SEMIANNUAL REPORT 

APRIL 1, 2023 – SEPTEMBER 30, 2023

FEDERAL COMMUNICATIONS COMMISSION

OFFICE OF INSPECTOR GENERAL
FCC OIG—Semiannual Report to Congress 1 4/1/23 – 9/30/23

FROM THE ACTING INSPECTOR GENERAL

I am pleased to present the Federal Communications Commission’s Office of Inspector 

General’s (OIG) Semiannual Report to Congress for the six months ending September

30, 2023. In accordance with Inspector General Act, as amended, 5 U.S.C. § 405, this 

report summarizes the activities and accomplishments of OIG. The report describes 

audit work and investigations we have completed during the preceding six months, as 

well as those in process. Where appropriate, reports of completed audits and 

investigations have been forwarded to the Commission's management for action and 

are posted to the OIG website. 

OIG is committed to promoting transparency and conducting aggressive oversight of the 

long-standing Universal Service Fund programs as well as the more than $10 billion in 

Federal Communications Commission pandemic response funding included in the 

American Rescue Plan Act of 2021, the Coronavirus Aid, Relief, and Economic Security 

Act, other pandemic response legislation, as well as the Infrastructure Investment and 

Jobs Act. We work to ensure that (1) funds for assistance are timely, effectively 

distributed, and used appropriately; (2) adequate and proper internal control procedures 

are in place; (3) program participants meet eligibility guidelines and comply with 

program requirements; and (4) offices establish effective compliance operations. 

The Investigations staff continues to address external threats to the integrity of the 

programs while also working proactively on agency processes to deter and detect fraud, 

waste, and abuse. Our audits of Federal Communications Commission’s programs and 

operations continue to promote effectiveness, efficiency, and integrity both internally 

and externally.

We thank the Offices of Inspector General of other federal agencies, the Department of 

Justice, the Federal Bureau of Investigation, senior officials throughout the Commission, 

and members of Congress and their staffs for their support of our work and for their 

receptiveness to our recommendations to improve Federal Communications 

Commission programs and operations. OIG remains committed to maintaining the 

highest possible standards of professionalism and quality in its audits, investigations, 

inspections, and consultations. We welcome your comments, suggestions, and 

questions.

 Sharon R. Diskin 

 Acting Inspector General
FCC OIG—Semiannual Report to Congress 2 4/1/23 – 9/30/23

TABLE OF CONTENTS

FROM THE ACTING INSPECTOR GENERAL..................................................................1

ABBREVIATIONS & ACRONYMS.........................................................................................3

INTRODUCTION.........................................................................................................................5

OFFICE OF MANAGEMENT...................................................................................................8

Office Staffing ...............................................................................................................................8

Legislative and Policy Matters.................................................................................................9

OFFICE OF INVESTIGATIONS............................................................................................10

OFFICE OF AUDIT...................................................................................................................26

Financial, and Program Audit Division ................................................................................27

Completed FPAD Projects......................................................................................................27

In-Process FPAD Audits ..........................................................................................................28

IT Program Audit Division .......................................................................................................29

Completed IPAD Project..........................................................................................................30

In-Process IPAD Audits and Other Projects ......................................................................30

REPORTING REQUIREMENTS ..........................................................................................32

APPENDIX A1............................................................................................................................37

APPENDIX A2............................................................................................................................38

APPENDIX B ..............................................................................................................................43

APPENDIX C..............................................................................................................................45
FCC OIG—Semiannual Report to Congress 3 4/1/23 – 9/30/23

ABBREVIATIONS & ACRONYMS

ACP Affordable Connectivity Program

AIG Assistant Inspector General 

ARPA American Rescue Plan Act 

BQP Benefit Qualifying Person 

CAF Connect America Fund

CAA Consolidated Appropriations Act

CARES Coronavirus Aid, Relief, and Economic Security

CGB Consumer & Governmental Affairs Bureau

CIGIE Council of the Inspectors General on Integrity and Efficiency

DFE Designated Federal Entity

DOE Department of Education 

DOJ Department of Justice

E-Rate Schools and Libraries Program

ED OIG Department of Education Office of Inspector General

ETC Eligible Telecommunications Carriers 

EBB Emergency Broadband Benefit

ECF Emergency Connectivity Fund

EXIM Export-Import Bank of the United States

FBI Federal Bureau of Investigation

FCA Federal False Claims Act

FCC Federal Communications Commission

FISMA Federal Information Security Modernization Act of 2014

FLETC Federal Law Enforcement Training Center

FPAD Financial and Program Audit Division

FY Fiscal Year

GAO Government Accountability Office

HUBB High Cost Universal Broadband

IPA Independent Public Accountant

IG Inspector General

IPAD IT and Program Audit Division

IP-CTS Internet Protocol Captioned Telephone Service

IT Information Technology

Kearney Kearney and Company, P.C. 

MOU Memorandum of Understanding

NARA National Archives and Records Administration

NLAD National Lifeline Accountability Database

NPRM Notice of Proposed Rulemaking

OA Office of Audit

OGC Office of General Counsel

OIG Office of Inspector General 

OI Office of Investigation

OMB Office of Management and Budget
FCC OIG—Semiannual Report to Congress 4 4/1/23 – 9/30/23

OMD Office of Managing Director

PBGC Pension Benefits Guaranty Corporation 

PII Personal Identifiable Information

PIIA Payment Integrity Information Act

PN Public Notice

QPAD Quality Assurance, Policy and Audit Division

RHC Rural Health Care 

SAR Semiannual Report to Congress

TRS Telecommunications Relay Services

TPIV Third-Party Identity Verification

USAC Universal Service Administrative Company 

USF Universal Service Fund

USPIS U.S. Postal Inspection Service

WCB Wireline Competition Bureau
FCC OIG—Semiannual Report to Congress 5 4/1/23 – 9/30/23

INTRODUCTION

The Federal Communications Commission (FCC or the Commission) is an independent 

regulatory agency, established by Congress to regulate interstate and foreign 

communications by radio, television, wire, satellite, and cable. The FCC’s jurisdiction 

covers the fifty states, the District of Columbia, the Commonwealth of Puerto Rico, and 

all U.S. territories.

The Commission is composed of five members who are appointed by the President and 

subject to confirmation by the Senate. Normally, one Commissioner is appointed or 

reappointed each year, for a term of five years. One of the members of the Commission 

is designated by the President to serve as Chair of the Commission. Jessica 

Rosenworcel currently serves as Chairwoman. Brendan Carr, Geoffrey Starks, Nathan 

Simington, and Anna Gomez currently serve as Commissioners. Most of the FCC's 

employees are located at the FCC’s Headquarters at 45 L Street NE, Washington, DC. 

Field offices are located throughout the United States.

The Office of Inspector General (OIG) is dedicated to ensuring compliance with the 

requirements of the Inspector General Act of 1978, as amended (IG Act), and to assist 

the Commission in its continuing efforts to improve operational and program 

effectiveness and efficiency. The OIG is headed by Acting Inspector General 

Sharon R. Diskin while awaiting Senate confirmation of a permanent Inspector 

General. The principal assistants to the Acting Inspector General are:

Eric Phelps, Acting Counsel to the Acting IG 

Hillary Burchuk, Acting AIG for Investigations 

Sophila Jones, AIG for Audit

Johnny Drake, AIG for Management

In this Semiannual Report to Congress (SAR), we discuss OIG’s accomplishments and 

activities from April 1, 2023, through September 30, 2023, as well as our goals and 

plans.

During this period, OIG focused a significant portion of our effort overseeing and 

monitoring the Universal Service Fund (USF) programs, which are administered by the 

Universal Service Administration Company (USAC) on behalf of the FCC, and on the 

newer subsidy programs established by Congress related to COVID-19 Pandemic relief 

programs and the Infrastructure Investment and Jobs Act (Infrastructure Act). Because 

the newer programs used existing USF program infrastructure, USAC also administers 

the FCC’s COVID-19 Pandemic programs. The following provides an overview of the 

USF and the related pandemic and economic relief programs:

The High-Cost Fund provides support to certain qualifying telecommunications carriers 

serving high-cost (primarily rural) areas. Telecommunications carriers receiving support 
FCC OIG—Semiannual Report to Congress 6 4/1/23 – 9/30/23

must offer services to rural area consumers at rates reasonably comparable to the rates 

for services offered in urban areas. The Connect American Fund (CAF) was designed to 

transition the program away from its predecessor, the High-Cost Fund, which provided 

voice-only telephone service, to providing multi-purpose networks capable of offering 

broadband Internet access. Disbursements for the High-Cost Program, including legacy 

High-Cost Program and CAF support, totaled $4.2 billion in calendar year 2022.

1

The Schools and Libraries Program, also known as “E-Rate,” provides support to 

eligible schools and libraries in every U.S. state and territory to help fund 

telecommunication services, Internet access, and internal connections. In E-rate funding 

year 2022, USAC processed over 35,400 applications from schools and libraries 

seeking over $3.08 billion in E-rate support to over 128,500 schools and libraries. In 

calendar year 2022, USAC authorized disbursement of over $2.083 billion in E-rate 

support, with over 130,000 schools and libraries receiving support. 

As part of the American Rescue Plan Act of 2021, Congress authorized the Emergency 

Connectivity Fund (ECF), a $7.17 billion program to help schools and libraries provide 

the tools and services their communities needed for remote learning during the COVID19 emergency period. For eligible schools and libraries, the ECF Program covers 

reasonable costs of laptop and tablet computers, Wi-Fi hotspots, modems, routers, and 

broadband connectivity purchases for off-campus use by students, school staff, and 

library patrons. Since ECF’s June 2021 launch, the Commission has committed nearly

$7 billion in funding to support approximately 11,220 schools, 1,050 libraries and 120 

consortia, and provided nearly 13 million connected devices and over 8 million 

broadband connections. To date, the funding has provided support to approximately 18 

million students.

The Lifeline Program provides support to eligible telecommunications carriers that, in 

turn, offer discounts on telecommunications services to eligible consumers. In 2022, 

Lifeline support was approved for disbursement totaling more than $609 million.

The Consolidated Appropriations Act of 2021 (CAA) established the Emergency 

Broadband Benefit (EBB) Fund, which provided $3.2 billion to the FCC to help lowincome households pay for broadband service and connected internet devices, as part 

of a response to the COVID-19 emergency. The EBB Program provided a discount of 

up to $50 per month for broadband service for eligible customers. The EBB Program 

was intended to be a temporary response to the pandemic emergency. However, in the 

Infrastructure Act, Congress appropriated money for a long-term program subsidy 

program known as the Affordable Connectivity Program (ACP). The ACP is a $14 billion 

benefit program intended to ensure households can afford the broadband they need for 

work, school, healthcare and more. This program provides a discount of up to $30 per 

month toward internet service for eligible households and up to $75 per month for 

1 FCC OIG provides the updated annual data in the March Semiannual Reports to Congress.
FCC OIG—Semiannual Report to Congress 7 4/1/23 – 9/30/23

households on qualifying Tribal lands. More than 17 million households have enrolled in 

the ACP. 

The Rural Health Care (RHC) Program provides support to eligible rural health care 

providers who qualify for reduced rates for telecommunications and broadband 

services. This support subsidizes their access to these services, making telehealth 

services affordable in rural areas. Demand for RHC Program funding has continued to 

be high. The RHC Program approved disbursements totaled more than $496 million 

with over 12,238 participating health care providers receiving commitments in 2022. 

The COVID-19 Telehealth Program provided funding to eligible health care providers 

responding to the COVID-19 pandemic to support telecommunications services, 

information services, and connected devices needed to provide critical connected care. 

This program was established in the Coronavirus Aid, Relief, and Economic Security 

(CARES Act), providing $200 million in funding. The CAA provided an additional 

$249.95 million to fund a second round of the COVID-19 Telehealth Program. A 

resolution terminating the national emergency was signed by President Biden on April 

10, 2023, and thus the emergency period for purposes of the COVID 19 Telehealth 

Program has also ended. Therefore, the Program may only reimburse eligible telehealth 

expenses incurred by healthcare providers from March 13, 2020 through April 10, 2023. 

These eligible expenses must be submitted for reimbursement by October 31, 2023. 

OIG is also responsible for oversight of USF receipts collected from telecommunications 

providers offering international and interstate telecommunications services. Those 

telecommunications providers are collectively referred to as contributors. More than 

3,600 contributors submitted total USF contributions of approximately $7.38 billion in 

2022.
FCC OIG—Semiannual Report to Congress 8 4/1/23 – 9/30/23

OFFICE OF MANAGEMENT

Office Staffing

Our office consists of 47 experienced professional and administrative staff comprised of 

auditors, investigative attorneys, data analysts, administrative management specialists, 

program and management analysts, a paralegal, an investigative analyst, an industry 

economist, an information technology (IT) specialist, a computer forensics investigator, 

a budget officer, and a writer/editor. 

Continuous training and education increase the expertise of all staff and satisfy the 

training requirements mandated by various professional organizations. The staff 

attended and completed courses sponsored by government agencies, including the 

Government Accountability Office (GAO), Council of Inspectors General on Integrity and 

Efficiency (CIGIE), the National Defense University, and the Federal Law Enforcement 

Training Center (FLETC); and professional organizations and other training vendors, 

such as the American Institute of Certified Public Accountants, Institute of Internal 

Auditors, Association of Governmental Accountants, Association of Certified Fraud 

Examiners, Information Systems Audit and Control Association, Management Concepts, 

National Association of State Auditors, Controllers and Treasurers, and the Graduate 

School USA.

Changes and Improvements

Remote Work Environment

Staff have been primarily working remotely for more than three years. During this SAR 

period, staff have returned to in-person work at least two days per pay period, with an 

emphasis placed on weekly community days whereby all investigations and audit staff 

return to the office on the same day to promote collaboration. Technological solutions 

continue to effectively facilitate all aspects of OIG’s telework and the commitment of the 

staff has enabled the office to seamlessly integrate new hires while remaining 

substantially in a teleworking environment. Moving out of the pandemic emergency, 

investigative staff is again fully engaged in robust travel, permitting us to have “boots on 

the ground” to engage fully with our law enforcement partners throughout the country, 

as well as conduct independent investigatory work. 

Secure Office Space for OIG

As reported in the last SAR, although the COVID-19 pandemic impeded access to the 

new headquarters, once we entered the facility the lack of secure space for 

investigation staff raised concerns. Secure space is fundamental and integral to 

conducting OIG investigations. OIG investigates not only waste, fraud, and abuse but 

also potential violations of law. Appropriate targets of OIG investigations include 
FCC OIG—Semiannual Report to Congress 9 4/1/23 – 9/30/23

Commission staff. OIG personnel need to conduct sensitive discussions and analyze 

evidence and data without fear or concern that Commission staff or others 

unnecessarily or inappropriately enter OIG space. OIG’s lack of secure space in the 

building disrupts and compromises our mission as our work concerning sensitive law 

enforcement matters, and often material governed by 18 USC Sec 6(e), must be 

conducted in an environment that guarantees the confidentiality of our work. This work 

includes, but is not limited to, conducting interviews as part of covert criminal 

investigations or False Claims Act (FCA) suits, with or without the assistance of Federal 

Bureau of Investigation (FBI) agents and Department of Justice (DOJ) prosecutors; 

examining sensitive documents; conducting data analytics and forensic examinations; 

and participating in confidential intra-office meetings. Our concerns are shared by CIGIE 

and broader groups of inspectors general. 

Significantly, within the perimeter of OIG space are several common meeting spaces 

that anyone in the agency may reserve, thus inviting FCC personnel as well as outside 

visitors directly into our space. In one example, a conference room is adjacent to two 

OIG-desginated cubicles that will be occupied by OIG staff engaged in sensitive and 

work of the office. 

Our office is well within its authority to ask the FCC to provide secure space, i.e., to 

erect walls and other barriers necessary to restrict access to our space. However, at 

this time, we have asked only that the FCC adopt a pragmatic approach; we proposed a 

few low-cost, practical solutions to our space concerns, including door locks to which 

only OIG personnel would have access. Yet, because the FCC has continually identified 

problems with our suggested remedies, rather than provide workable solutions, 

providing us only temporary exclusive access to the common meeting room spaces, we 

are led to question the FCC’s commitment to resolving our space concerns. 

Legislative and Policy Matters

Pursuant to 5 U.S.C. § 404(a)(2) OIG monitors and reviews existing and proposed 

legislation and regulatory proposals for their potential impact on OIG and the FCC’s 

programs and operations. We perform this activity to evaluate legislative potential for 

encouraging economy and efficiency, while helping to reduce fraud, waste, abuse, and 

mismanagement.

Tasked with supporting efforts to prevent and detect fraud, waste, abuse, and 

mismanagement and to mitigate major risks that cut across program and agency 

boundaries, OIG is committed to promoting transparency and conducting aggressive 

oversight of the Universal Service programs and other subsidy programs. During the 

reporting period, we continued to share updated recommendations to prevent and 

detect fraud, waste, and abuse with Commission and USAC staff. 
FCC OIG—Semiannual Report to Congress 10 4/1/23 – 9/30/23

OFFICE OF INVESTIGATIONS

The work of the OIG Office of Investigations (OI) covers a wide range of topics touching 

on myriad aspects of the FCC’s mission and programs. Most significantly, our 

investigations often address allegations of criminal misconduct or civil fraud in the 

Commission’s telecommunications subsidy programs. We deal with complex 

investigations, large criminal conspiracies, and matters involving complex financial 

transactions throughout the United States and its territories. These difficult and wideranging cases often require substantial investigative expertise and resources, including 

personnel on the ground across several states, or high-grade forensic tools and the 

expertise to use them. In these cases, we have always received, and are grateful for, 

the assistance of other agencies, especially the Offices of Inspector General of other 

federal agencies, the DOJ, and the FBI.

OI receives and investigates complaints regarding the manner in which the FCC 

executes its programs, how it handles its operations administratively, and how the FCC 

conducts its oversight responsibilities. Allegations come from a variety of sources 

including FCC managers and employees, contractors, program stakeholders, Congress, 

and the public at large. Whistleblower requests for anonymity are honored, except when 

identification is needed for law enforcement purposes. Allegations may also be referred 

by OIG auditors.

In addition to investigations regarding Commission programs, OI investigates 

allegations of improper employee and contractor activity implicating federal statutes or 

regulations establishing standards of conduct and procedure. 

While we have made recent additions to our staff, OI, like most government offices, has 

an ever-increasing volume of work and limited resources. Thus, matters having the 

potential to significantly impact federal funds, important FCC missions or programs, or 

the basic integrity and workings of the agency receive the highest priority for 

investigation and assignment of resources.

Statutory Law Enforcement Authority

OIG has sought to hire federal criminal investigators (1811s) for a decade. OI is staffed 

primarily by investigative attorneys. OI’s investigative attorneys assess complaints, 

collect and analyze evidence, direct data analyses, interview witnesses, and make 

criminal and civil referrals to the U.S. DOJ. OI’s lack of on-staff 1811s significantly 

encumbers our ability to fulfill the mission of the office.

As noted, OI’s investigative attorneys routinely conduct in-person interviews of 

witnesses, potential targets, and targets (collectively, interview subjects). These 
FCC OIG—Semiannual Report to Congress 11 4/1/23 – 9/30/23

interviews are frequently unscheduled and often occur at unsecure locations including 

office buildings, coffee shops, and personal residences. To mitigate safety risks, OI 

investigative attorneys conduct higher risk interviews only when an armed agent is 

available to assist. Many interview subjects, including some who have criminal records, 

present a safety risk to untrained, unarmed OIG staff. In addition, 1811s also receive 

specialized investigative training that would significantly enhance OIG’s ability to 

accomplish its mission, including covert and surveillance operations, and evidence and 

intelligence gathering.

Accordingly, OIG must rely upon the trained special agents and law enforcement 

authority of other agencies, including the FBI, the Department of Education Office of 

Inspector General (ED OIG), and the U.S. Postal Inspection Service (USPIS) to conduct 

many interviews. While these law enforcement agencies have generously supported 

many OIG investigations, each has their own distinct mission to fulfill and resource 

constraints, and such partners are not always available to assist our office. 

We have repeatedly, over many years, attempted to persuade the FCC to allow our 

office to post vacancy announcements and hire 1811s, most recently in 2022. While the 

FCC states that “it is willing to do what it can to facilitate OIG hiring,” it has requested 

that OIG first enter into a memorandum of understanding (MOU) regarding various 

hiring issues including position classification, qualification determination, and pay 

setting. The FCC also stated that its HR staff lacks the expertise required to hire 1811s.

The FCC’s HR has well-handled OIG hiring and has worked with our office on position 

classifications, qualification determinations and other hiring questions for decades.

Thus, if there are gaps in FCC’s HR expertise concerning 1811 hiring, we stand ready 

to procure the missing expertise. Moreover, OIG recently provided specific answers and 

took measures to address perceived administrative hurdles identified by the agency. 

Notably, many designated federal entities (DFE) and establishment OIGs throughout 

the government have on-staff 1811s to support their missions—those federal agencies 

routinely hire and manage 1811s in the normal course of operations.

In the most recent exchange with the agency on this matter, the FCC has proposed to 

work with us “to develop a written outline for such an MOU,” not an actual MOU. By the 

FCC’s timeline, we are still years away from hiring 1811s. In the meantime, criminals 

remain unprosecuted and threats to FCC programs, which disburse billions of dollars 

annually, go undeterred. 

Following is a small sample of FCC investigations that were negatively impacted by a 

lack of 1811s:

➢ In January 2023, OIG received credible information from a law enforcement 

partner that a sales agent who works for an ACP provider is stealing personal 

identifiable information (PII) to enroll unsuspecting Medicaid recipients into the 
FCC OIG—Semiannual Report to Congress 12 4/1/23 – 9/30/23

ACP. Moreover, the law enforcement partner shared compelling evidence that 

the sales agent, who may be involved in gang-related activity, was selling tablets 

provisioned with ACP-subsidized service on the street for several hundred dollars 

each. We have received several similar tips regarding other sales agents around 

the country suspected of stealing low-income consumer PII and selling ACPsubsidized devices on the street from whistleblowers and other law enforcement 

agencies over the past year.

➢ OIG recently concluded a near decade-long investigation into E-Rate fraud 

involving tens of millions of dollars committed by schools and vendors in New 

York. The investigation resulted in guilty pleas by seven individuals who must 

now pay millions in restitution and fines. The challenges faced by OIG during this 

investigation demonstrate our need for trained 1811s. During the investigation, 

the FBI reported multiple incidents of physical harassment by individuals at some 

of the schools under investigation. It was unsafe for OIG investigators to attempt 

to conduct interviews or site visits at the schools without armed agents. FBI 

agents ensured the safety of OIG’s investigative attorneys. Second, OIG 

depended on the FBI and other special agents to execute multiple search 

warrants to gather evidence that the schools had not received the millions of 

dollars of equipment funded by the E-Rate program. Absent FBI and other 1811 

assistance, these search warrants would not have been possible and valuable 

evidence used in the subsequent criminal prosecutions would have remained 

uncollected. Simply put, OIG’s investigation was not possible without 1811 

support.

➢ During an ongoing investigation targeting an ACP provider, the government team 

determined that conducting a covert intelligence-gathering operation is necessary 

to collect essential evidence. All OIG’s investigative attorneys are prevented by 

ethics rules from using a false identity to obtain evidence of potential criminal 

conduct. As a result, OIG must rely on the USPIS to conduct the covert 

operation. It has taken months to get approval for the operation while 

government losses multiply.

Upon request, we will provide additional examples of cases adversely impacted by our 

lack of on-staff 1811s. 

Additionally, due to the lengthy delay in seeking 1811 hiring, one of OI’s investigative 

attorneys left OIG for private practice. This attorney, who had commenced the Basic 

Criminal Investigator Training Program before its cancellation as a result of the COVID19 pandemic, would have been an ideal candidate for hiring as an 1811 given his nearly 

10 years of USF investigative experience. This attorney indicated the continuing 

problems with hiring 1811s was a primary reason for his leaving government. A second 

investigative attorney in OIG who would have been a second ideal candidate, has 

reached the maximum age limit for hiring as an 1811 (despite having military experience 
FCC OIG—Semiannual Report to Congress 13 4/1/23 – 9/30/23

and the possibility of an age waiver). The continuing delays by the agency are thus 

having direct negative ramifications beyond just limiting OI’s ability to utilize its statutory 

law enforcement authority.

We continue to believe this matter is vitally important and thus pursued it aggressively in 

this SAR period by raising the issue in a bi-partisan, bi-cameral meeting with 

Congressional oversight staff, as well as with the Office of Management and Budget

(OMB). 

Activity During This Period 

Cases pending as of March 31, 2023.................................. 55

New Cases...................................................................... 7

Cases Closed.....................................................................7

Cases pending as of September 30, 2023.................................55

These numbers do not include preliminary reviews of allegations, from the Hotline or 

other sources, or matters involving minimal analysis of the allegations or evidence.

Significant Activities

Several of the Office’s significant activities are described below. However, we discuss 

investigations only when and if information may be made public without negative impact 

on law enforcement activities, including criminal prosecutions, and without divulging 

investigative techniques. Thus, many matters could not be considered for inclusion in 

this summary. During this reporting period, we have been working on numerous 

investigations upon which we cannot report, including matters before a Grand Jury and 

qui tam lawsuits under seal. 

Investigations into Fraud in FCC Subsidy Programs 

The bulk of OI’s work involves investigating and supporting civil and criminal 

investigations and prosecutions of fraud in the FCC subsidy programs. The Assistant 

Inspector General for Investigation and investigations staff routinely work with other 

state, local and federal agencies on these matters. These coordinated investigatory and 

prosecutorial efforts, especially those involving DOJ, ED OIG, and various U.S. 

Attorneys, have resulted in many successes, including civil settlements and criminal 

convictions.

Most of our ongoing investigations are not known to the public and even some closed 

investigations cannot be disclosed because of sensitivities that could impact related 

ongoing matters. Specifically, the OI is engaged in multiple, ongoing, large-scale 

investigations, as well as qui tam lawsuits under seal, seeking damages pursuant to the 
FCC OIG—Semiannual Report to Congress 14 4/1/23 – 9/30/23

FCA. We hope to share details about these matters in the near future. We have, 

however, begun to disseminate information that can be made publicly available more 

widely, with the expectation that details of our work will serve as a deterrence against 

future fraud. In addition to OIG posting news releases on the FCC OIG’s webpage and 

on our social media sites, in response to OI’s request, USAC has also been posting OI 

headlines, such as press releases and other significant items, to USAC’s website.

Highlighted below are a few matters where public developments occurred during the 

reporting period:

Lifeline, Emergency Broadband Benefit Program and Affordable 

Connectivity Program

Proactive Work

Update on ACP Transfer Abuse

As reported in the last SAR, in March 2023, OI briefed the Wireline Competition and 

Enforcement Bureaus regarding a pattern of unauthorized and abusive transfers of 

subscribers’ ACP service benefits including transfer exception abuses. OI 

recommended changes to the ACP transfer process and recommended the 

Commission consider suspending and removing the provider that was worst offender. 

Since that briefing, the Wireline Competition Bureau (WCB) worked with USAC to 

address these concerns. 

USAC suspended ACP payments to the worst offending provider, revoked the 

provider’s API access to National Lifeline Accountability Database (NLAD), and locked 

out all of its agents in the Representative Accountability Database (RAD), effectively 

preventing it from making new enrollments in NLAD. USAC also completed a Payment 

Integrity Assurance (PIA) review of the worst offending provider and, in Aug 2023, 

started the process of recovering $1.7 million in overpayments. The PIA process also 

identified other problems with the provider’s procedures, including its procedures for 

addressing subscriber non-usage.

In April and May 2023, USAC reviewed agent overuse of transfer exceptions and locked 

31 agents out of RAD for transfer-related misconduct.

USAC also reviewed the use of transfer exceptions by 26 other ACP providers. USAC’s 

review identified high failure rates among the providers’ sampled documents. Although 

USAC completed its review, USAC is still working on its responses including: seeking 

recovery from the providers; requiring providers to attempt to cure noncompliance; 

making referrals back to the Commission for providers with high failure rates; and 
FCC OIG—Semiannual Report to Congress 15 4/1/23 – 9/30/23

conducting outreach and guidance to promote increased compliance with the rules for 

transfers and transfer exceptions. 

USAC also made changes to NLAD to mitigate the transfer abuse. In September 2023, 

USAC announced it would begin requiring all providers to submit the date and time it 

collects a consumer’s consent to be transferred with each transfer transaction in NLAD. 

USAC also removed one of the transfer exception codes that was being misused by 

providers. 

OI Advisory Regarding ACP Provider Noncompliance with Program Usage & DeEnrollment Rules

On September 28, 2023, OI issued an advisory to describe its growing concern that 

data and other evidence strongly suggest dozens of participating mobile broadband 

providers are not complying with ACP usage and de-enrollment requirements. OI’s 

concern originated from a recent OI investigation of an ACP provider that improperly 

claimed $44.5 million in program funds on behalf of subscribers who were not using 

their ACP service. Subsequent OI work further deepened this concern.

De-enrollments for non-usage typically comprise about half of de-enrollments by large 

mobile broadband ACP providers. However, OI analyses showed that dozens of 

participating mobile broadband providers de-enrolled few, if any, ACP subscribers for 

non-usage and claimed reimbursement for all or nearly all their ACP subscribers. In 

some instances, these suspect providers de-enrolled less than one percent of the 

subscribers that many similarly-sized ACP providers de-enrolled for non-usage. 

Extensive experience with the Lifeline program and ACP and comparisons with other 

ACP providers suggest these suspect providers are likely noncompliant with ACP usage 

and related de-enrollment rules as well as other program rules.

OI encouraged all providers to reconfirm compliance with program usage monitoring 

and de-enrollment requirements, and to repay any improperly received program funds 

received as a result of noncompliance. Moreover, OI encouraged the Commission to 

address its failure to require providers to report some objective measure of individual 

subscriber usage prior to disbursing program funds. As reflected in previous SARs, OI 

repeatedly recommended the Commission ask for proof ACP service is truly benefitting 

low-income households enrolled in the program. 

OI previously issued an advisory concerning compliance with Lifeline usage 

requirements in January 2020. 
FCC OIG—Semiannual Report to Congress 16 4/1/23 – 9/30/23

OI Recommendations Regarding the ACP Sixth Report and Order Recommendations

On July 13, 2023, the FCC issued a draft ACP Sixth Report and Order (Draft Order) 

regarding its proposed plans to implement an enhanced ACP benefit for providers who 

serve ACP households in qualifying high-cost areas as required by the Infrastructure 

Act.2 Specifically, the Infrastructure Act requires the Commission to permit ACP 

providers to offer a high-cost area benefit of up to $45 per month in addition to the 

standard up-to-$30 per month ACP benefit, for a total of up to $75, where the provider 

demonstrates that a particularized economic hardship may leave it unable to maintain 

the operation of all or a part of its broadband network. 

Based on extensive investigative experience and lessons learned from the USF HighCost Program, OI provided a number of significant recommendations, many (but not all) 

of which were subsequently adopted by the Commission in its final version of the ACP 

Sixth Report and Order on August 3, 2023 (Final Order).

3

Among the requested recommendations, OI advised the Commission:

(i) The Draft Order did not include adequate standards to govern how much of the “upto-$75 monthly benefit” a provider could claim, i.e., particularized hardship, because the 

Draft Order failed to define the magnitude of a provider’s loss necessary to demonstrate 

a provider was unable to cover network maintenance costs. Congress clearly intended 

that some providers receive less than the full subsidy. This is important because a 

facilities-based provider receiving the standard $30 per month ACP subsidy, for 

example, may be able to maintain its plant and provide broadband service with only $20 

more dollars per subscriber, rather than receiving the full additional $45 subsidy. 

Absent strong safeguards and identifiable criteria governing how much could be claimed 

for support, an operator seeking to manipulate its income statement to ensure a loss on 

its books in the high cost areas it served could easily do so, much like a cost-of service 

company claiming for High Cost support, particularly when the Draft Order did not 

require operators to provide an audited income statement if they did not normally 

commission one. Potentially, a massive waste of government resources could result, 

and a provider could receive more support than was necessary to make up the short fall 

in needed funds. 

The Final Order accepted OI’s recommendation to more clearly define the elements of 

particularized economic hardship by requiring providers to submit more detailed 

operating cost and revenue information in the high-cost area(s) where the provider 

sought the benefit. The Final Order, however, did not explain how USAC would 

2 See https://docs.fcc.gov/public/attachments/DOC-395112A1.pdf

3 See https://docs.fcc.gov/public/attachments/FCC-23-62A1.pdf
FCC OIG—Semiannual Report to Congress 17 4/1/23 – 9/30/23

determine what proportion of the supplemental $45 per subscriber subsidy a provider 

would be awarded based on its submission. 

(ii) The Draft Order failed to articulate fully and codify in the rules the elements of the 

showing required to support a provider’s request to offer the high-cost area benefit, 

including requirements for an income statement. OI recommended the Commission 

provide further guidance on income statements to prohibit providers from manipulating 

their income statements and selectively choosing among accounting principles to create 

income statements that meet the “economic hardship” criteria; if income statements for 

high-cost areas were created in the normal course of business, OI advised that the 

applicant should be required to submit those income statements. Regardless of whether 

providers create income statements specifically targeting high-cost areas in the normal 

course of business, OI recommended that providers’ income statements should utilize 

(1) Generally Accepted Accounting Principles and (2) the same accounting principles 

the provider uses in its normal course of business in other income statements, such as 

those filed with the Securities and Exchange Commission or distributed to owners and 

shareholders. OI also recommended the Commission require the submission of 

consolidated and component-level income statements along with tax filings to support 

those statements. 

The Commission adopted these recommendations in the Final Order.

(iii) OI recommended that an income statement must, at a minimum, include detailed 

information on the provider’s net income, operating revenue and operating expenses, 

including, but not necessarily limited to, cost of goods sold or services, general and 

administrative expenses and depreciation or amortization expenses. Moreover, every 

applicant should be required to submit an audited income statement with its application. 

Audited income statements are the most useful and convincing form of evidence to 

promote program integrity and deter fraud. 

Although the Commission did not follow OI’s recommendation to require every applicant 

to submit to an audited financial statement, the Final Order required providers that are 

publicly traded or that prepare audited income statements in the ordinary course of 

business, to submit the audited income statement, rather than an unaudited income 

statement, in support of their certification. 

(iv) The Draft Order failed to require that a corporate office certify the provider’s request 

for approval of the high cost benefit. Such certifications improve the ability of the 

Government to enforce and prosecute violations and fraud in the program. 

The Final Order included the requirement for such a certification. 
FCC OIG—Semiannual Report to Congress 18 4/1/23 – 9/30/23

(v) The Draft Order did not require applicants to submit documentation that 

demonstrated they met the definition of facilities-based provider in 47 CFR § 

1.7001(2)(i)-(v). OI advised that this basic requirement for enhanced support should be 

verified before approval.

The Final Order was strengthened to include this recommendation.

(vi) The Draft Order did not provide adequate safeguards to prevent providers from 

manipulating their cost data to obtain the supplementary benefit. As many providers are 

likely to provide ACP service both in areas that are eligible for High Cost support and in 

other places where only the regular ACP benefit would be available, or to utilize 

affiliates to provide services, it was important that the rules prevent providers from cost 

shifting and cherry-picking that would allow providers to manipulate their costs to qualify 

for the generous high-cost ACP benefit. The Draft Order proposed an allocation 

methodology that OIG deemed insufficient because it was more permissive than the 

rules in place for High Cost distributions of USF monies to rate-of-return ILECs in the 

High Cost program. Additionally, if required conduct was not specifically prescribed in 

applicable FCC rules and the rules were found to be ambiguous, obtaining a 

prosecution for wrongdoing, for even the most egregious cost-shifting practice, could be 

difficult.

The Final Order strengthened the requirement that applicants explain their allocation 

methodology; a participating provider must first attempt to directly assign or attribute 

costs to broadband Internet access services, and if that is not possible, must use a costcausative mechanism to the extent possible. If neither is possible, the participating 

provider must employ a reasonable cost-allocation with a justification for its 

methodology. 

(vii) The Draft Order did not include the guidance USAC will receive from WCB and the 

Office of Economic Analysis regarding how to evaluate and approve applications. OIG 

recommended it be included. Absent such guidance, OI could not determine whether 

the USAC approval processes sufficiently guarded against fraud, waste and abuse. The 

Commission’s failure to issue such guidance which providers will want to examine to 

increase the likelihood their submissions are approved, could also lead some providers 

to adopt approaches in their submissions that tolerate waste or abuse. 

The Final Order did not include this recommendation. 

(viii) OI also recommended that a participating provider indicate in its application for 

ACP high-cost support whether it previously applied for financial assistance in the three 
FCC OIG—Semiannual Report to Congress 19 4/1/23 – 9/30/23

fiscal years prior to the applicant’s claims, and upon request, submit to USAC or the 

Commission applications for loans submitted to the Rural Utility Service (RUS) or any 

financial institution, approvals or denials of such loans, the provider’s RUS Operating 

Report for Telecommunications Borrowers filed with the RUS, and any financial reports 

filed with a state Public Utility Commission, as applicable. The requirement to submit 

these documents is an important tool to deter a provider from manipulating its books, 

particularly if the Commission does not require providers to submit audited income 

statements and would also assist USAC in ascertaining the authenticity of the provider’s 

application materials. 

This recommendation was adopted in the Final Order.

Ongoing Investigations

Major ACP Provider Voluntarily Repaid Nearly $50 Million

Following an OI investigation, a major ACP provider has voluntarily repaid $49.4 million 

that it improperly claimed between June 2021 and July 2022. In May 2022, OI sent a 

warning letter to the provider regarding abusive and potentially fraudulent EBB 

enrollments made by its sales agents. OI issues warning letters to providers when we 

identify data and other evidence suggestive of fraud, waste or abuse, and our office 

concludes our mission will be best served by a direct inquiry and dialogue. Specifically, 

OI was concerned this specific provider’s sales agents engaged in improper and 

abusive EBB program enrollments made in connection with the National School Lunch 

Program’s Community Eligibility Provision as described in our November 22, 2021, 

advisory.

Later, in August 2022, OI presented the provider with an analysis of its ACP claims data 

that raised serious questions regarding its compliance with EBB and ACP usage 

requirements. OI requested the provider demonstrate that it was compliant with those 

rules. After investigating, the provider disclosed to OI that it improperly claimed $44.5 

million due to improperly implementing the usage requirements. The provider also 

disclosed it received $2.6 million for improper enrollments associated with the National 

School Lunch Program’s Community Eligibility Provision and $2.3 million for claims 

associated with other compliance issues. In total, the provider voluntarily repaid 

approximately $50 million (or one-third) of the total ACP funds it received for service 

claims between June 2021 and July 2022. USAC completed collection of the provider’s 

repayments at the end of August 2023.
FCC OIG—Semiannual Report to Congress 20 4/1/23 – 9/30/23

E-Rate and Emergency Connectivity Fund Programs

Proactive Work 

Creation of an Online Competitive Bid Repository within EPC

The Commission released its Notice of Proposed Rulemaking which would seek 

comments on establishing a competitive bid repository. OI has been monitoring the 

filings in this proceeding, which were generally against the proposed bid repository. 

However, on August 16, 2022, the United States Department of Justice, Antitrust 

Division filed an ex parte comment in the proceeding, recommending the Commission 

adopt the proposal. In part, the Antitrust Division stated that to best protect the E-rate 

program’s competitive process, real-time, centralized, electronic collection of pre-award 

bids and bid selections should occur, which would allow for more robust enforcement of 

the laws designed to protect the E-rate program’s public procurement process and 

enhance the program’s integrity, including the investigation and prosecution of antitrust 

and related crimes related to E-rate procurements. It does not appear as though there 

has been any recent progress on this matter. 

Suspension and Debarment Recommendation 

In numerous previous SARs, OI has explained the importance of the FCC establishing a 

more robust suspension and debarment program similar to those in most other federal 

agencies. Currently, suspension and debarment actions at the Commission are 

extremely limited and only occur in instances where a criminal conviction or civil 

judgment arising out of activities associated with or related to the USF has occurred. 

The limited nature of this criteria hamstrings both OI and the Commission’s efforts to 

protect the USF from non-responsible persons and entities. As we have done for over a 

decade, and first noted in the SAR in 2017, we again ask the Commission to institute a 

new suspension and debarment program at the FCC. 

The Commission issued a “Modernizing Suspension and Debarment Rules” NPRM in 

November 2019, and the Notice was published in the Federal Register on January 14, 

2020. The Commission collected comments and reply comments on its proposed 

Suspension and Debarment rules through March 16, 2020. As requested by the 

Commission, in September 2020, OI provided additional information to the Commission 

following the close of the comment period. OI was informed progress had been made 

on the Suspension and Debarment rulemaking during this reporting period and 

expected the Commission to issue rules and regulations. However, no final action has 

yet been taken by the Commission. 

As noted in the last reporting periods, on April 30, 2019, OI become aware of 

Commission activity granting multiple appeals filed by two schools in the E-Rate 
FCC OIG—Semiannual Report to Congress 21 4/1/23 – 9/30/23

program, seeking additional time to respond to USAC requests for information. 

Individuals associated with these two schools have either been found guilty of federal 

program fraud or work for an E-rate consultant who is currently under indictment for Erate program fraud. If a robust suspension and debarment program existed at the 

Commission, it may have prevented these schools from receiving funding from the 

Program.

By way of example of the immediate need for updated suspension and debarment rules, 

OI staff working on an active investigation were queried by a prosecutor as to why FCC 

was unable to suspend or debar individuals and companies who appeared to be not 

presently responsible. OI explained FCC’s rules only permit suspension or debarment 

after a civil judgment when a defendant admits liability or following criminal convictions 

for certain activities. OI is concerned that funding from FCC programs continues to be

paid out in circumstances when OI would have sought suspension or debarment if a 

robust program were in effect.

Additionally, especially with respect to the newer subsidy programs at the FCC, the 

Commission is unable to take steps to protect itself from irresponsible actors who seek 

to take advantage of additional funding sources. OI’s recent work regarding the ECF 

has revealed certain matters where suspension and/or debarment might be appropriate. 

It is imperative that the Commission join much of the rest of the government and adopt 

robust and effective suspension and debarment rules.

Recommendation to Develop a Notification Process for Cancelled FCC Forms 470

As noted in the last few reporting periods, OI became aware that USAC does not 

employ a mechanism to notify service providers when an applicant seeks to or has 

cancelled its FCC Form 470. OI informed the Commission’s WCB of this 

recommendation on April 1, 2019 and was informed in December 2019 that FCC staff 

have started the process of looking into the feasibility of adding a status field for the 

FCC Form 470 when it has been cancelled. OI is aware WCB has nearly completed 

implementation of a method to cancel FCC Form 470s and OI expects to have an 

update for the next Semi-Annual Report.

Ongoing Investigations 

OI’s E-rate investigations team continues its work on ongoing investigations of E-rate 

service providers, recipients, and consultants. OI has continued to open new 

investigations and has been assisting the DOJ and United States Attorney’s Offices 

around the country to pursue civil and criminal fraud cases in the E-rate program. The 

E-rate Investigations team has expanded its area of responsibility to include 

investigations in the RHC Program, ECF, Contributions matters and the EBB Programs.
FCC OIG—Semiannual Report to Congress 22 4/1/23 – 9/30/23

OI staff have continued to devote extensive resources toward work on open 

investigative matters developed from various sources, including whistleblower 

complaints, proactive data analysis, referrals and other sources and methods. OI 

anticipates some of its investigative work will move to an overt phase in the next 

reporting period and OI can report appropriate information.

Referrals to Enforcement Bureau and USAC

OI continues to track the progress made by the Enforcement Bureau and USAC 

concerning the various referrals OI provided for possible enforcement action. The 

majority of matters referred to the Enforcement Bureau and USAC are still pending.

Emergency Connectivity Fund

OI continues to devote a significant amount of staff time and resources to ensure 

program funds are utilized appropriately by the intended beneficiaries. During the past 

reporting period, OI continued collecting documentation from selected schools 

participating in the ECF. Based on the evaluation of documentation collected, OI staff 

and its contracted staff have conducted site visits at approximately 95 schools and 

libraries to verify equipment, interview school and library staff and understand how the 

program is operating. 

OI’s work has revealed problems with ECF rule compliance, such as failure to develop 

or maintain the required asset and service inventories or to have documentation of 

unmet or actual needs. OI also has concerns regarding whether the ECF-purchased 

equipment is actually being used, as well as if it is being used remotely, as required by 

the rules. OI plans to refer numerous matters to the WCB for administrative remedies as 

OI does not believe these issues rise to the level of fraud.

Based on a prior referral to the WCB, USAC is seeking to recover more than $51,000 

from a school that failed to respond to requests for documentation from either OI or 

USAC. During this reporting period, OI referred an ECF participant’s consultant to WCB 

where OI’s site visit revealed the consultant overbilled the ECF program on behalf of her 

client school. 

OI has additionally referred some of the programmatic issues it has observed in the 

ECF program to the FCC’s Office of General Counsel (OGC). 

Rural Health Care Program

FCA Settlement with GCI Communications Corp.

On May 11, 2023, the U.S. Department of Justice, Civil Division, announced that it had 

reached a settlement with GCI Communications Corp., to resolve allegations it violated 
FCC OIG—Semiannual Report to Congress 23 4/1/23 – 9/30/23

the False Claims Act by knowingly inflating its prices and violating the FCC’s 

competitive bidding rules in connection with GCI’s participation in the RHC Program. To 

resolve these allegations, GCI agreed to pay $40.2 million. Contemporaneously with 

the civil settlement, GCI agreed to enter into a corporate compliance agreement with the 

FCC and resolved an administrative investigation and an FCC proceeding arising from 

GCI’s participation in the RHC program.

Investigations Progress Issues Concerning the FCC’s Office of General Counsel

OI repeatedly has had difficulties obtaining decisions from OGC in its FCA cases. 

OGC’s inaction has reflected poorly on the Commission and in OI’s opinion, has 

degraded the Commission’s relationship with DOJ. In the ordinary course of matters, 

the decision whether to close an investigative file or how to proceed with an open qui 

tam case requires some action from OGC. Most often, OI drafts a memorandum to 

OGC seeking OGC’s concurrence in OIG’s recommendations regarding intervention, 

declination or the closing of an investigative file. In several instances, including the GCI 

matter referred to above, it has taken months of repeated communications to OGC from 

both OI and DOJ attorneys to obtain any substantive response from OGC. In another 

matter, monthly follow-up requests to OGC in an attempt to obtain OGC’s concurrence, 

no productive response has been received. The case file still remains open, more than 

520 days after the initial email was sent to OGC - an email which only sought a short 

response from OGC concurring in closure of an investigative file.

Additionally, OGC has not been forthcoming with respect to OI requests for legal 

interpretations of program rules. This lack of guidance has hindered OI’s consideration 

of whether to recommend criminal or civil remedies in pending investigations.

Contributions

OI staff have continued to review data from service provider contributions to the USF 

and have developed concerns related to the failure of certain entities to provide their 

required contributions into the Fund. OI has continued to expend resources to 

investigating these matters during the current reporting period. Additionally, OI has 

shared certain concerns with OA to assist OA to develop an audit plan to evaluate 

contributors to the fund. 

OI Data Analytics Efforts 

OI’s data team continues to proactively pursue potential fraud, waste, and abuse of the 

USF as well as the Congressionally appropriated subsidy programs. During this 

reporting period, OI’s data analysts continued conducting proactive review of ECF data 

identifying potentially high-risk recipients based on predetermined factors. OI utilized the 

results of this analysis to initiate site visits and plans to rely in large part on the 

information generated to guide future ECF investigations. 
FCC OIG—Semiannual Report to Congress 24 4/1/23 – 9/30/23

OI has also continued testing ACP and E-rate data to identify potentially fraudulent 

behavior. In addition, the team has supported multiple ongoing criminal investigations 

and undertaken efforts to further data analysis of other FCC non subsidy-related 

programs. 

Internal Affairs

The IG is authorized by the IG Act, as amended, to investigate allegations of fraud, 

waste, and abuse occurring in FCC operations. Matters of possible wrongdoing are 

referred to OIG in the form of allegations or complaints from a variety of sources, 

including FCC employees, contractors, other government agencies, and the general 

public. Several such investigations are ongoing, the results of which will be reported 

upon completion. 

Office of Inspector General Hotline

OIG maintains a Hotline to facilitate the reporting of allegations of fraud, waste, abuse, 

mismanagement, or misconduct in FCC programs or operations. Commission 

employees and concerned citizens may report such allegations to the Hotline at (202) 

418-0473 or toll free at (888) 863-2244 or by e-mail at hotline@fcc.gov. OIG’s Hotline is

available 24 hours a day, seven days a week via a recorded messaging system.

Many of the allegations received by the Hotline raise issues that do not fall within the 

jurisdiction of the FCC or the OIG, and many do not rise to the level of devoting 

investigative or audit resources to the claim. Upon receipt of a specific claim of fraud, 

waste, abuse, or mismanagement, OIG may, where appropriate, take any one of the 

following actions:

1. Open an OIG investigation or audit.

2. Refer the matter to an FCC Bureau or Office for appropriate review and action.

3. Refer the allegation to another federal agency. For example, complaints about

fraudulent sweepstakes are referred to the Federal Trade Commission (FTC).

Consumers who have general questions, consumer complaints, or issues not related to 

fraud, waste, and abuse, should contact the FCC’s Consumer & Governmental Affairs 

Bureau (CGB) at www.fcc.gov/cgb, or contact the FCC’s Consumer Center by calling 1-

888-CALL-FCC (1-888-225-5322) voice or 1-888-TELL-FCC (1-888-835-5322). CGB

develops and implements the Commission’s consumer policies, including disability

access. The FCC Consumer Center processes public inquiries, informal complaints,

and questions regarding cable, radio, satellite, telephone, television, and wireless
FCC OIG—Semiannual Report to Congress 25 4/1/23 – 9/30/23

services. The goal of this process is to foster a mutually satisfactory resolution of the 

complaint between the service provider and its customer. 

During the current reporting period, OIG received:

1. 20,550 Hotline contacts. Of these, one was referred to OIG for possible case 

opening.

2. 275 were referred to FCC Consumer Center or other FCC Bureaus.

3. 341 were referred to other agencies.
FCC OIG—Semiannual Report to Congress 26 4/1/23 – 9/30/23

OFFICE OF AUDIT

Under the authority of the IG Act of 1978, as amended, the Office of Audit (OA) 

conducts or contracts for independent and objective audits, inspections, evaluations, 

and other related projects. OA staff is responsible for monitoring, planning, and 

executing projects that cover all areas of the Commission’s activities. 

OA’s mission is to assess the integrity, efficiency and effectiveness of the programs 

administered by the FCC and its components. The work we perform provides

reasonable assurance to the Commission of the integrity of the activities under review 

and promotes accountability and transparency for the agency’s operations and 

programs. OA projects monitor efforts and activities undertaken to meet the agency’s 

goals and mission, and assess how the Commission's rules and regulations are being 

implemented by beneficiaries and other program participants. OA projects are 

conducted in accordance with relevant professional standards, including Generally 

Accepted Government Auditing Standards (also known as Government Auditing 

Standards or the Yellow Book) and CIGIE Quality Standards for Inspection and 

Evaluation (the Blue Book).

OA is organized into three divisions: 

• the Financial and Program Audit Division (FPAD),

• the IT and Program Audit Division (IPAD), and

• the Quality Assurance, Policy and Audit Division (QPAD).

FPAD and IPAD perform audits, evaluations, inspections, and other projects in addition 

to monitoring the status of unimplemented audit recommendations. OA also provides 

assistance to OI on accounting and audit matters and responding to congressional 

inquiries. Due to our limited resources, we staff our projects using a combination of OA 

personnel and contracted audit specialists. OA contracts with Independent Public 

Accountant (IPA) firms for many mandatory projects and some discretionary projects. 

All contracted OA projects are closely monitored by OA personnel to ensure project 

objectives and applicable engagement standards are met. Our oversight approach 

assures that OA staff are fully versed in all FCC program areas, and it ensures that OA 

staff provide timely and adequate input and review of all issues identified by the contract 

auditors. 

FPAD and IPAD selects and conducts projects using a risk-based approach. The 

divisions determined that projects concerning the High Cost Universal Broadband

Portal, the Secure and Trusted Network/Supply Chain Reimbursement Program,

Lifeline, ECF, and personally identifiable verification (PIV) card implementation activities 

meet our risk-based criteria. Our risk-based criteria select projects receiving the highest 

risk ratings based on our most recent program risk assessment results. The two 

divisions plan to conduct audits or other projects covering these areas as resources 
FCC OIG—Semiannual Report to Congress 27 4/1/23 – 9/30/23

become available. Information regarding completed, planned projects, and ongoing 

projects are included in the division sections below. Additionally, published reports are 

posted to the OA OIG webpage. 

QPAD develops OA policies and procedures, performs internal quality assurance 

reviews to ensure OA compliance with applicable professional standards, coordinates 

external peer reviews of the FCC OIG by other OIGs, and leads external peer reviews 

of other OIGs in accordance with CIGIE guidance. 

Financial and Program Audit Division

FPAD conducts mandatory and discretionary audits, inspections, and evaluations of 

FCC programs and operations. FPAD’s annual mandatory projects include the annual 

Financial Statements audit and the Payment Integrity Information Act (PIIA) audit. FPAD 

is responsible for performing other periodic mandated projects such as the ACP 

implementation audit, and the government charge card program projects. FPAD

discretionary projects cover multiple areas of FCC operations and selected USF 

programs such as the Lifeline and USF Contributions. For example, the division is 

currently conducting a Contributions audit and planning for an audit of the Supply Chain 

reimbursement program (SCRP) established by the Secure and Trusted 

Communications Networks Act of 2019. The SCRP program was created at the 

direction of Congress to reimburse providers of advanced communications services for 

the reasonable expenses incurred in the removal, replacement, and disposal of covered 

equipment and services for the purpose of protecting the security and integrity of 

communications networks or communications supply chain. 

During this semi-annual reporting period, FPAD completed one project. Three FPAD 

projects are in process. The results of these in-process projects will be summarized in a 

future semi-annual report.

Completed FPAD Projects

FY22 Performance Audit of FCC's Compliance with the Payment Integrity Information 

Act (PIIA) of 2019 (Project No. 23-AUD-01-03)

The Payment Integrity Information Act (PIIA) of 2019 directs federal agencies and 

departments to reduce and recover improper payments. The Office of Audit contracted 

with an IPA firm for an audit of the FCC’s compliance with PIIA for fiscal year 2022. 

The audit report was issued on May 24, 2023. The FCC was compliant in seven of its 

ten programs that were susceptible to significant improper payments. The USF Lifeline, 

E-rate, and the High-Cost Legacy program were non-compliant with at least one PIIA

criteria.
FCC OIG—Semiannual Report to Congress 28 4/1/23 – 9/30/23

The Lifeline program was not compliant with PIIA criteria because the FCC had not 

accurately reported the overpayment amount first identified in the 2019 IPERIA audit 

report as of fiscal year 2022. 

Secondly, the E-rate program was not compliant with PIIA criteria because the FCC did 

not demonstrate expected improvements in reducing its improper payment rate 

estimates to a level at or below its tolerable improper payment rate or annual reduction 

targets during fiscal year 2022. 

Lastly, the High-Cost Legacy program was not compliant with PIIA criteria because the 

FCC did not publish its improper Payments and unknown payments estimates for this 

program in fiscal year 2022. 

In addition to the compliance findings, the report includes conditions regarding the 

FCC’s risk assessments and internal controls that were reported as recommendations 

for improvement. 

In summary, the audit report presented five findings and offers 10 recommendations to 

address those findings. Management agreed with the finding regarding the 

improvements needed in FCC risk assessments, and provided neither concurrence nor 

nonconcurrence on the remaining four findings.

In-Process FPAD Audits

FY 2022 Audit of the Federal Communications Commission’s Compliance with the 

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

As required by the Infrastructure Act, OIG engaged a contractor to audit the FCC’s 

implementation of ACP. The overall objective of the audit was to determine if the FCC 

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

Specific objectives included the following:

1. Determine whether the FCC and USAC implemented effective internal controls to

ensure ACP disbursements were made to eligible service providers for eligible

ACP program participants, to reduce improper payments, and to prevent and

detect fraud, waste, and abuse;

2. Determine whether the FCC complied with agency oversight requirements for

consumer complaint resolution and participating provider compliance as defined in

the Infrastructure Act Section 60502(9) Commission Oversight;

3. Determine if the FCC conducted effective outreach efforts, as described in the

Infrastructure Act Section 60502 10 (C) Commission Outreach, to identify eligible

households, encourage them to enroll in the ACP, and provide information on how

to enroll;
FCC OIG—Semiannual Report to Congress 29 4/1/23 – 9/30/23

4. Determine whether the FCC developed effective program goals and performance

measures to accurately report the performance results of the ACP program; and

5. Follow up on the status of recommendations reported in prior OIG and GAO

audits of the EBB Program.

Fiscal Year 2023 FCC Financial Statements Audit (Project No. 23-AUD-06-01)

As required by the Accountability of Tax Dollars Act of 2002 (Pub. L. 107-289), the OIG 

engaged a contractor to audit the consolidated financial statements of the FCC, which 

comprise the consolidated balance sheets, the related consolidated statements of net 

cost and changes in net position, the consolidated statement of custodial activity and 

the combined statements of budgetary resources (hereinafter referred to as the 

“financial statements”) for the years ended September 30, 2023, and 2022, and the 

related notes to the financial statements.

USAC’s Oversight USF Contributions Process Audit (Project No. 23-AUD-05-01)

The objective of this audit is to evaluate whether the internal controls over the USF 

payment process via the E-file system are effective, timely, and include all providers of 

telecommunications required to make contributions per FCC and USAC guidelines

(service providers). Specifically, the audit is:

1. Reviewing the adequacy of controls over the process by which service providers

transmit their contributions to the USF/USAC as calculated on FCC Form 499;

2. Determining whether USAC ensures that collections from service providers are

submitted accurately within the timeframe established by the FCC, and that late

fees are assessed and collected on time;

3. Determining whether USAC ensures that all service providers required to

contribute to the USF pursuant to FCC guidelines are doing so; and

4. Determining whether USAC ensures service providers that apply for de minimis

status accurately report revenues on their FCC Form 499 to qualify as a non-filer

per FCC guidance.

IT Program Audit Division

The IT Program Audit Division (IPAD) conducts mandatory and discretionary audits, 

inspections, evaluations, and surveys of FCC programs and operations. IPAD’s

mandatory project includes an annual Federal Information Security Modernization Act of 

2014 (FISMA) evaluation and a periodic Privacy and Data Protection (P&DP) 
FCC OIG—Semiannual Report to Congress 30 4/1/23 – 9/30/23

inspection. Discretionary projects include USF programs, such as the High Cost Fund, 

RHC, and E-rate programs, as well as other areas of FCC operations. Additionally, 

IPAD is planning an audit of the High Cost Program’s High Cost Universal Broadband 

(HUBB) Data, which covers broadband deployment data submitted in the HUBB Portal 

relevant to completed verification reviews and performance measures testing. The 

HUBB Portal monitors compliance with broadband deployment, ensuring carriers 

receiving CAF support are deploying broadband, as required. 

IPAD completed one project during this reporting period. Four IPAD projects are in 

process. The results of the in-process projects will be summarized in a future semiannual report.

Completed IPAD Project

E-rate – FY 2020 Audit of Orange County Public Library (Project No. 22-AUD-11-03)

OA contracted with an IPA firm to conduct a performance audit of Orange County Public 

Libraries. The objectives were to (1) determine if the District complied with FCC rules 

and orders applicable to the USF E-rate program; and (2) report on potential instances 

of fraud, waste and/or abuse, if applicable. The scope of the performance audit was July 

1, 2020, through June 30, 2021.

The final audit report issued on August 25, 2023, did not identify any findings or 

instances of non-compliance. Additionally, the report identified no potential instances of 

fraud, waste, and/or abuse. 

In-Process IPAD Audits and Other Projects

FY 2023 FISMA Evaluation

The FISMA legislation requires federal agencies to develop, document, and implement 

an agency-wide program to provide information security for the information and 

information systems supporting the operations and assets of the agency. FISMA also 

requires agency IGs to conduct or contract for an independent evaluation of the 

agency’s information security program annually. Under the oversight of OIG, Kearney & 

Company, P.C. (Kearney) performed the FY 2023 FISMA evaluation. 

The objectives of the FISMA evaluation are to:

• Determine the effectiveness of information security policies, procedures, and 

practices for a representative subset of the FCC’s and USAC’s information 

systems;

• Assess compliance with FISMA and applicable OMB and National Institute of 

Standards and Technology (NIST) guidance;
FCC OIG—Semiannual Report to Congress 31 4/1/23 – 9/30/23

• Prepare the FCC OIG’s response to the Department of Homeland Security’s

(DHS) FY 2022 Inspector General (IG) FISMA Reporting Metrics Questionnaire;

and

• Follow-up on findings and recommendations reported in previous FISMA

evaluations.

FY 2019 & 2020 Audit of New River Valley Community Services 

(Project No. 23-A-02-01)

The objective of this performance audit is to determine whether New River Valley 

Community Services complied with Title 47 of the Code of Federal Regulations (C.F.R.) 

§§ 54.601 - 54.607, 54.619 - 54.633. Additionally, the audit evaluates the beneficiary's

compliance with FCC rules and orders for RHC providers relevant to the audit objective.

FY 2019 & 2020 Audit of Mt. Rogers Community Services (Project No. 23-AUD-02-02)

The objective of this performance audit is to determine whether Mt. Rogers Community 

Services complied with Title 47 C.F.R. §§ 54.601-54.607, 54.619-54.633. Additionally, 

the audit evaluates the beneficiary's compliance with FCC rules and orders for RHC 

providers relevant to the audit objective.

FY 2021 Privacy and Data Protection Inspection (Project No. 21-INSP-10-01)

The objective of this inspection is to determine whether the FCC has implemented 

effective privacy and data protection policies and procedures in accordance with federal 

laws, regulations, and policies, with a focus on FCC’s implementation of the nine 

requirements identified in 42 U.S.C. § 2000ee-2 Privacy and Data Protection Policies 

and Procedures. The inspection includes a review of how effectively the FCC 

implemented its data protection and privacy program from October 1, 2020, to 

September 30, 2021.
FCC OIG—Semiannual Report to Congress 32 4/1/23 – 9/30/23

REPORTING REQUIREMENTS

The SAR questions were updated to comply with the OIG 16 reporting requirements for 

the National Defense Authorization Act (NDAA) for FY 2023, Section 5273, which

amends Section 5(a) of the IG Act.

1. A description of significant problems, abuses, and deficiencies relating to the 

administration of programs and operations of the establishment and associated reports 

and recommendations for corrective action made by the Office.

Please refer to sections of this report titled “Office of Audit” and “Office of 

Investigations.”

2. An identification of each recommendation made before the reporting period, for which 

corrective action has not been completed, including the potential costs savings 

associated with the recommendation.

See Appendix A1. OI Unimplemented Recommendations and

See Appendix A2: OA Unimplemented Recommendations. 

3. A summary of significant investigations closed during the reporting period.

Please refer to sections of this report titled “Office of Investigations.”

4. An identification of the total number of convictions during the reporting period 

resulting from investigations.

During this reporting period, no convictions resulted from investigations.

5. Information regarding each audit, inspection, or evaluation report issued during the 

reporting period, including—

(A) a listing of each audit, inspection, or evaluation;

(B) if applicable, the total dollar value of questioned costs (including a separate 

category for the dollar value of unsupported costs) and the dollar value of 

recommendations that funds be put to better use, including whether a 

management decision had been made by the end of the reporting period.

Please refer to the sections of this report titled “Office of Audit.”
FCC OIG—Semiannual Report to Congress 33 4/1/23 – 9/30/23

6. Information regarding any management decision made during the reporting period 

with respect to any audit, inspection, or evaluation issued during a previous reporting 

period.

See Appendix B: Reports Issued in Prior Periods for which a Management Decision is 

Pending as of September 30, 2023.

7. The information described under section 804(b) of the Federal Financial Management 

Improvement Act of 1996.

No report required by 804(b) of the Federal Financial Management Improvement Act of 

1996 was issued during this reporting period.

8. (A) An appendix containing the results of any peer review conducted by another 

Office of Inspector General.

(B) If no peer review was conducted within the reporting period, a statement identifying 

the date of the last peer review conducted by another Office of Inspector General.

(A) No peer reviews were conducted within the reporting period. 

(B) On May 27, 2022, the Export-Import Bank of the United States (EXIM) Office of 

Inspector General (EXIM OIG) OIG performed an Inspection and Evaluation peer review 

to determine the FCC OIG compliance with CIGIE’s Quality Standards for Inspection 

and Evaluation (Blue Book) for the year ending September 30, 2021. EXIM OIG 

determined that the FCC OIG’s policies and procedures generally were consistent with 

Blue Book standards.

On September 1, 2022, the Pension Benefits Guaranty Corporation Office of Inspector 

General (PBGC OIG) issued a modified peer review4 of the FCC OIG’s system of quality 

control for audit operations for the period ending March 31, 2022. 

See Appendix C: Peer Review Results, for further details.

9. A list of any outstanding recommendations from any peer review conducted by 

another Office of Inspector General that have not been fully implemented, including a 

statement describing the status of the implementation and why implementation is not 

complete.

There are no outstanding recommendations from any peer review conducted by another 

Office of Inspector General. All recommendations from the two most recent peer 

reviews completed, EXIM I&E peer review and the PBGC Audit peer review, have been 

fully implemented.

4 CIGIE requires a Modified Peer Review for OIGs that do not perform GAGAS engagements, but maintained audit 

policies and procedures in anticipation of performing such work.
FCC OIG—Semiannual Report to Congress 34 4/1/23 – 9/30/23

10. A list of any peer reviews conducted by the Inspector General of another Office of 

the Inspector General during the reporting period, including a list of any outstanding 

recommendations made from any previous peer review (including any peer review 

conducted before the reporting period) that remain outstanding or have not been fully 

implemented.

The FCC OIG conducted a peer review of the National Archives and Records 

Administration (NARA) OIG’s audit operations during a previous reporting period. The 

peer review report was issued on March 16, 2023, and NARA OIG received a “Pass” 

rating. The FCC OIG also issued a Letter of Comment with two findings and two 

recommendations. In response to the letter of comment, NARA OIG has outstanding 

recommendations that they committed to complete by June 30, 2023.

11. A statistical tables showing—

(A) the total number of investigative reports issued during the reporting period; 

(B) the total number of persons referred to the Department of Justice for criminal 

prosecution during the reporting period; 

(C) the total number of persons referred to State and local prosecuting authorities for 

criminal prosecution during the reporting period; and 

(D) the total number of indictments and criminal information during the reporting period 

that resulted from any prior referral to prosecuting authorities

(A) The “Office of Investigations” section contains the total number of investigative 

reports during the reporting period. 

(B) In this reporting period, three referrals were made to the Department of Justice 

for criminal prosecution, including two companies and one individual. 

(C)No person was referred to state or local prosecuting authorities for criminal 

prosecution during this reporting period.

(D)No indictment or criminal information was filed during the reporting period.

12. A description of the metrics used for developing the data for the statistical tables 

under paragraph (11).

The Office of Investigations issues “investigative reports” to either (1) close an 

investigation or (2) refer a matter for administrative action or for pursuit of civil or 

criminal fraud. An “investigative report” refers to any document, including but not limited 

to a Report of Investigation, sufficient to close a case in OI’s Case Management 

System. We do not close a matter until it is finally resolved, that is until (a) action is 

taken by the Commission in an administrative referral, or until the civil or criminal 

referral is declined or resolved by the court or (b) it is determined that no further action 

is merited. 
FCC OIG—Semiannual Report to Congress 35 4/1/23 – 9/30/23

13. A report on each investigation conducted by the Office where allegations of 

misconduct were substantiated involving a senior Government employee or senior

official (as defined by the Office) if the establishment does not have senior Government

employees or senior official, which shall include—

(A) the name of the senior Government employee, if already made public by the Office; 

and 

(B) a detailed description of—

(i) the facts and circumstances of the investigation; and

(ii) the status and disposition of the matter, including—

(I) if the matter was referred to the Department of Justice, the date of the 

referral; and

(II) if the Department of Justice declined the referral, the date of the 

declination.

No investigation involving a senior government employee or senior official where 

allegations of misconduct were substantiated was conducted by the Office.

14. (A) A detailed description of any instance of whistleblower retaliation, including 

information about the official found to have engaged in retaliation; and (B) what, if any, 

consequences the establishment imposed to hold that official described in 

subparagraph (A) accountable

No findings of whistleblower retaliation were made during this reporting period.

15. (A) A detailed description of any attempt by the establishment to interfere with the 

independence of the Office, including—

(i) with budget constraints designed to limit the capabilities of the Office; and 

(ii) incidents where the establishment has resisted or objected to oversight 

activities of the Office or restricted or significantly delayed access to information, 

including the justification of the establishment for such action; and 

(B) a summary of each report made to the head of the establishment under section 

6(c)(2) during the reporting period.

OIG experiences with attempts by FCC management to interfere with the independence 

of the Office are described on pages 8-9 and 10-13.

16. A detailed descriptions of the circumstances of each—

(A) inspection, evaluation, and audit conducted by the Office that is closed and was not 

disclosed to the public; and (B) investigation conducted by the Office involving a senior 

Government employee that is closed and was not disclosed to the public.

(A) No inspection, evaluation, and audits were closed and not disclosed to the public

during this reporting period.
FCC OIG—Semiannual Report to Congress 36 4/1/23 – 9/30/23

(B) No investigation was conducted involving a senior Government employee that is 

now closed and was not disclosed to the public. 
FCC OIG—Semiannual Report to Congress 37 4/1/23 – 9/30/23

APPENDIX A1

OI Unimplemented Recommendations

The following FCC OIG OI recommendations, for which corrective action has not been 

taken, are described in this SAR:

OI Advisory Regarding ACP Provider Noncompliance 

with Program Usage & De-Enrollment Rules

Please refer to page 15 of 

this report.

OI Recommendations Regarding the ACP Sixth Report 

and Order Recommendations

Please refer to page 16 of 

this report.

Creation of an Online Competitive Bid Repository 

within EPC

Please refer to page 20 of 

this report.

Suspension and Debarment Recommendation Please refer to page 20 of 

this report.

Recommendation to Develop a Notification Process for 

Cancelled FCC Forms 470

Please refer to page 21 of 

this report.

For further descriptions of prior recommendations made by the FCC OIG OI, for which 

corrective action has not been completed, please refer to previous FCC OIG 

Semiannual Reports to Congress.
FCC OIG—Semiannual Report to Congress 38 4/1/23 – 9/30/23

APPENDIX A2

OA Unimplemented Recommendations

As of this semi-annual reporting period, OIG OA has 40 open and unimplemented 

recommendations from our audits, inspections and evaluations. Information 

Technology recommendations are considered sensitive, and contain non-public 

information. Therefore they are presented by FISMA reporting metrics domain5 only in 

the below OA table of unimplemented recommendations.

Project Code Project Title Report 

Issue Date

Recommendation

23-AUD-01-03 Final Report on the 

Performance Audit 

of Fiscal Year 2022 

Compliance with 

Payment Integrity 

Information Act of 

2019 for the 

Federal 

Communications 

Commission 

5/24/2023 1. Correct the 2019 IP estimate amount 

reported in PY in the current year reporting by 

reporting the full estimated amount of $30 

million as an overpayment.

2. If a settlement is reached by issuing a 

Forfeiture Order or Consent Decree, then 

report the amount recovered from the provider 

as an overpayment recaptured outside 

payment recapture audits.

7. Through the OMB annual data call, include 

measurable milestones to accurately report IP 

information on paymentaccuracy.gov and 

achieve compliance.

9. Adequately plan the PQA assessments for 

HC Legacy to account for additional review 

time needed to complete the expanded 

procedures. Specifically, create and gain 

approval for the assessment procedures and 

select samples in an approved timeframe that 

allows for the expanded procedures to be 

completed by the reporting deadline.

10. Perform outreach to all beneficiaries of HC 

Legacy prior to PQA assessments to ensure 

beneficiaries are aware and understand the 

expanded procedures for PQA, the additional 

documentation request and requirements, and

the feasibility of the requested due date in 

providing the documentation.

22-EVAL-06-01 FY 2022 FISMA 

Evaluation Report

2/28/2023 1. Risk Management 

2. Risk Management

5. Supply Chain Risk Management

5 The FISMA reporting metrics domains:

• Risk management and supply chain risk management (SCRM);

• Configuration management, identity, and access management (CAM), data protection and privacy, and security training;

• Information security continuous monitoring (ISCM);

• Incident response; and

• Contingency planning.
FCC OIG—Semiannual Report to Congress 39 4/1/23 – 9/30/23

6. Supply Chain Risk Management

8. Configuration Management

12. Identity Access Management

13. Identity Access Management

14. Identity and Access Management

17. Configuration Management

18. Configuration Management

22-AUD-01-01 Fiscal Year 2021

Payment Integrity

Information Act of

2019 Performance

Audit

6/28/2022 9. Develop and implement a written improper 

(IP) and unknown payment (UP) risk 

assessment methodology that incorporates the 

Enterprise Risk Management (ERM) 

framework from Office of Management and 

Budget (OMB) Circular A-123, to help identify

and manage payment integrity risk and support 

whether the program is susceptible to making 

IPs and/or UPs. The methodology should 

include a risk scoring or weighting factor for 

each program and associated risk.

14. Continue to enhance USACs applicant 

outreach program to educate applicants on the 

schools and libraries (S&L) program rules, 

especially rules relating to the competitive 

bidding processes.

15. Enhance the use of automation tools in ERate Productivity Center (EPC) to check 

invoices for common errors and invoices that 

are flagged as high risk of non-compliance with 

program invoicing requirements.

16. Work with the Chairwoman’s Office to 

formalize the improper payment by issuing a 

Forfeiture Order or Consent Decree. Report 

the amount from the binding agreement as an 

Improper Payment identified through recovery 

actions or report the full amount of

$30 million as an overpayment identified 

through recovery activities.

17. Once the settlement has been finalized, 

through the OMB annual data call, include 

measurable milestones to accurately report

IP information on paymentaccuracy.gov if 

found non-compliant with OMB M-21-19.

21-EVAL-06-01 FY 2021 FISMA 

Evaluation Report 

12/15/2021 11. Identity and Access Management 

21-AUD-10-01 FY 2021 FCC 

Emergency 

Broadband Benefit 

Program 

Performance Audit

6/21/2022 1. Increase the scrutiny of the manual 

verification process, including implementing a 

multilevel review process that includes reviews 

of the supporting documentation in comparison 

to the application.
FCC OIG—Semiannual Report to Congress 40 4/1/23 – 9/30/23

21-AUD-08-06 FY 2021 DATA Act 

Audit

11/8/2021 3. Develop and implement FCC’s DQP policies 

and procedures for updating the DQP in 

accordance with the applicable guidance. 

Policies and procedures should address the 

timeframe in updating the DQP due to changes 

in the FCC’s processes, including component 

processes, and new or revised guidance from 

OMB, the Department of the Treasury 

(Treasury), or other authoritative sources. 

4. Develop and implement policies and 

procedures to ensure FCC communicates new 

guidance to its components. This can include 

holding regular meetings with the components 

to ensure all new guidance is communicated 

and interpreted consistently across the FCC 

entity.

5.Develop and implement oversight policies 

and procedures to ensure component entities 

report financial assistance awards timely.

7. Coordinate with USAC management to 

develop and implement processes for obtaining 

all required data elements from awardees prior 

to issuing an award. This may include updating 

or creating program forms to include all 

required data elements needed for Financial 

Assistance Broker Submission.

8. Develop and implement oversight policies 

and procedures for monitoring data reported by 

component entities to ensure that all DATA Act 

information is being reported timely, accurately, 

and completely.

20-AUD-01-01 FY 2019 Improper 

Payments 

Elimination and 

Recovery 

Improvement Act 

(IPERIA) 

Compliance Audit

6/15/2020 12. FCC Management develop policies and 

procedures that (a) acknowledge the 

interdependent relationships between FCC, the 

TRS Fund Administrator, and TRS providers; 

(b) address the responsibilities of each party to 

manage risks of IPs; and (c) describe 

methodologies used to obtain assurance that 

each party manages its risks of IPs 

appropriately and as intended. 

19-EVAL-07-01 FY 2019 FISMA

Evaluation Report

1/8/2020 4. Identity and Access Management 
FCC OIG—Semiannual Report to Congress 41 4/1/23 – 9/30/23

19-AUD-08-05 FY 2019 DATA Act 

Audit

11/8/2019 2. Continue to coordinate with the TRS Fund 

administrator to develop a DATA Act project 

plan. The TRS Fund project plan should 

include an expected timeline and steps to 

implement necessary changes to systems and 

business processes to capture, link, reconcile, 

and report on award-level financial and 

spending information. The TRS Fund 

Administrator, in coordination with the FCC, 

should develop and execute a project plan that 

conforms with Steps 1 through 8 of the DATA 

Act Implementation Playbook (Version 2.0).

19-AUD-02-01 FY 2018 Improper 

Payments 

Elimination and 

Recovery 

Improvement Act 

(IPERIA) 

Compliance Audit

6/3/2019 4. Modify the Payment Quality Assurance 

(PQA) assessment procedures to target USFHigh Cost (HC) program rules and significant 

risks of improper payments. 

18-EVAL-07-01 FY 2018 FISMA 

Evaluation Report

12/21/2018 7. Configuration Management 

15. Information Security Continuous Monitoring

17-EVAL-07-01 FY 2017 FISMA 

Evaluation Report

12/21/2017 4. Risk Management

17-AUD-08-04 FY 2017 DATA Act 

Audit

11/7/2017 2. As technical and operational issues arise 

during the USAC and Rolka DATA Act 

implementation, USAC and Rolka, in 

coordination with the FCC, should coordinate 

with OMB and Treasury to work through any 

issues in real time. The FCC should document 

all significant issues encountered that required 

OMB and Treasury involvement. Ensure that 

as technical and operational issues arise 

during the TRS Fund Administrator DATA Act 

implementation, the TRS Fund Administrator, 

in conjunction with the FCC, coordinates with 

OMB and Treasury to work through any issues 

in real time. The FCC should document all 

significant issues encountered that required 

OMB and Treasury involvement.

16-EVAL-06-01 FY 2016 FISMA 

Evaluation Report

12/8/2016 9. Identity and Access Management

15-AUD-10-09 Audit of National 

Lifeline 

Accountability 

Database

3/26/2018 2.2. Require that USAC obtain written 

statements from state commissions and ETCs 

to confirm that their staff and agents who have 

NLAD access rights have successfully 

completed background investigations.
FCC OIG—Semiannual Report to Congress 42 4/1/23 – 9/30/23

15-AUD-10-09 Audit of National 

Lifeline 

Accountability 

Database

3/26/2018 2.4. Require that USAC obtain written 

statements from state commissions, 

contractors, and ETCs confirming that their 

staff and agents who are granted access rights 

for NLAD have completed appropriate training 

to reduce the possibility that Personal 

Identifiable Information (PII) will be

accessed, used, or disclosed inappropriately.

13-AUD-12-29 FY 2014 Wireline 

Competition 

Bureau Audit

6/14/2017 4.1. We recommend WCB develop and 

implement a plan that ensures the closure of 

pending appeals in a timely manner and 

prioritizes the resolution of appeals filed 2010 

and earlier.

12-AUD-12-20 FY 2012 A-130 

Audit

3/12/2014 4.1. Configuration Management
FCC OIG—Semiannual Report to Congress 43 4/1/23 – 9/30/23

APPENDIX B

Reports Issued in Prior Periods for which a Management Decision is Pending

as of September 30, 2023

Report 

Number

Project Title

(Recommendat

ion No.)

Report 

Date

Recommendation(s) Comments

12-AUD-12-20

Audit of the FCC 

Compliance with 

OMB Circular No. 

A-130, Revised

(Rec. No. 4.1)

3/12/2014

4.1. Configuration 

Management

Management has not 

demonstrated sufficient 

progress to implement the 

one remaining open 

recommendation. 

Management revised the 

target date from February 28, 

2023, to December 1, 2023. 

The audit report contains 

nonpublic information, 

therefore the report was not 

posted to the OIG webpage.

13-AUD-12-29

Performance 

Audit of the 

Federal 

Communications 

Commission 

Wireline 

Competition 

Bureau

(Rec. No. 4.1)

07/31/2015

4.1. We recommend WCB 

develop and implement a 

plan that ensures the 

closure of pending appeals 

in a timely manner and 

prioritizes the resolution of 

appeals filed 2010 and 

earlier.

Management has not 

demonstrated sufficient 

progress to implement the 

recommendation. 

Management provided an 

updated CAP on September 

29, 2023. The new timeline to 

complete the corrective action 

is December 31, 2023. WCB 

explained that it needs 

additional time based on its 

ongoing need to focus 

resources on an unusual 

volume of critical work.
FCC OIG—Semiannual Report to Congress 44 4/1/23 – 9/30/23

15-AUD-10-09

Performance Audit 

of Universal 

Service 

Administrative 

Company National 

Lifeline 

Accountability 

Database

(Rec No. 2.2 and 

2.4)

3/26/2018

2.2. Require that USAC obtain 

written statements from state 

commissions and ETCs to confirm 

that their staff and agents who 

have NLAD access rights have 

successfully completed 

background investigations.

2.4 Require that USAC obtain 

written statements from state 

commissions, contractors, and 

ETCs confirming that their staff 

and agents who are granted 

access rights for NLAD have 

completed appropriate training to 

reduce the possibility that 

Personal Identifiable Information 

(PII) will be accessed, used, or 

disclosed inappropriately.

Two recommendations remain 

open from this audit report. 

Although FCC provided a 

corrective action plan, it did not 

contain actions needed to 

address the audit 

recommendations.
FCC OIG—Semiannual Report to Congress 45 4/1/23 – 9/30/23

APPENDIX C

Peer Review Results

The Inspector General Act of 1978, as amended, requires the OIGs to report the results 

of peer reviews of their operations conducted by other OIGs, including the date of the 

last peer review, outstanding recommendations from prior peer reviews, and peer 

reviews of other OIGs conducted during the semiannual period. Peer reviews are 

conducted by member organizations of the CIGIE. 

Office of Audit Peer Review Results

On May 27, 2022, EXIM OIG assessed the extent to which the FCC OIG compiled with 

the seven covered Blue Book standards, specifically: Quality Control; Planning; Data 

Collections and Analysis; Evidence; Records Maintenance; Reporting; and Follow-up for 

the year ending September 30, 2021. EXIM OIG determined that the FCC OIG’s 

policies and procedures generally were consistent with each of the seven Blue Book 

standards addressed in the external peer review. Of the two reports reviewed, both 

reports generally compiled with the seven covered Blue Book standards. No 

recommendations from the EXIM OIG remain outstanding.

On September 1, 2022, the Pension Benefits Guaranty Corporation Office of Inspector 

General (PBGC OIG) issued a modified peer review6 of the FCC OIG’s system of quality 

control for audit operations for the period ending March 31, 2022. The purpose of the 

review was to determine whether FCC OIG had controls to ensure that IPAs performed 

contracted work in accordance with professional standards. PBGC identified one 

recommendation to improve the FCC OIG policies and procedures. No recommendation 

from the PBGC OIG remain outstanding.

Office of Audit Peer Reviews of Other Office of Inspector General 

On March 16, 2023, the FCC OIG issued a report on the results of its peer review of the 

NARA OIG’s system of quality control for its audit operations. The FCC OIG determined 

that NARA OIG’s system of quality control in effect for the year ended September 30, 

2022, was suitably designed to provide reasonable assurance that it is performing 

audits and reporting the audit results in conformity with applicable professional 

standards in all material respects. NARA OIG received a peer review rating of “Pass.” 

The FCC OIG’s peer review letter of comment contained two recommendations that 

were designed to further strengthen the NARA OIG’s system of quality control. NARA 

OIG’s management concurred with the FCC OIG’s peer review findings and

recommendations and issued a memo initiating its corrective actions, effective March 6, 

6 CIGIE requires a Modified Peer Review for OIGs that do not perform GAGAS engagements, but maintained audit 

policies and procedures in anticipation of performing such work.
FCC OIG—Semiannual Report to Congress 46 4/1/23 – 9/30/23

2023. In response to the letter of comment, NARA OIG committed to complete

outstanding recommendations by June 30, 2023.
FCC OIG—Semiannual Report to Congress 47 4/1/23 – 9/30/23

Office of Inspector General

Federal Communications Commission

45 L Street NE

Washington, DC 20554

. 

Report fraud, waste, and abuse.

Email: Hotline@FCC.gov

Call Hotline: 202-418-0473

Whistleblower Disclosure Hotline

800-872-9855 or info@osc.gov

FCC OIG: WPC@fcc.gov