 

For calendar years 2003 through 2006, the number of complaints received 

by CGB totaled about 454,000 and grew, from almost 86,000 in 2003, to a 

high of about 132,000 in 2005, as shown in figure 1. Also, as shown in 

figure 1, the number of complaints processed during these years increased,

reaching a high of 116,000 in 2005. 

Complaints Received 

by FCC Have 

Increased and the 

Majority of 

Investigations Have 

Not Resulted in 

Enforcement Actions 

Complaints Received and 

Processed by FCC’s CGB 

Have Increased 

Page 14 GAO-08-125 Telecommunications
Figure 1: Number of Complaints Received and Processed by the Consumer and

Governmental Affairs Bureau, Calendar Years 2003 through 2006 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

 

Not processed

Processed

2003 2004 2005 2006

Source: GAO analysis of CGB’s database.

Number of complaints

Total number

of complaints

each year 85,824 116,446 132,049 120,054

66,511

19,313

101,328

15,118

116,005

16,044

100,633

19,421

In its written comments, FCC said that figure 1 only reflects the status of 

complaints received by CGB during the year in which the complaint was 

received and that the figure does not reflect complaints that were closed in 

subsequent years. This figure is designed to show a year-by-year analysis 

of the number of complaints received, processed, and not processed by 

CGB in the same year and is not designed to show the number of 

complaints that were received in one year and processed in a subsequent 

year. 

Furthermore, from 2003 through 2006, about 65 percent of the 454,000 

complaints received by CGB were about alleged violations of the FCC’s 

TCPA rules, as well as billing and rates for wireline and wireless services, 

as shown in figure 2. TCPA complaints, which include allegations of failing 

to honor the do-not-call list request and soliciting during prohibited hours, 

Page 15 GAO-08-125 Telecommunications
increased, from almost 25,000 in 2003, to a high of about 58,000 in 2005.16

In addition, complaints about billing and rates for wireline and wireless 

services increased, from almost 30,000 in 2003, to almost 36,000 in 2004; 

complaints then decreased to about 21,000 in 2006. These complaints 

included not receiving credits, refunds, or adjustments that were owed to 

the subscriber; questions about local, state, or federal taxes appearing on 

the complainant’s bills; and premature termination of calls. The overall

trend for programming issues, such as indecency, has been steadily 

upward. For example, this type of complaint increased, from about 700 in

2003, to almost 9,000 in 2006. 

 16Under FCC’s TCPA rules, no person or entity may initiate any telephone solicitation to a

residential telephone subscriber before 8 a.m. or after 9 p.m., based on the called party’s 

local time. 47 C.F.R. 64.1200(e)(1). 

Page 16 GAO-08-125 Telecommunications
Figure 2: Top 10 Complaints Received by the Consumer and Governmental Affairs Bureau, Calendar Years 2003 through 2006 

TCPA (general solicitations)

Complaints regarding the receipt of unsolicited calls or messages

for the purpose of encouraging the purchase, rental, or investment 

in property, goods, or services.

Billing and rates

Complaints regarding a number of issues, including airtime 

charges, roaming rates, credit, and refund adjustments.

Referral to government agencies/FCC offices/states

Complaints beyond FCC’s jurisdiction, such as intrastate billing 

charges and expanded local calling service.

Service related issues

Complaints regarding the quality of services provided by cable, 

satellite, wireless, and wireline providers.

Carrier marketing and advertising

Complaints regarding advertising and marketing practices of 

carriers, including misrepresentation.

Programming issues

Complaints regarding programs, such as those that allegedly 

contain indecent, obscene, or profane material.

Number portability

Complaints regarding the porting of telephone numbers from a

wireline to a wireless carrier or the reverse.

Slamming

Complaints regarding the switching of a consumer’s telephone 

services from one telephone company, or from one calling plan, 

to another.

Cramming

Complaints regarding unauthorized, misleading, or deceptive 

charges on a consumer’s telephone bill for services and products.

Operator Service Provider issues

Complaints about a common carrier that provides services from 

public phones, including payphones, and those in hotels or motels.

All other complaints

Complaints such as those regarding connection to cable service, 

closed captioning of video programs, digital subscriber lines, and 

may also include consumer inquiries.

Subject matter

0 10,000 20,000 30,000 40,000 50,000 60,000

2003 2004 2006 2005

Number of complaints

Total

(2003-2006)

454,373

178,079

117,875

20,757

19,509

17,568

16,076

13,824

10,374

8,915

5,273

46,123

Source: GAO analysis of CGB’s database.

Page 17 GAO-08-125 Telecommunications
Our analysis of CGB’s database shows that, as of December 31, 2006, CGB 

had processed almost 95 percent of the 454,000 complaints it received

from 2003 through 2006. Of the 23,000 complaints that were not processed, 

about 84 percent, or 19,400, were pending for less than 1 year, and about 

16 percent, or almost 3,600, were pending for 1 to 4 years, as shown in 

figure 3. Most of the complaints that remained pending were potential 

TCPA and billing violations. 

Figure 3: Number of Years Consumer and Governmental Affairs Bureau Complaints 

Were Pending, as of December 31, 2006 

Number of years

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

20,000

<1 1 - 2 2 - 3 3 - 4

Number of complaints

Source: GAO analysis of CGB’s database.

Enforcement Bureau 

Opened and Closed a 

Large Number of 

Investigations, but Few 

Enforcement Actions Were 

Taken 

Based on our analysis of FCC’s Enforcement Bureau’s databases for 

calendar years 2003 through 2006, the Enforcement Bureau opened a total 

of about 46,000 investigations that resulted from complaints it received 

directly, audits and inspections, self-initiated inquiries, and complaints it 

selected from CGB’s database; the bureau closed about 39,000 of these 

investigations.17 As shown in figure 4, the number of investigations the 

Enforcement Bureau opened between 2003 and 2006 increased, from 

 17The Enforcement Bureau does not investigate every complaint received by CGB. We were

not able to identify the number of complaints from CGB’s database that the Enforcement

Bureau selected for investigation. 

Page 18 GAO-08-125 Telecommunications
about 8,600 in 2003, to almost 19,600 in 2006, or about 127 percent. 

Similarly, the number of investigations closed by the Enforcement Bureau 

in the same year they were opened also increased, from about 7,400 in 

2003, to almost 13,800 in 2006, or about 85 percent. However, the number 

of investigations pending in the same year they were opened almost 

quadrupled—increasing from almost 1,200 in 2003, to about 5,800 in 2006.

In addition, while the number of investigations opened and closed 

increased in 2005 and 2006, the percentage of investigations closed in 

these years is starting to trend downward to about 78 and 70 percent, 

respectively, compared with about 85 percent in 2003 and 2004. 

Figure 4: Number of Investigations Opened, Closed, and Pending by the 

Enforcement Bureau, Calendar Years 2003 through 2006 

0

4,000

8,000

12,000

16,000

20,000

Pending

Closed

2003 2004 2005 2006

Source: GAO analysis of the Enforcement Bureau’s databases.

Number of investigations

Total number

of investigations

each year 8,621 8,288 9,765 19,593

7,447

1,174

7,052

1,236

7,654

2,111

13,764

5,829

Using the data that was available in the Enforcement Bureau’s databases, we 

determined that about 9 percent, or almost 3,400 of the approximately 39,000 

investigations, were closed with an enforcement action, and about 83 percent, 

or about 32,200 of the investigations, were listed as closed with no enforcement

action, as shown in figure 5. We asked Enforcement Bureau officials to provide 

information on why investigations were closed with no enforcement action.

They explained that investigations are generally closed for a number of reasons, 

Page 19 GAO-08-125 Telecommunications
including insufficient information or because no violation was found. 

Enforcement Bureau officials also stated that a time-consuming, manual review

of the paper case files was necessary to provide specific information on its 

enforcement activities. We also were not able to determine whether 

enforcement actions were taken or not taken for the remaining 8 percent, or 

about 3,200 closed investigations, because the Enforcement Bureau’s databases 

did not contain sufficient information on the disposition of the investigations. 

Figure 5: Disposition of Enforcement Bureau’s 39,000 Closed Investigations, 

Calendar Years 2003 through 2006 

Source: GAO analysis of Enforcement Bureau’s databases.

Investigation closed; action taken

Investigation closed with no enforcement

action taken; unable to determine reason

why from databases

Investigation closed; unable to determine

if enforcement action was taken

8%

83%

9%

Note: The information in this figure was derived entirely from our analysis of FCC’s Enforcement 

Bureau’s databases. This figure does not include 283 proceedings closed by the Market Disputes

Resolution Division. Market Disputes Resolution Division cases result in FCC’s issuance of an order 

to resolve a dispute between two companies, rather than a specific enforcement action taken by FCC

against a subject.

Enforcement actions can help correct identified compliance problems and 

deter future noncompliance. As shown in table 2, the majority of the 

investigations conducted from 2003 through 2006, which totaled about 

20,000, were potential violations regarding antenna lighting and structure 

requirements, 18 junk faxes, domestic interference, and indecency. FCC 

 18For public safety purposes, FCC requires owners to register antenna structures that are 

more than 200 feet in height or located near an airport. 

Page 20 GAO-08-125 Telecommunications
took enforcement actions in about 1,300 of these investigations; 

admonishments, warnings, citations, and notices of violation were the 

primary actions taken. FCC rarely relied on more serious enforcement 

actions, such as issuing an order to cease and desist. According to FCC, it 

takes several factors into account, such as the nature and extent of the 

violation and whether the violator had any history of prior offenses, before 

determining the type of enforcement action. 

Table 2: Summary of Enforcement Bureau’s Approximately 39,000 Closed Investigations, Calendar Years 2003 through 2006 

Types of enforcement actions takena

Type and number of 

investigations

Admonishment 

and warning Citation 

 Consent 

decree Debarment 

 Monetary 

forfeitureb

 Notice 

of 

violation 

Closed; 

no 

action

taken

Unable to 

determine if 

any action

was taken

 Antenna lighting and structure 

requirements (9,241) 

 320 49 244 8,628 

 Junk fax (4,135) 192 1 3,942 

 Domestic interference (3,539) 221 30 54 114 3,120 

 Indecency (3,075) 85 11 2,880 99 

Customer Proprietary Network

Information (CPNI) 

certification (2,315) 

 2,315 

 Audits of certification-based 

facilities (1,965) 

 189 72 92 1,612 

Emergency Alert System 

requirements (1,533) 

 230 53 69 1,181 

 Due diligence (1,082)c 365 717 

 Other general enforcement 

(1,079)d

 34 3 5 6 1,031 

Cable TV leakage (1,022) 98 7 6 142 769 

All other investigationse (9,800) 698 124 50 10 88 77 6,394 2,348 

Total (38,786) 1,790 356 135 10 339 744 32,237f3,164

Source: GAO analysis of Enforcement Bureau’s databases. 

Note: The information in this table was derived entirely from our analysis of FCC’s Enforcement 

Bureau’s databases. 

a

In addition to the enforcement actions listed in this table, the Enforcement Bureau took four civil/ 

criminal actions and seven equipment seizures. 

b

Monetary forfeiture also includes notice of apparent liability actions. 

c

According to an Enforcement Bureau official, due diligence, though included in its databases, is not 

an investigation. Due diligence refers to a request made to the Enforcement Bureau for information 

concerning matters pending before the Bureau that might adversely impact a proposed transaction 

with a station or company. 

Page 21 GAO-08-125 Telecommunications
d

FCC did not provide us with a definition for investigations it referred to as other general enforcement. 

e

All other investigations includes, for example, Freedom of Information requests, Universal Service 

Fund, unlicensed and unauthorized operations, sponsorship identification, and unauthorized 

equipment enforcement. 

f

This figure does not include 283 proceedings closed by the Market Disputes Resolution Division. 

In its written comments FCC said that figure 5 and table 2 in our report 

understate or inaccurately state information about its enforcement record 

or systems. As such, FCC conducted its own analyses and provided us 

with the results of these analyses. However, while FCC did not provide its 

methodology, its overall approach differs significantly from the approach

we used. Based on discussions with FCC officials, we analyzed the 

variables from its databases that contained information on enforcement 

actions and that could be searched for codes indicating particular types of 

actions, such as “citation” or “monetary forfeiture.” We worked 

extensively with these officials to ensure that we searched for all of the 

appropriate codes for enforcement actions. However, in its comment 

letter, FCC acknowledged that it had to review about 46,000 paper case 

files and use its databases to determine the reasons why investigations 

were closed with no enforcement action. FCC also acknowledged that it 

conducted a manual review of a variable in its database that we could not 

use because of reliability concerns. As noted in our report, the data that 

we used for our analyses are derived directly from FCC’s databases. We 

did not review the 46,000 paper case files that FCC maintains. Our focus 

was on the database systems for FCC’s enforcement program. We 

continue to believe that FCC should have data management systems that 

will allow it to generate this type of information automatically, reliably, 

and regularly. 

According to FCC, it assessed fines and negotiated payments through 

consent decrees, which totaled about $73 million from 2003 through 2006, 

and has collected about $53 million, or 72 percent. However, as shown in 

figure 6, the amount of the fines and payments negotiated through consent 

decrees decreased, from about $25 million in 2003 and $26 million in 2004, 

to almost $11 million in 2005 and $12 million in 2006—a decrease of more 

than 50 percent. According to an Enforcement Bureau senior official, the 

phasing out of section 271 complaints may have contributed to this 

Page 22 GAO-08-125 Telecommunications
decrease.19 FCC staff also stated that the amount of fines and negotiated

payments through consent decrees totaled about $43 million in 2007. 

Figure 6: Amount of Monetary Forfeitures Assessed and Payments Negotiated

through Consent Decrees, Calendar Years 2003 through 2006 

Year

0

5,000

10,000

15,000

20,000

25,000

30,000

2003 2004 2005 2006

Dollars in millions

Source: FCC.

At the end of December 2006, the Enforcement Bureau had almost 7,200 

investigations that were pending resolution, as shown in figure 7. About 81 

percent, or about 5,800, were pending for less than 1 year, and 19 percent, 

or almost 1,400, were pending from about 1 to 4 years. About 46 percent of

the pending investigations were related to potential indecency violations, 

 19Under section 271 of the Communications Act of 1934, as amended, the Bell Operating

Companies (BOC) needed to file applications with FCC on a state-by-state basis in order to

provide in-region, interLATA services. In 2002, the Enforcement Bureau set up a Section

271 Compliance Review Program for each newly filed section 271 application. As of

December 3, 2003, the Commission had granted all of the BOCs section 271 authorization

for the provision of in-region, interLATA services in all of the BOCs’ territories nationwide.

Page 23 GAO-08-125 Telecommunications
and about 800 of them remained open for more than 1 year. According to

FCC, litigation has delayed resolution of many indecency investigations.20

Figure 7: Number of Years Enforcement Bureau Investigations Were Pending, as of

December 31, 2006 

Number of years

0

1,000

2,000

3,000

4,000

5,000

6,000

<1 1 - 2 2 - 3 3 - 4

Number of investigations pending

Source: GAO analysis of FCC data.

It is difficult to fully determine the reasons why the trends we identified

occurred. FCC officials were not able to explain or provide documentation 

on why the number of complaints, investigations, and enforcement actions 

fluctuated from 2003 through 2006. While we were able to use FCC 

enforcement data to identify some overall trends, FCC had not 

systematically identified trends related to enforcement issues associated 

with its overall mission, and we were not able to use the data to determine 

why the trends occurred. Apart from providing requested information for 

our analysis of FCC’s enforcement data, the Enforcement Bureau has 

taken few steps to analyze the Commission’s existing data to determine 

the reasons for the fluctuations in complaints received, investigations 

conducted, and enforcement actions taken. FCC has not systematically 

 20Fox Television Stations, Inc. v. FCC, 489 F.3d 444 (D.C. Cir. 2007), petition for cert. filed, 

No. 07-582, 2007 Westlaw 3231567 (Nov. 1, 2007); Complaints Against Various Television 

Licensees Concerning Their February 1, 2004 Broadcast of the Super Bowl XXXVII 

Halftime Show, pet. for rev. pending sub nom. CBS Corp. v. FCC, No. 06-3575 (3d Cir. Filed 

July 28, 2006). 

Page 24 GAO-08-125 Telecommunications
analyzed its existing enforcement data to identify factors that might 

account for the year-to-year fluctuations we found in the data. While FCC 

has an array of enforcement actions that it may take, performing this type 

of analysis may help in assessing the effectiveness of the enforcement 

program and the utility of FCC’s enforcement actions. 

FCC’s Enforcement Bureau periodically reviews some of its enforcement 

program outputs to determine how well it is doing in certain areas but 

does not use its data to evaluate the outcomes of its enforcement efforts. 

The Enforcement Bureau’s ability to assess the impact of its enforcement 

program is limited because it does not have a well-defined enforcement 

strategy, specific enforcement goals, or performance measures. We have

previously reported that a key element in an organization’s efforts to 

manage for results is its ability to select meaningful performance goals and 

measures. Without these key management tools, FCC faces challenges in 

managing its enforcement program and in fully assuring Congress and 

other stakeholders that it is meeting its enforcement mission and related 

objectives of the Act, which include protecting the consumer, ensuring 

public safety, and encouraging competition. 

FCC has focused on measuring the outputs of its enforcement program 

and not on measuring outcomes or the net effect of its program. For 

example, Enforcement Bureau officials told us that two measures they use 

to determine how well they are doing are whether they have met the 

statute of limitations for monetary forfeitures and how long it takes to 

close a case. However, Enforcement Bureau officials told us that to 

prepare written reports on these two output measures, data must be 

compiled from several different databases, as well as from a manual 

search of thousands of paper case files. In addition, each of the 

Enforcement Bureau’s five divisions described a different method for 

measuring its performance. For example, three divisions (Spectrum 

Enforcement, Investigations and Hearings, and the Field Offices) told us 

they know their actions are effective because they handle 100 percent of 

the complaints they receive. The Telecommunications Consumer Division 

generally assesses its effectiveness on a case-by-case basis through staff 

dialogue, and the Market Disputes Resolution Division measures its 

effectiveness by the percentage of proceedings, that meet statutory 

deadlines, and the amount of time taken to close cases. 

FCC’s Enforcement 

Bureau Assesses 

Some Program 

Outputs, but Lacks 

Key Management 

Tools to Measure 

Outcomes and 

Manage Its Program 

FCC’s Enforcement 

Bureau Measures Outputs 

Rather Than Outcomes 

While measures of outputs are useful, measures of outcomes are also 

important because they can provide FCC with broader information on 

Page 25 GAO-08-125 Telecommunications
program results, such as the extent to which its current enforcement 

efforts are contributing to higher compliance rates or fewer repeat 

violations or whether other types of enforcement action may be needed to

deter noncompliance. Currently, FCC’s Enforcement Bureau conducts 

limited analyses of its enforcement data. For example, the Enforcement 

Bureau monitors the amount of time it takes to close an investigation, but 

it does not measure the effect of one of its key enforcement tools—

monetary forfeitures—on companies’ compliance with 

telecommunications laws and Commission rules. Without this information, 

it is difficult for FCC to make sound decisions about how this program 

might be made more effective. In addition, FCC created the Enforcement 

Bureau in 1999 because it wanted to enhance the Commission’s ability to 

serve the public by improving the effectiveness of the enforcement 

program. However, FCC has not analyzed the impact of this new 

organizational structure to determine if it is more effective and efficient

than the previous decentralized structure, under which several bureaus 

were responsible for enforcing telecommunications laws and Commission 

rules. According to Enforcement Bureau officials, they believe that 

centralizing enforcement efforts has been effective because it has enabled 

the bureau to establish standard procedures across all issue areas, 

resulting in more consistent and effective enforcement, and has also 

brought greater visibility and importance to the enforcement function. As 

a measure of the program’s effectiveness, Enforcement Bureau officials 

pointed out that the efforts of the bureau have garnered headlines in the 

mainstream press and have been cited by a wide range of citizens and 

industry participants. 

We asked several stakeholders, including telecommunications company 

executives and telecommunications experts, for their views on the impact 

of FCC’s enforcement efforts.21 Eleven of the fifteen executives we 

interviewed stated that they believe FCC’s enforcement program is having 

an impact on the telecommunications industry, and four of the five experts 

we interviewed said they thought FCC was having a positive effect on the 

telecommunications industry. For example, one expert stated that FCC is 

doing a good job, particularly in protecting consumers; another said that

the Enforcement Bureau has had an impact on reducing intentional 

interference and ensuring public safety; and a third said that FCC’s 

 21As our sample size was small and nongeneralizeable, the views we obtained may not be 

representative of all stakeholders. However, we asked experts and company 

representatives about similar issues. 

Page 26 GAO-08-125 Telecommunications
Enforcement Bureau has been effective in working with the states to 

address slamming and cramming issues. However, all five experts and 9 of 

the 15 executives we interviewed were also critical of FCC’s enforcement 

efforts. The 9 executives said that FCC’s enforcement decisions are not 

always equitable, and 6 of the 9 stated that FCC’s enforcement actions 

were not always transparent. For example, 1 executive said that the use of 

consent decrees lacked both transparency and equity because there was 

no indication as to how the final result was determined and parties to the 

consent decree did not know how prior consent decrees involving the 

same alleged violation were handled. Another executive told us that the 

focus of FCC’s investigations appeared to be arbitrary and based on the 

issues of the moment, resulting in inequitable enforcement actions. One 

expert stated that whenever FCC makes an enforcement decision, there is

always the possibility that negotiations behind the scenes are not subject 

to public review. 

FCC’s Enforcement Bureau has not fully defined its strategy for carrying 

out its enforcement of consumer protection, public safety, and 

competition laws and rules. FCC’s Web site states that “the Enforcement 

Bureau is the primary organizational unit within the Federal

Communications Commission that is responsible for enforcement of 

provisions of the Communications Act, the Commission’s rules, 

Commission orders and terms and conditions of station authorizations.” 

However, FCC’s Strategic Plan for 2006 through 2011, Fiscal Year 2006 

Performance and Accountability Report, and Fiscal Year 2006 

Congressional Justification of Estimates do not identify specific 

enforcement goals or performance measures linked to those goals that 

would allow a complete assessment of the results of FCC’s enforcement 

program.22 In addition, while the Enforcement Bureau has an enforcement 

manual that provides general guidance on conducting investigations, the 

various types of enforcement actions it can take, and how each should be 

used, the manual does not specify enforcement goals or priorities relating 

to consumer protection, public safety, and competition. 

FCC’s Enforcement 

Bureau Has Not Fully 

Defined Its Strategy 

and Has No Specific 

Goals or Performance 

Measures 

 22According to an FCC official, while the Enforcement Bureau does not have outcome

goals, it does have some output goals. As an example of FCC’s output goals, the official 

provided us with a copy of a March 31, 2006, letter sent to the Chairman, Subcommittee on

Commerce, Justice, Science, and Related Agencies, House Committee on Appropriations.

In response to questions from the Chairman, FCC wrote that the Commission attempts to 

resolve public safety interference complaints within 1 day, nonemergency interference

complaints within 1 month, indecency complaints within 9 months, formal complaints 

within 1 year, and all other investigations and complaints within 15 months. 

Page 27 GAO-08-125 Telecommunications
Federal agencies are required to develop strategic plans with long-term, 

outcome-oriented goals and objectives, annual goals linked to achieving 

the long-term goals, and annual reports on the results achieved.23 An 

analysis of FCC’s Strategic Plan for 2006 through 2011, Fiscal Year 2006 

Performance and Accountability Report, and Fiscal Year 2006 

Congressional Justification of Estimates shows that, although there are 

strategic goals for FCC, there are no strategic or performance goals 

pertaining to the Enforcement Bureau. For example, in its Strategic Plan 

for 2006 through 2011, FCC lists goals in six categories: broadband, 

competition, spectrum, media, public safety and homeland security, and 

FCC modernization. Each of these strategic goals is supported by a 

number of objectives showing how FCC will meet these goals. Several of 

the objectives include the term “enforcement,” such as the objective that 

states, “the Commission shall vigorously enforce its spectrum regulations 

and policies,” but there are no specific or measurable enforcement actions

indicated. The Fiscal Year 2006 Performance and Accountability Report

also illustrates the lack of specific performance measures relating to 

enforcement. In the section on program performance, there are 

performance goals for each of the six strategic goals. While some of these 

performance goals do include the term “enforcement,” such as in the 

statement “enforce the Commission’s rules for the benefit of consumers,” 

no specific, measurable actions are listed. Additionally, in the Fiscal Year

2006 Congressional Justification of Estimates, FCC uses a performance 

measure scorecard to identify its activities of the past year in support of 

each of its six strategic goals. One of the activities in support of homeland 

security is to “enforce technical regulations and investigate harmful 

interference complaints affecting public safety communications systems 

and infrastructure.” FCC rated itself as having met this goal, although 

there are no specific actions listed and no indication of how much activity 

is required for FCC to meet the goal.

Enforcement Bureau officials told us that the bureau has not set specific 

goals and performance measures because its priorities are constantly 

changing. Officials explained that the Enforcement Bureau is responsive 

to a number of stakeholders—Congress, Commissioners, the public—and 

the priorities of those stakeholders change. In addition, the Enforcement 

Bureau is responsible for enforcing a wide range of rules and issues, and 

current enforcement priorities may not be future enforcement priorities. 

For example, according to an FCC official, issues regarding the transition 

 23Pub. L. No. 103-62, 107 Stat. 285. 

Page 28 GAO-08-125 Telecommunications
to digital television have become a high priority, but after February 2009,

when the transition takes place, these issues will no longer be as 

significant. However, we found that the Enforcement Bureau had specific 

enforcement goals and performance measures in the past. For example, in 

its fiscal year 2004 annual performance plan, FCC specified the following 

performance goals relating to enforcement and stated that it met these 

goals: 

• achieve a 10 percent reduction in the number of long-distance 

slamming complaints in 2000, a 20 percent reduction in 2001, and a 40

percent reduction in 2002; 

• achieve 65 percent compliance with new disability rules in 2000, 80 

percent compliance in 2001, and 85 percent compliance in 2002; and 

• achieve 85 percent compliance with antenna lighting rules in 2000, 90 

percent compliance in 2001, and 92 percent compliance in 2002. 

The Federal Trade Commission (FTC), which shares responsibility with 

FCC for consumer protection against violations of the do-not-call list 

request and telemarketing fraud, has developed goals and performance 

measures to assess the results of its enforcement program. For example, 

one of FTC’s strategic goals is to maintain competition by identifying and

taking enforcement action against anticompetitive mergers and practices

that cause the greatest injury to consumers. In support of this goal, they 

have established performance measures, one of which is to achieve a 

positive result in at least 80 percent of the cases in which the FTC takes 

enforcement action each year. According to FTC officials, setting specific 

goals and performance measures allows them to target their enforcement 

activities and more efficiently use their limited resources. 

Goals and Performance 

Measures Are Key 

Elements of Effective 

Management 

We have previously reported that a key element in an organization’s efforts 

to manage for results is its ability to set meaningful performance goals and 

measures and agencies should create a set of performance goals that 

address key aspects of program performance. We and other federal 

agencies have also maintained that adequate and reliable performance 

Page 29 GAO-08-125 Telecommunications
measures are a necessary component of effective management. 24 We have 

also found that performance measures should provide agency managers 

with timely, action-oriented information in a format conducive to helping 

them make decisions that improve program performance, including 

decisions to adjust policies and priorities.25 However, FCC does not appear

to be using these key management practices to manage the work of its 

Enforcement Bureau. 

In 2006, we recommended that FCC develop goals and performance 

measures for its program pertaining to the enforcement of junk fax rules.

FCC has told us it is in the process of implementing some of those 

recommendations. For example, in 2006, we found that FCC’s 

Enforcement Bureau did not have goals or performance measures for junk 

fax monitoring and was not performing any analysis of complaint and 

enforcement data, making it impossible to explore the effectiveness of 

their current enforcement measures.26 FCC acknowledged the need for 

such measures and, in July 2007, told us it had begun drafting such goals 

and performance measures. The Commission has also recognized the need

for more data to measure performance, as indicated by a directive from 

FCC’s OMD issued in May 2007. This directive outlines FCC’s plans to 

begin collecting and analyzing data to measure the performance of 

Commission programs that involve the processing of applications or other 

filings from the public or other private entities. An Enforcement Bureau 

official told us that the bureau will respond to this directive by gathering 

data that could be used to help FCC better manage its enforcement 

program. Although these efforts, when completed, will begin to address 

the Enforcement Bureau’s lack of specific program goals and performance 

measures, the Enforcement Bureau will not have goals or performance 

measures for several of its divisions, such as the Investigations and 

Hearings Division or the Market Disputes Resolution Division. Without 

goals, a well-defined enforcement strategy, and performance measures 

 24GAO, Results-Oriented Government: GPRA Has Established a Solid Foundation for 

Achieving Greater Results, GAO-04-38 (Washington, D.C.: Mar. 10, 2004); GAO, Managing

for Results: Strengthening Regulatory Agencies’ Performance Management Practices, 

GAO/GGD-00-10 (Washington, D.C.: Oct. 28, 1999); and GAO, Agency Performance Plans: 

Examples of Practices That Can Improve Usefulness to Decisionmakers, 

GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999). 

25GAO, Pipeline Safety: Management of the Office of Pipeline Safety’s Enforcement

Program Needs Further Strengthening, GAO-04-801 (Washington, D.C.: July 23, 2004). 

26GAO, Telecommunications: Weaknesses in Procedures and Performance Management 

Hinder Junk Fax Enforcement, GAO-06-425 (Washington, D.C.: Apr. 5, 2006). 

Page 30 GAO-08-125 Telecommunications
linked to those goals, the Commission lacks important tools for assessing 

and reporting on the progress of its enforcement program and determining 

whether changes should be made. 

FCC disagreed with our finding that it has no specific enforcement goals 

or performance measures. In its comments, FCC stated that its 

performance goals for disposing of complaints are 1 day for public safety 

interference complaints, 1 month for nonemergency interference 

complaints, and 9 months for indecency complaints. We view FCC’s efforts 

to collect, track, and report data for such goals as first steps toward 

performance management, and we encourage FCC to ensure that it 

consistently includes this information in its future Performance and 

Accountability Reports. However, as we state in our report, such goals are 

measures of outputs and are useful as indicators of program activities, but 

measures of outcomes, such as the extent to which FCC’s current 

enforcement efforts are contributing to higher compliance rates or fewer 

repeat violations may be more important because they can provide FCC 

with broader information on program results. 

Limitations with FCC’s current approach for collecting and analyzing 

enforcement data challenge the ability of the Enforcement Bureau to carry 

out its enforcement responsibilities, making it difficult for the bureau and 

others to determine the enforcement program’s effectiveness or for the 

bureau to accurately track and monitor data on complaints received, 

investigations conducted, and enforcement actions taken. Currently, the 

Enforcement Bureau uses several separate databases and manually 

searches paper case files to track and monitor its enforcement activities. 

Consequently, we could not use the Enforcement Bureau’s databases to 

obtain bureau-level information on the percentage of monetary forfeitures 

assessed within FCC’s statute of limitations, the speed with which FCC 

disposed of complaints, the reasons for closing investigations with no 

enforcement action, or the amounts of the fines FCC assessed. Our past 

work has shown that when data management systems are not integrated 

and compatible, excessive use of resources and inconsistent analyses of 

program results can occur. 

An Inadequate Data 

Management System 

Challenges the 

Enforcement Bureau’s

Ability to Carry Out 

Its Responsibilities 

The Enforcement Bureau has five databases, one for each of its five 

divisions. However, these databases are not standardized and do not track 

the same information in the same manner. FCC officials explained that

when the Enforcement Bureau was created in 1999, it inherited these 

databases from the various bureaus and, partly because of budget 

constraints, cobbled them together rather than create a single, 

Page 31 GAO-08-125 Telecommunications
standardized, automated data management system. These officials 

acknowledged that the databases have limitations and were created only 

to manage staff workload, not to track the history of cases or measure 

performance.27

While the Enforcement Bureau’s databases do contain some information, 

our analysis of their files indicates that this information is not sufficient to

measure certain important aspects of FCC’s enforcement program. For 

example, when we tried to determine whether FCC met the statute of 

limitations for assessing monetary forfeitures, we could not determine 

how many cases the Enforcement Bureau resolved within the statutory 

deadline because the databases did not contain sufficient information. 

Specifically, the Investigations and Hearings Division’s database was 

missing 84 percent, the Telecommunications Consumers Division’s 

database was missing 99 percent, and the Spectrum Enforcement 

Division’s database was missing 99 percent of the information needed to 

determine whether FCC met the statute of limitations for assessing 

monetary forfeitures. Of the remaining two databases, one (for Field 

Offices) would allow the statutory deadline to be determined for 

investigations that were closed with an enforcement action, but not for 

investigations that were closed with no enforcement action because the 

database does not include a field for the date of the alleged violation. The 

other database is managed by the Market Disputes Resolution Division; 

according to Enforcement Bureau officials, the majority of the division’s 

investigations do not have a statute of limitations involving forfeitures, and 

the database does not have a field for this information.28

We were also unable to determine how long it took the Enforcement 

Bureau to open and close investigations for three of its five divisions 

because of how the required information is entered into the databases. 

Enforcement Bureau personnel did not always enter the dates into the 

database and, when a date was entered, it was not always clear what the 

date represented. For example, it was unclear whether the date entered 

was the date of the initial or the final enforcement action. More 

 27According to an FCC official, the Commission is planning to spend $2 million to improve 

its existing systems for receiving, processing, and enforcing consumer telemarketing 

complaints alleging violations of junk fax and do-not-call list request but has not finalized 

its plans to improve the Enforcement Bureau’s databases. 

28FCC may choose to initiate a forfeiture proceeding separate and apart from a formal 208

complaint proceeding. The complainant would not be a party to such a forfeiture 

proceeding. 

Page 32 GAO-08-125 Telecommunications
specifically, according to one Investigations and Hearings Division official,

it would be difficult to calculate the speed of disposal times for 

investigations in its database because entering the date when an 

investigation was closed was not always a priority for the division and its 

database does not track all milestones in an investigation. While the 

Spectrum Enforcement Division’s database has fields for opening and 

closing dates, we were not able to calculate the speed of disposal because

we could not always determine what the closing date represented. 

According to Enforcement Bureau officials, the Telecommunications 

Consumers Division’s database cannot determine the speed of disposal for 

investigations because some investigations tracked in the database have 

been closed at one point with an enforcement action but have

subsequently been reopened to consider the next stage of enforcement. 

This reopening affects both the number of enforcement actions tracked in 

the database and the speed of disposition. In addition, cases that were 

initially closed but then reopened, and left pending for some time after 

being reopened, would be tracked back to the initial date and would 

appear to have taken a long time to close. As a result, data for such cases 

would skew calculations of the average speed of disposition for all of the 

Telecommunications Consumers Division’s enforcement actions. 

We were also unable to use the Enforcement Bureau divisions’ databases 

to determine the amounts of the fines the bureau had assessed, the 

amount collected, or the status of the uncollected amount. We could not

determine this information because several of the database fields relating

to fines either were missing information or did not contain sufficient 

information to allow for data analysis.

29 For example, while the 

Investigations and Hearings Division’s database tracks the amounts of the 

fines assessed, the information is not consistently entered into the 

database and there are no distinct fields for the amounts initially assessed, 

reduced, collected, or outstanding. In addition, we found that the database 

used by the Telecommunications Consumers Division had a table for 

tracking fines, but data were not entered into the table consistently. FCC 

officials told us that they could generate information on fines and other 

aspects of the agency’s enforcement program by manually searching 

thousands of paper files.

Finally, during the course of our review, we could not use FCC’s databases 

to determine how many of the 32,200 investigations that were closed with 

 29The Market Disputes Resolution Division does not impose fines.

Page 33 GAO-08-125 Telecommunications
no enforcement action from 2003 through 2006 were closed because no

violation was found, because of insufficient information, because the 

statute of limitations had expired, or because of other reasons. We were 

not able to make this determination because FCC did not collect the 

information systematically, which hampered our ability to analyze its 

enforcement efforts. Specifically, we found that the Investigations and 

Hearings and the Telecommunications Consumers Divisions’ databases 

did not clearly indicate whether a case was closed because no violation 

was found or because of other reasons. The Spectrum Enforcement 

Division entered some information specific to why investigations were 

closed with no enforcement action in text fields, but the information was 

not entered in a way that would allow for quantitative analysis. While the

Field Office database allows for some determination of when 

investigations were closed with no enforcement action, we had to follow 

up with Field Office officials to obtain the specific reasons. In addition, we 

could not use the database to determine why the majority of their 

investigations were closed with no enforcement action. According to Field 

Office officials, the majority of their investigations do not result in an 

enforcement action because, generally, no Commission rules were 

violated. For FCC to analyze the 83 percent of investigations that did not 

result in an enforcement action, it would have to (1) access files for all of 

those cases, (2) ensure that the files contained sufficient information for a 

reviewer to reconstruct the reasons for no action, and (3) establish and 

implement procedures that would ensure consistency and accuracy in the 

review. FCC could also review a statistical sample of the cases in which no 

action was taken, rather than the entire universe of such cases. The review

procedures should include clear guidance for reviewers to categorize the 

reasons for no action and provide a means for checking the accuracy and 

consistency of the reviewers. 

The extent to which FCC is effectively enforcing the Communications Act 

of 1934, as amended, and Commission rules and orders is difficult to 

assess because it lacks a robust data management system, as well as 

performance goals and measures. For example, a more robust data 

management system for monitoring complaints, investigations, and 

enforcement actions is critical for the agency to better understand the 

outcome and net results of its enforcement efforts. In past reports, we 

have discussed the importance of maintaining timely and accurate data to

help monitor and improve the effectiveness of government programs. We 

have found that, in order to make informed decisions and ensure 

accountability, agencies need data management systems that can generate

timely, accurate, and useful information. Lacking such critical information, 

Conclusions 

Page 34 GAO-08-125 Telecommunications
government leaders are not able to invest resources where they are 

needed, reduce costs, or fully oversee programs; they are also unable to 

hold agency managers accountable for the outcomes of government 

programs. We also found that agencies that do not have integrated data

management systems are more likely to devote more time and resources 

to collecting information than those with integrated systems and that 

opportunities for errors increase when agency systems are not compatible.

Moreover, beyond our analysis of FCC’s enforcement data, there have 

been limited efforts to analyze the Commission’s existing data to identify

trends and determine the reasons for the year-to-year fluctuations in the 

number of complaints received, investigations conducted, and 

enforcement actions taken. FCC has not systematically analyzed its 

existing data to identify factors that might account for these fluctuations 

and to assess their implications for the enforcement program. As 

demonstrated by our analysis of FCC’s enforcement data, the Commission 

does have some information available, despite data limitations, to analyze 

enforcement outputs and outcomes in a manner that could provide more 

reliable, useful, and timely information for managing its day-to-day 

operations and to make more informed decisions about its enforcement 

efforts. In addition, improvements in existing data management could 

make this type of analysis more useful and could enhance FCC’s ability to 

provide Congress and other stakeholders with accurate and timely 

information on its enforcement program. This information could also help

the Enforcement Bureau determine whether different policy options might 

be more effective in implementing the enforcement program. 

The extent to which the Enforcement Bureau is achieving its mission is 

difficult to determine because the bureau does not use several important 

performance management tools. FCC’s Enforcement Bureau has not set

specific enforcement goals, developed a well-defined strategy for 

achieving those goals, or established performance measures linked to 

goals. Performance measures of program results are important for several

reasons. First, they can help hold agencies accountable for the 

performance of their programs. Among other things, measures of 

enforcement results may help FCC allocate limited resources where they 

are most needed and determine if rules and procedures should be changed 

to deter potential violators. Second, Congress needs information on 

program results to support its oversight of agencies and their budgets. 

Third, stakeholders can use this information to accurately judge program 

effectiveness. 

Page 35 GAO-08-125 Telecommunications
To develop a more effective approach to enforcing telecommunications 

laws and Commission rules, we recommend that the Chairman of the 

Federal Communications Commission 

• improve how FCC collects and analyzes data on complaints received, 

investigations conducted, and enforcement actions taken to help it 

better manage and understand the outcomes and net results of 

enforcement efforts and to provide Congress and stakeholders with 

timely and accurate information that can be used to hold FCC’s 

enforcement program accountable for accomplishing its mission under 

the Act; and 

• develop and implement additional performance management practices, 

such as outcome measures, to assess the performance and improve the 

accountability of FCC’s enforcement program. 

We provided a draft of our report to FCC for review and comment. FCC 

commented that it has already implemented measures that address both of 

our recommendations, but it provided no supporting documentation. In 

addition, FCC disagreed with our methodology and several of our findings. 

FCC’s detailed comments appear in appendix II. FCC also provided over 

100 pages of attachments in its comments. Because these attachments 

cover time periods that are after the scope of our audit and are 

voluminous, we have decided to characterize the attachments rather than 

include them in their entirety.30 FCC also provided technical and legal 

clarifications, which we incorporated as appropriate. In appendix I, we 

also clarified our methodology for analyzing FCC’s databases. These 

technical and legal changes did not affect our findings, conclusions, or 

recommendations. 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 

In FCC’s view, it has already implemented measures that address both of 

our recommendations. Concerning our first recommendation, FCC said 

that during the period of our audit (2003 through 2006), the Commission 

was already aware of the challenges posed by its limited information 

systems and database management resources and already had plans in 

place to improve its enforcement data collection methods and process. By 

 30Generally accepted government auditing standards do not require us to print responses 

submitted by an agency in connection with our reports in their entirety and allows us to 

characterize responses where suitable, and to include or not to include responses as 

appropriate. 

Page 36 GAO-08-125 Telecommunications
July 2007, FCC said, the Commission had secured congressional approval

to make significant modifications to the databases and systems used to 

support its enforcement activities. Concerning our second 

recommendation, FCC noted that it has implemented standardized 

enforcement performance goals to better manage the enforcement process 

and to automate portions of this process. Moreover, according to FCC, 

goals and measures for managing the enforcement process have been 

incorporated for the first time into the performance plans of the senior 

executives responsible for oversight of the enforcement program and that 

information about these efforts is included in the Commission’s Fiscal 

Year 2007 Performance and Accountability Report. Finally, FCC said that 

we based our conclusions and recommendations on significantly outdated 

information and that our report contains several errors. As a result of 

these errors, FCC said, our report provides a misleading description of 

FCC’s current enforcement processes, understates or inaccurately states 

information about FCC’s enforcement record or systems, and provides an 

incomplete and misleading picture of FCC’s legal enforcement 

environment. 

We are pleased that FCC may be taking some steps toward implementing 

our recommendations, but we disagree with FCC that it has already fully

implemented them; we also disagree with FCC’s criticisms of our 

methodology and findings. We believe that our report provides an accurate 

and sufficient overview of FCC’s processes for handling complaints, 

conducting investigations, and taking enforcement actions and the results 

of FCC’s efforts to enforce telecommunications laws and the 

Commission’s rules from 2003 through 2006. We also exercised the due 

diligence in writing our report to ensure we explained that the results of 

our analysis are based entirely on FCC’s databases. In our view, FCC’s 

concerns about the accuracy of our findings stem from (1) the challenges 

FCC faces in not having a data management system that will allow it to 

systematically collect and analyze information about complaints, 

investigations, and enforcement actions and (2) the Commission’s use of 

an approach that differs significantly from ours. We discuss the challenges 

posed by FCC’s data management system in our report and point out that

without improvements such as we recommend, FCC cannot readily 

analyze trends, determine program effectiveness, allocate Commission 

resources, or accurately track and monitor key aspects of all complaints 

received, investigations conducted, and enforcement actions taken. In 

addition, the Commission’s use of data for 2007 and data from paper case 

files, both of which were outside the scope of our analysis, necessarily led

to findings that differed from ours. These differences, however, do not 

Page 37 GAO-08-125 Telecommunications
affect the appropriateness of our methodology or the accuracy of our 

findings. 

In commenting that it has already implemented our first 

recommendation—to improve how it collects and analyzes data on 

complaints received, investigations conducted, and enforcement actions 

taken—FCC stated that its Managing Director wrote Congress on June 27, 

2007, asking for approval to upgrade its databases and that FCC expected

the final delivery of system enhancements this year. While we are pleased 

that FCC has taken this step, on July 26, 2007, the Chief of FCC’s 

Enforcement Bureau stated that the funds would be used to enhance 

CGB’s database for processing junk fax and do-not-call list request 

complaints and that FCC has no specific plans or time frames for 

upgrading the Enforcement Bureau’s databases. In its comments, FCC did 

not provide any additional information that changes our understanding of

the Enforcement Bureau’s plans to upgrade it databases systems. Thus, it 

is not apparent to us how enhancements to CGB’s database will address 

the weaknesses with the Enforcement Bureau’s databases. Therefore, we 

do not believe that FCC has yet fully implemented our first 

recommendation. 

In commenting that it has already implemented our second 

recommendation—that it develop and implement performance 

management practices for the Enforcement Bureau, such as a well-defined 

enforcement strategy that includes specific goals and performance 

measures—FCC cited its implementation of standardized enforcement 

performance goals, its incorporation of enforcement goals and measures 

in the performance plans of its senior executives responsible for 

enforcement oversight, and its inclusion of this information in its Fiscal 

Year 2007 Performance and Accountability Report. The performance 

goals that FCC cited for disposing of complaints are 1 day for public safety

interference complaints, 1 month for nonemergency interference 

complaints, and 9 months for indecency complaints. We view FCC’s efforts 

to collect, track, and report data for such goals as first steps towards 

performance management, and we encourage FCC to ensure that it 

consistently includes this information in its future Performance and 

Accountability Reports. However, as we state in our report, such goals are 

measures of outputs and are useful as indicators of program activities, but 

are not measures of outcomes, such as the extent to which FCC’s current 

enforcement efforts are contributing to higher compliance rates or fewer 

repeat violations. These outcome measures are necessary to determine a 

broader perspective on program results. Thus, while FCC has begun to 

develop and implement performance management practices, we believe

Page 38 GAO-08-125 Telecommunications
that further efforts are needed for FCC to fully implement our 

recommendation. 

FCC disagreed with our methodology and our findings, conducted its own 

analyses, and included the results of these analyses in attachments to its 

comments. According to FCC, its results are more accurate than ours. We 

disagree and believe that our results represent an accurate analysis of the 

relevant information in FCC’s databases. Whereas we used data only from

FCC’s databases, FCC used information from both its databases and its 

approximately 46,000 paper case files. In addition, because FCC’s 

databases are frequently updated and it analyzed data a year after we 

received our data, we believe this could have contributed to the 

differences in our results. As part of our routine recommendation followup work, we will assess FCC’s progress in 2007. 

According to FCC, the data for 2003 through 2006 that we used are out of

date. However, these are the most recent data for complete years that 

were available to us at the time of our review. In conducting our audit 

work, we often select data for the last 3 or 4 years to analyze because it 

allows us to ensure the consistency and integrity of the data, identify 

trends, and understand information over time. We initially designed our 

analysis to cover a longer time period and requested data from FCC for 

2000 through 2006, but FCC was not able to provide us with CGB’s data 

from 2000 through 2003 because data prior to 2003 had been purged from 

its files. To be consistent in our reporting, we analyzed data from CGB and 

the Enforcement Bureau for the same time period, 2003 through 2006. 

FCC also stated that our report does not acknowledge or assess its new 

process for handling consumer complaints. We disagree. Our description 

of FCC’s process for responding to consumer complaints is based on 

information it provided to us during the course of our review. During the 

course of our review, FCC stated that it planned to change its process for 

responding to consumer complaints. However, FCC did not provide any 

documentation explaining how or when. Thus, we were not able to 

evaluate any changes that FCC may have made to it process for 

responding to consumer complaints. 

FCC also disagreed with our finding that 83 percent of its investigations 

were closed with no enforcement actions and that there were no 

justifications for these closures in its databases. In its comments, FCC 

stated that its analysis of its databases and paper case files showed that 85

percent of its investigations were closed with no enforcement actions and 

96 percent of these closures were due to findings of compliance or 

Page 39 GAO-08-125 Telecommunications
insufficient information from the complainant. To determine the reasons 

why investigations were closed, we attempted to identify a reliable 

variable in FCC’s enforcement database that clearly categorized the 

justifications for closing an investigation with no enforcement action. No 

such variable exists. As an alternative, FCC referred us to open-ended text 

variables in the course of our audit work. We reviewed these variables, 

and in June 2007, told FCC officials that we could not use these variables

because many of the database fields were frequently blank or, if 

completed, contained varying amounts of text to justify the actions or lack 

thereof. While such information may be useful to the FCC analysts 

working on the investigations, they are not useful or usable for 

management information purposes. In addition, as FCC acknowledged in 

its comments, to determine the reasons why its investigations were closed 

with no enforcement action, it had to use approximately 46,000 paper case

files. As noted in our report, the data that we used for our analysis are 

derived entirely from FCC’s databases. We did not review the 46,000 paper

case files that FCC maintains. Our focus was on the database systems for 

FCC’s enforcement program. FCC also acknowledged that it conducted a 

manual review of a variable that indicated enforcement action codes we

could not search with any reliability. While our analyses are accurate 

based on the database variables we analyzed, we acknowledge that they 

do not account for information that FCC retained in paper case files and 

did not enter into its databases or for information that was entered in data

fields that we could not search with our computer routines. Our 

understanding is that FCC analysts reviewed the information from its 

databases and paper case files and categorized the reasons for 

approximately 46,000 investigations after we conducted our initial 

analysis. We believe that FCC should have data management systems that 

allow it to generate this type of information automatically, reliably, and 

regularly. Therefore, we stand by our recommendation that FCC needs to 

improve how it collects and analyzes data on complaints received, 

investigations conducted, and enforcement actions taken because we do

not believe that managing a program by reviewing 46,000 paper case files 

constitutes a good management practice. 

Finally, we continue to believe that the findings, conclusions, and 

recommendations in our report are accurate and can improve how FCC 

manages its enforcement program. We also believe that FCC will continue 

to have difficulty providing Congress and other stakeholders with accurate

and timely information on its enforcement efforts if it does not take 

additional steps to fully address our recommendations. 

Page 40 GAO-08-125 Telecommunications
As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution of it until 30 days from 

the date of this letter. At that time, we will send copies of this report to the 

appropriate congressional committees and the Chairman of the Federal

Communications Commission. We will also make copies available to 

others on request. In addition, the report will be available at no charge on

the GAO Web site at http://www.gao.gov. 

If you or your staff have any questions, please contact me at (202) 512-2834

or goldsteinm@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

GAO staff who made major contributions to this report are listed in 

appendix III. 

Sincerely yours, 

Mark L. Goldstein 

Director, Physical Infrastructure Issues 

Page 41 GAO-08-125 Telecommunications
Appendix I: Scope and Methodology 

Page 42 GAO-08-125 Telecommunications

Appendix I: Scope and Methodology 

To summarize the number and types of complaints received, investigations

conducted, and enforcement actions taken by the Federal

Communications Commission (FCC) during calendar years 2003 through

2006, we obtained six different databases from FCC in various formats. 

FCC’s Enforcement Bureau provided four Microsoft Access databases and 

one fixed-width delimited text file, which had several text files linked by a 

single unique identifier. FCC’s Consumer and Governmental Affairs 

Bureau (CGB) also provided a fixed-width delimited text file, which was a 

single ‘flat file’ that contained information on all complaints received from

2003 through 2006. The ‘flat file’ contained all the information and there 

were no other data files associated with it. When available, FCC also 

provided data dictionaries, user guides, screen shots, and illustrations of 

how key tables were linked for each database. Each of FCC’s databases is 

independent (meaning that they are not connected or related to one 

another) and, therefore, the specific data elements contained in each one 

differed. Additionally, when multiple databases contained the same data 

element, it was often referred to or tracked differently. 

We subsequently reviewed each database and file for consistency; 

duplication; and missing identifiers, such as case number. We limited our 

analysis to records that had an open date between calendar years January

1, 2003 and December 31, 2006. We excluded all cases in each database 

that were received before 2003 and after 2006. We then sorted the data into 

closed and pending cases. Closed cases had a closing date in the record 

and were closed as of December 31, 2006. If a situation existed in which a 

case had multiple records with varying dates, we always used the last date. 

We also excluded any cases where the closing date was before the opening

date. Pending cases are cases that either did not have a closing date or the 

closing date was after December 31, 2006. We also reviewed the data 

dictionaries FCC provided to determine which fields contained the data 

elements we planned to report on. We ran frequency distributions using 

SAS software on all selected fields. These distributions provide guidance 

as to whether the contents are complete enough for use. This means that if 

a database has two similar fields such as Date Received and Data Entry 

Date, we needed to know which of these fields is used most frequently so

that we could base our analysis on fields that are actually used by FCC. 

For example, if the Date Received field was populated only 40 percent of 

the time and the Data Entry Date field was populated 99 percent of the 

time, we used the Data Entry Date field. Based on this analysis, we 

developed a list of fields we could use from each database. We compared 

this list to the data elements we wanted to report on to determine the 

extent to which we would be able to report data according to our initial 

plan. We found that for three of the five Enforcement Bureau’s databases 
Appendix I: Scope and Methodology 

that are maintained by its Investigations and Hearings Division, 

Telecommunications Consumers Division, and Field Offices, we could 

report on the subject matter, the number of open and closed cases, and the 

disposition of closed cases from 2003 through 2006. For one of the 

remaining two databases, we were only able to report on the number of 

open and closed cases from 2003 through 2006. The remaining database is

maintained by the Enforcement Bureau’s Market Disputes Resolution 

Division. This division does not conduct investigations; instead it conducts

proceedings which may result in FCC’s issuance of an order to resolve a 

dispute between two companies, rather than an enforcement action. Thus, 

we are not including this database in our analysis. 

We met with Enforcement Bureau officials to discuss the specific fields 

that we were planning to use and the manner in which we were going to 

use them. These officials agreed with the fields we had selected and

acknowledged the limitations we faced with its databases. We reached 

agreement with Enforcement Bureau officials that for the Investigations

and Hearings Division, Telecommunications Consumers Division, and 

Field Office databases we would report on the subject matter, the number 

of opened and closed investigations, and the most recent action taken for 

the closed investigations. Since the databases contained a large number of

subject matters and many options for disposition of closed cases, we 

worked with Enforcement Bureau officials to combine the subject matters 

and dispositions of cases for reporting purposes. For example, CGB’s 

database contained numerous subject matters for various types of billing 

issues. Based on discussions with CGB officials, we combined all subject 

matters related to billing into one subject matter called “Billing.” 

Based on our interviews with FCC and examination of its data, we 

determined that certain variables in the databases were sufficiently 

reliable for the purposes of this engagement. These variables allowed us to 

identify closed cases and determine whether enforcement actions had 

been taken, but did not allow us to determine the reasons for which 

actions were taken. To determine whether enforcement actions were 

taken, we analyzed the variables from FCC’s databases. FCC officials told

us that these databases contained information on enforcement actions and 

could be searched for codes indicating particular types of actions, such as 

“citation” or “monetary forfeiture.” We worked extensively with these 

officials to ensure that we searched for all of the appropriate codes for 

enforcement actions. We did not analyze the approximately 46,000 paper 

case files that FCC maintains. Our focus was on the database systems for 

FCC’s enforcement program. We also did not analyze a lengthy text 

variable that FCC indicated might contain some information on 

Page 43 GAO-08-125 Telecommunications
Appendix I: Scope and Methodology 

enforcement actions because the information was entered in data fields 

that we could not search with our computer routines. To determine why 

investigations were closed with no enforcement actions, we attempted to

identify a reliable variable in FCC’s enforcement database that clearly 

categorized the justifications for closing an investigation with no 

enforcement action. No such variable exists. As an alternative, FCC 

referred us to open-ended text variables in the course of our audit work. 

We reviewed these variables, and in June 2007, told FCC officials that we

could not use these variables because they were not analyzable. We also 

discovered that some database fields were frequently blank or, if 

completed, contained varying amounts of text to justify the actions or lack 

thereof. Thus, we were not able to use the databases to determine why 

investigations were closed with no enforcement action. 

In addition, we interviewed officials from FCC’s CGB about the 

Commission’s overall approach for enforcing telecommunications laws 

and rules, as well as its specific processes for handling complaints, 

conducting investigations, and taking enforcement actions. We also 

reviewed the FCC Enforcement Bureau’s Enforcement Manual and the 

Code of Federal Regulations to understand how FCC conducts 

investigations, determines whether a violation has occurred, and whether 

an enforcement action is appropriate. Finally, to ensure that we fully 

understood FCC’s process for handling complaints, conducting 

investigations, and taking enforcement actions, in April, 2007, we provided 

FCC’s Enforcement Bureau and CGB officials with a written summary of 

its processes for review. We revised our summary based on FCC’s 

technical comments. 

To review how FCC assesses the impact of its enforcement program, we 

interviewed both the Chief of the Enforcement Bureau and representatives 

from each of the divisions about their methods for assessing the 

effectiveness of their enforcement activities. We reviewed FCC’s Strategic 

Plan for 2006 through 2011, Fiscal Year 2006 Performance and 

Accountability Report, Fiscal Year 2006 Congressional Justification of

Estimates, and FCC’s Enforcement Manual in order to identify

enforcement goals and performance measures. We also reviewed 

provisions of the Government Performance and Results Act of 1993 

(GPRA) and prior GAO reports on the effectiveness of GPRA and the 

methods other federal agencies use to measure their performance in order 

to identify leading performance measurement practices. We also analyzed 

FCC’s quarterly complaint reports to assess the volume and subject matter 

of complaints over the past 4 years. As part of our analysis of the 

performance measures used by FCC’s Enforcement Bureau, we also 

Page 44 GAO-08-125 Telecommunications
Appendix I: Scope and Methodology 

interviewed officials from the Federal Trade Commission (FTC) to identify 

their methods for assessing the effectiveness of their enforcement 

program and obtained and reviewed information from FTC on its 

enforcement activities, as well as its Strategic Plan for 2006 through 

2011, and Fiscal Year 2006 Performance and Accountability Report. To 

understand how FCC selects subjects and companies for investigation, we 

reviewed documentation for FCC’s Data Analysis Report on 

Telecommunications and FCC reports based on that analysis for 2000 

through 2006. In performing our work, we also reviewed and considered 

best practices identified in previous GAO reports and guides issued over 

the years on strategic plans and planning processes and the 

implementation of GPRA requirements. These documents helped us to 

compare the FCC Enforcement Bureau’s management practices with those 

of leading organizations.

To obtain views on the effectiveness of FCC’s enforcement efforts, we 

contacted 25 telecommunications companies and obtained interviews with 

executives from 15 of them. Of the 15 companies, 4 were in the radio and

television broadcasting industry; 4 were in the cable and satellite industry;

and 7 were in the wireless and wireline industry. In making this selection, 

we chose companies based on the following criteria: type of 

communication services provided (radio and television broadcasting, 

cable and satellite, wireless and wireline telecommunications services) 

and company size (small, medium, and large) according to FCC and 

industry data. We also contacted seven experts with knowledge of the 

telecommunications sector and FCC’s enforcement program and obtained 

interviews with five of them. Among the five experts, two are 

academicians who have taught and written extensively about 

telecommunications, and the other three once held positions at FCC but 

are no longer employed at the Commission. The views we obtained from

stakeholders and experts may not be representative of all stakeholders, 

but we asked both experts and stakeholders about similar issues. 

Finally, to identify challenges FCC faces in providing complete and 

accurate information on its enforcement program, we interviewed FCC 

officials to understand how complaints are processed, investigated, and 

resolved. We obtained from FCC six different databases in various 

formats, five from the Enforcement Bureau and one from CGB; sent and 

received answers to data reliability questions; and discussed the 

limitations of each of the Enforcement Bureau’s databases with staff from 

each of the divisions in the Enforcement Bureau. We examined each 

database for consistency in order to determine if the fields were sufficient 

for use. Based on this analysis, we developed a list of fields we could use 

Page 45 GAO-08-125 Telecommunications
Appendix I: Scope and Methodology 

from each database and compared the fields across databases to 

determine what data elements could be reported across all databases. We 

found that we were limited in what we could report. 

We conducted this performance audit from November 2006 through 

December 2007 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 

Page 46 GAO-08-125 Telecommunications
Appendix II: Comments from the Federal 

Communications Commission 

Page 47 GAO-08-125 Telecommunications

Appendix II: Comments from the Federal 

Communications Commission 
Appendix II: Comments from the Federal 

Communications Commission 

Page 48 GAO-08-125 Telecommunications
Appendix II: Comments from the Federal 

Communications Commission 

Page 49 GAO-08-125 Telecommunications
Appendix II: Comments from the Federal 

Communications Commission 

Page 50 GAO-08-125 Telecommunications
Appendix II: Comments from the Federal 

Communications Commission 

Page 51 GAO-08-125 Telecommunications
Appendix II: Comments from the Federal 

Communications Commission 

Page 52 GAO-08-125 Telecommunications
Appendix III: GAO Contact and Staff 

Acknowledgments 

Page 53 GAO-08-125 Telecommunications

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov

Staff 

Acknowledgments 

In addition to the contact named above, individuals making key 

contributions to this report include Tammy Conquest, Assistant Director; 

Eli Albagli; Martin De Alteriis; Konstantin Dubrovsky; Sharon Dyer; Bess 

Eisenstadt; Heather Frevert; Mitch Karpman; Josh Ormond; Mindi 

Weisenbloom; and Nancy Zearfoss. 

(543182) 
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