UNITED STATES GOVERNMENT

FEDERAL COMMUNICATIONS COMMISSION 

OFFICE OF INSPECTOR GENERAL

MEMORANDUM

DATE: January 22, 2024 

TO: Chairwoman Jessica Rosenworcel 

Commissioner Brendan Carr 

Commissioner Geoffrey Starks 

Commissioner Nathan Simington

 Commissioner Anna Gomez 

FROM: Acting Inspector General Sharon R. Diskin

SUBJECT: Final Report on the Audit of the Federal Communications Commission 

Affordable Connectivity Program (Project No. 23-AUD-01-04). 

In accordance with Infrastructure Investment and Jobs Act (Infrastructure Act) dated November 

15, 2021, Public Law 117–58, the Office of Inspector General (OIG) is providing the final report 

on the Audit of the Federal Communication Commission’s Affordable Connectivity Program 

(ACP). 

The OIG contracted with Kearney and Company, P.C. (Kearney) to audit the FCC’s 

implementation of the ACP. This audit is consistent with the OIG's authority under the Inspector 

General Act of 1978, as amended, but not limited to sections 2(1)(2) and 4(a)(1). The audit is not 

intended as a substitute for any agency regulatory compliance review or regulatory compliance 

audit. The audit was performed in accordance with generally accepted government auditing 

standards. Those standards require that the auditors plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for their findings and conclusions 

based on the audit objectives. 

The audit was conducted from November 2022, through August 2023. The audit scope period 

covered ACP activities from January 1, 2022, through December 31, 2022, to meet the carryover 

provision from the Consolidated Appropriations Act of 2021 (PL 116-260) requiring an OIG audit 

within the first year of the program. The overall objective of the audit was to determine if the FCC 

implemented the ACP in accordance with the requirements of the Infrastructure Act. 

Kearney found that the FCC made significant progress during the scope period covered by the audit. 

However, improvements were needed. In the attached audit report, dated January 22, 2024, Kearney

noted five findings and 12 recommendations. A summary of each finding is provided below. 
• The FCC did not establish specific performance targets to evaluate its performance 

against its goals, nor did the FCC’s Agency Performance Report clearly reflect how well 

the FCC is progressing towards achieving its ACP performance (Finding 1). 

• USAC did not have effective controls in place to ensure that manual reviews of 

subscriber eligibility documents resulted in correct subscriber eligibility decisions

(Finding 2). 

• The FCC did not publish a report on participating providers compliance, as required by 

the Infrastructure Act, nor did it create a policy and procedures document outlining the 

procedures used for identifying and reporting ACP complaints (Finding 3). 

• The FCC and USAC do not have an effective process for determining if providers are 

maintaining proper documentation supporting reimbursement claims (Finding 4). 

• Although the FCC established its grant program in January 2022, most grant awards 

were not accepted until May or June 2023, when nearly half of ACP funds (48%) were 

expended, making the grant program less impactful to communities in need. 

Additionally, FCC’s outreach efforts could have been more effective in targeting 

consumers in need by conducting consumer research and focus groups at the time of 

program implementation. Finally, Kearney was unable to assess the effectiveness of the 

FCC’s grant outreach because the grants were awarded after the scope period of the audit 

(Finding 5). 

The FCC generally concurred on the audit findings, except for Finding 4 where the FCC disagreed 

with Kearney’s treatment of test samples that were unsupported at the conclusion of audit 

fieldwork due to a lack of response from two service providers. In response, Kearney affirmed 

that the audit report reflected conclusions based on the evidence received, and that the context of 

the finding as presented in the report was factual and accurate. 

Kearney is wholly responsible for the attached audit report and the conclusions expressed 

therein. OIG monitored Kearney’s performance throughout the audit and reviewed Kearney’s

audit report and the related audit documentation. Our review disclosed no instances where 

Kearney did not comply in all material respects with generally accepted government auditing 

standards. 

Questions regarding this report may be directed to Sophie Jones, Assistant Inspector General for 

Audit, at (202) 418-1655 or sophila.jones@fcc.gov, or Menjie Medina, Deputy Assistant Inspector 

General for Audit, at (202) 418-0949 or menjie.medina@fcc.gov. 

Attachment

cc: Managing Director 

Chief of Staff

Chief Financial Officer