Rural Health Care
Notes from the Rural Health Care Monthly Conference Call: October 14, 2010
Agenda
• Gifts & Payment Quality Assurance (PQA)
• Reminder about Rural Health Care Training for New Applicants and Pilot Program
• Forms and Application Processing System Redesign
1. Gifts & PQA
Wayne Scott, Vice President of USAC’s Internal Audit Division, provided an overview of the
gift rule and Payment Quality Assurance (PQA) program.
• Gift Rule
o Do not accept gifts from service providers over $20 at any point during the RFP
process.
o The FCC recently clarified gift rules for the Schools and Libraries’ E-Rate Program,
USAC recommends that Rural Health Care applicants follow these rules.
o See page 2 for more information.
• PQA Program
o PQA is a payment assessment program that enables USAC to estimate rates of
improper payments across all four USF programs; it is not an audit program.
o Payment assessments will be conducted by the USAC Internal Audit Division.
o Assessments require participants to submit documents, but no on-site work is
involved.
o Participants will receive the results of their assessment when their case is closed.
o Participants have 10 business days to respond to their selection notice. Requests for
extensions are considered case by case.
o See page 3 for more information.
2. Rural Health Care Training for New Applicants and Pilot Program
A live training will be held for Rural Health Care program applicants on October 19-20 in Salt
Lake City, UT. The first day will be for Pilot Program participants and the second will be for
new applicants to the RHC Primary program. The Primary program training will be for those
who have been in the program for less than two years. This training is also a good opportunity
for those who are transitioning the responsibility of filing RHC forms to another individual or for
those who have had the responsibility transitioned over to them. Topics that will be covered in
the training include determining eligibility, understanding and submitting required forms and
supporting documentation, how to ensure compliance with competitive bidding rules, important
deadlines, the role of the service provider, and other information to help new applicants through
the application process.
3. Forms and Application Processing System Redesign
Application forms and the processing system are undergoing a comprehensive review and
redesign to streamline the application process. If you have any suggestions for the redesign of the
forms and system redesign, please e-mail your comments.
SCHOOLS AND LIBRARIES GIFT RULES (FCC Sixth Report & Order)
• Receipt of gifts by applicants from service providers and potential service providers is a
competitive bidding violation.
• Must follow the stricter of state/local or FCC rules.
• Exceptions mirror Federal Government regulations. Items worth $20 or less (meals,
pencils, pens, hats, t-shirts, etc.) as long as those items do not exceed $50 per year per
employee from any one source (service provider) are OK.
o This means all gifts from all employees, officers, representatives, agents,
independent contractors, or directors of the service provider.
• Gift prohibitions are always applicable, not just during the competitive bidding process.
• Prohibition includes soliciting and receiving any gift or other thing of value from a
service provider participating in or seeking to participate in the E-rate program.
• Service providers may not offer or provide any gifts to applicant personnel involved in E-
rate.
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USAC PAYMENT QUALITY ASSURANCE PROGRAM (PQA)
Purpose
• Measure accuracy of Universal Service Fund (USF) payments to beneficiaries to assist
FCC in complying with reporting obligations under the Improper Payments Information
Act (IPIA)
• Provide timely, comprehensive data as required by IPIA
• Conduct ongoing testing of USAC disbursement procedures
Approach
• USAC and FCC collaborated on designing and implementing program
• Assess payments in all four USF programs
• Calibrate sample size to IPIA requirements
• Smooth performance of program activity over entire year
• Automate to fullest extent possible
• Maintain full, regular communications with PQA participants
Process
• Four-month cycle of selection and notification, analysis, and reporting
• Selection and notification
o Sample program beneficiaries and select participants
o Send beneficiary notice of selection and requirements for submitting documents
• Analysis
o Examine beneficiary and USAC documentation to assess payment
• Reporting
o Conclude assessment and report outcome to beneficiary
o Aggregate findings and report improper payment data to FCC
Benefits
• PQA will cover all four universal service programs
• Less burdensome on beneficiaries
o PQA assessments are not audits
o No on-site activities required
o Document production requires hours, not days or weeks
• PQA designed only to calculate estimated improper payment rates, not to assess overall
compliance with program rules
• Much lower administrative cost to gather more meaningful results than full-scale audits
• More reliable, statistically valid data about rates of improper payments
Timing
• USAC has tested PQA procedures and process with volunteer beneficiaries
• Conducted numerous sessions to fine-tune communication process
• The PQA Program started during the summer of 2010
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