At times, USAC may conduct post-commitment funding reviews which may include Program Integrity Assurance (PIA) reviews, audits, invoice reviews, appeal reviews, and other investigations (such as whistleblower alerts). As a result of these reviews, USAC may discover that certain funds were committed in error. The FCC requires USAC to rescind such commitments and recover funding that may have been improperly disbursed. USAC refers to this process as the "Commitment Adjustment" or "COMAD" process.
If a COMAD is necessary, USAC will provide both the applicant and the service provider with a Commitment Adjustment Letter containing a Funding Commitment Report which lists the Funding Request Number(s) (FRNs), FCC Form 471 Application Number, Billed Entity Number (BEN), and Service Provider Identification Number (SPIN) affected by the COMAD. Decisions on COMADs can be appealed and appeal information is included in the letter.
If the amount of funds disbursed to date exceeds the adjusted funding commitment amount, FCC rules require USAC to recover the funds disbursed in error. In these cases, USAC will send a letter to the responsible party (service provider, applicant, or both) describing the process for recovering those funds. USAC will send a copy of the letter to the party who is not responsible, when applicable. This letter will include an explanation of the options available for USAC to recover the funds disbursed in error. Future communications from USAC concerning the COMAD are tailored to the response(s) received.
If the amount of funds disbursed to date is less than the adjusted funding commitment amount, USAC will continue to process valid invoices up to the adjusted funding commitment amount. In general, if funds need to be recovered, USAC will seek recovery from the responsible party.
When USAC discovers that funds were disbursed in error but the decision to commit the funds was correct, such as invoicing USAC for ineligible products/services, USAC will seek recovery of the improperly disbursed funds (RIDF). The commitment may not be adjusted when a RIDF is determined. Once the improperly disbursed funds are returned to USAC, USAC will pay valid invoices submitted for that FRN.
To ensure the highest level of program integrity, USAC operates the Beneficiary and Contributor Audit Program (BCAP) and Payment Quality Assurance (PQA) Program. USAC may discover funds were committed in error and/or funds were improperly disbursed during an audit or assessment. The auditor may recommend recovery and/or commitment adjustment. USAC will contact the responsible party to begin the COMAD process.