10. Audits
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How To Prepare For The Audit
Follow All E-rate Rules
Document, Document, Document! – Plan ahead for an audit by documenting every step of the process USAC Compliance Documentation Checklist for audits
– http://www.usac.org/sl/about/audits/documentationchecklist.aspx – http://www.usac.org/sl/about/trainingpresentations/training-2007/fall/2007-fall-trainingpresentation.aspx (divider labels)
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Prepare for the Audit Technology Plan Documentation
Copy of Technology Plan that covers entire year being audited Proof of approval of Technology Plan Supplemental Budget analysis (if using EETT Plan) • Summary of the technology environment and a high-level network diagram
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Preparing For The Audit Bidding Documentation
Copy of State and Local procurement policies Form 470 and any RFPs used Copy of all bids received (winning and losing) Bid evaluations Notice of Award to winning vendor –Copy of any change orders
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Preparing For The Audit Invoicing Documentation
Proof of payment to service providers Copies of warrants and cancelled checks Copies of BEAR Forms and supporting service provider invoices (if applicable) Reconciliation by FRN of service provider invoices to BEARs submitted to SLD
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Preparing For The Audit Other Documentation
Eligible Services List for year being audited Reports from any other audits conducted that relate to either E-rate program or the NSLP Financial statements and annual budgets Supporting worksheets for the discount calculation (see notes)
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Preparing For The Audit Other Documentation SPIN change requests including copy of notice to original service provider ALL communication regarding E-Rate –Service Providers –SLD/USAC
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Preparing For The Audit CIPA Documentation
Internet safety policy –Local governing board adoption of the Internet safety policy The date and a copy of the minutes of the public hearing regarding the Internet safety policy [Local Board adopted policy] Copies of Forms 479 and/or Forms 486, if applicable
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• Documentation – Other services necessary to make effective use of E-rate discounts, such as • Training • End user equipment – Equipment purchased using E-Rate • Vendor invoice • SLD Invoice • Serial Number • Physical location
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Preparing For The Audit Services
Preparing For The Audit The E-Rate Team
Description of the E-rate team, their roles and responsibilities –staff –vendors –consultants –For consortia, letters of agency
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Who Should Be Available
Person who – filed the E-rate forms – managed the bidding and award process – reviewed and approved invoices – prepared E-rate invoices – is responsible for budget (CBO) – is knowledgeable about the network and the location of equipment
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Appeals
• Submitted to USAC if you feel program rules were not upheld by the denial of funds • Submitted to FCC if you are questioning the existing program rules
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USAC Appeals – Approved for Limited Circumstances
• When the appeal makes it clear that USAC erred in its initial review • When the applicant provides USAC with information it did not provide when the original request was made • When USAC obtains policy clarification or new policies that impact the original decision • http://www.usac.org/sl/about/appeals/appealsguidelines.aspx
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