Schools and Libraries
About the Schools and Libraries Program:
- Overview of the Program
- Overview of the Process
- Outreach and Training
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- Understanding Audits
Schools and Libraries Tools:
Beneficiary Audits - Auditors' Observations - IPIA
The 155 Improper Payments Information Act (IPIA) audits focused on individual Funding Request Numbers (FRNs).
Following is a list of the most common auditors’ observations from the 155 audits conducted for Funding Years 2002 through 2004.
Documentation of discounts
- Entities did not retain documentation to support the student count and National School Lunch Program (NSLP) data as indicated on the FCC Form 471, Description of Services Ordered and Certification Form.
- Discrepancies existed in the total student and/or NSLP student count.
Entity eligibility
- Entities receiving services were not listed on the Form 471.
- Entities receiving services were not eligible under Schools and Libraries Program (Program) rules.
Equipment and services
- Entities transferred equipment in violation of Program rules.
- Equipment disposal policy was inconsistent with Program rules.
- Equipment was not installed.
- Equipment could not be located.
- The applicant was unable to make effective use of the discounted services.
- Services were ineligible.
- Services were substituted without authorization from USAC.
Payments
- Invoices from the service provider did not list the details of equipment and services provided.
- Invoice documentation was not available.
- USAC was invoiced in excess of the amount billed to Billed Entity Number (BEN).
- Entities did not perform a reconciliation of eligible amounts billed to them by service providers to the requested reimbursement amounts on the FCC Forms 474, Service Provider Invoice (SPI) Form.
- FCC Form 472, Billed Entity Applicant Reimbursement (BEAR) Form, payment from service provider remitted to applicant after the deadline.
- The non-discount portion of the cost of services provided was not paid.
Entity not listed on Form 471
- Entities received discounted services at locations that were not listed on the Form 471.
Children’s Internet Protection Act (CIPA) violation
- Internet safety policies failed to meet CIPA requirements.
Asset listing either not maintained or not updated
- Asset listing did not reflect the transfer of equipment from one location to another.
- Entities did not maintain a comprehensive asset listing which included the model, location, installation date, and equipment identification number.
- Equipment was installed at locations other than those specified in the asset listing.
Other issues
- Entities did not retain documentation of compliance with competitive bidding requirements.
- Entities did not retain a copy of the Technology Plan approval letter.
- Consortium was missing Letters of Agency (LOA).
- Entities filed the FCC Form 470, Description of Services Requested and Certification Form, when it was not necessary.
- Entities filed the Form 471 before entering into a contract with the service provider.
- Entities did not have a document retention policy.
- Entities did not follow their document retention policies.
