The Time to Prepare for a USAC Audit Starts Now


With increased frequency and vigor, the FCC is enforcing its most onerous and potentially costly regulations — those pertaining to Universal Service Fund (“USF”) contributions. And the FCC’s preferred method of enforcement is none other than USAC Audits.  If you are concerned about your company’s FCC Form 499 / USF compliance profile and want to achieve greater peace of mind, contact The CommLaw Group today and inquire about our USAC Compliance, Audit Preparation and Defense Practice.

Through both formal Audits and informal Desk Reviews, USAC (the Universal Service Fund administrator) will exhaustively evaluate your company’s compliance with a myriad of accounting, jurisdictionalization and revenue reporting rules emanating from the ever-changing regulatory landscape.  USAC and the FCC conduct such inquiries based on the year-end “True-Up” revenue report, also known as the FCC Form 499-A (due April 1, 2013).  With the reporting deadline fast approaching and less than 12 months to identify errors and make corrections, it’s never too early to begin the process of evaluating your company’s compliance profile; especially when you consider that upon receipt of a USAC audit notice, your company is expected to respond and demonstrate compliance within one to two weeks.  So if your “Books and Records” are not quite up to snuff, you will have very little time to polish them up before USAC auditors begin their examination.  Without any limitations period on USAC’s ability and willingness to look back in time to idenfiy under-reported revenue and missing contributions, the stakes are incredibly high.

The increasingly complex regulatory environment is making it imperative for communications companies to stay abreast of changing regulatory compliance requirements.  Last year was no exception, as the FCC continued to clarify, expand and enhance its enforcement of regulations specifically targeting the Universal Service Fund (“USF”) program.  Failure to keep up with the myriad changes emanating from the FCC can cause internal accounting, billing and revenue reporting systems to lapse, potentially resulting in non-compliance with both federal and state regulatory requirements. The FCC is increasingly re-directing regulatory subsidies and stimulus programs to high-speed broadband/data services in lieu of legacy voice telecommunications services. With new or changing regulation also comes increasingly complex revenue reporting and heightened regulatory scrutiny. More stringent accountability standards mean communications companies across all tiers are expected to enhance their control, monitoring, reporting and compliance capabilities.  Communications enterprises need assistance in assessing and optimizing their regulatory compliance activities in the current and future environment.

The CommLaw Group’s Telecommunications Regulatory Compliance professionals can help your communications organization comply with applicable FCC and state regulatory requirements.

Our services include:

  • Performing or helping you prepare for regulatory compliance audits
  • Enhancing regulatory processes and controls
  • Improving regulatory processes to help drive revenue enhancement and cost optimization while maintaining compliance
  • Assisting you in the regulatory revenue record to report process, including the proper identification and allocation of revenues and costs to appropriate categories and jurisdictions
  • Assisting you with regulatory and revenue-related filings, disputes, settlements and contract issues

Potential Benefits of Working Us

Clients that have worked with The CommLaw Group have reported numerous benefits from our services, including:

  • Reduced risk of regulatory non-compliance, limiting fines and penalties and regulatory audit exposure
  • Potential reductions in federal USF contributions, resulting in increased net income and/or reduced customer billings
  • Increased effectiveness and efficiency of regulatory reporting process
  • Enhanced awareness of regulatory changes and related business implications/risks
  • Enhanced preparation for compliance audits from regulatory agencies and third-parties with minimal disruption to normal operations
  • Automation of regulatory processes with appropriate controls, enabling continuous monitoring of regulatory compliance and timely reporting

Do You Need a USF Compliance Review?

To determine whether The CommLaw Group’s Telecommunications Regulatory Compliance professionals can help your communications organization comply with applicable FCC and state regulatory requirements, ask yourself the following questions.

  • Do you have a formal process to assess risk related to current regulations and pending regulatory changes?
  • Do you offer bundled services to customers involving wireline, wireless, voice and data services offered by multiple affiliates and/or technologies?
  • Are extensive manual adjustments and/or reconciliations required when preparing regulatory reports?
  • Are regulatory reports prepared consistently across jurisdictions and affiliated entities?
  • Are you currently subject to regulatory-mandated compliance audits at the federal or state level?

For more information about The CommLaw Group’s Regulatory Compliance Reviews for Telecommunications Providers, please contact:

Jonathan S. Marashlian, Managing Partner

Tel: (703) 714-1313


ATTORNEY ADVERTISING DISCLAIMER: This information may be considered advertising in some jurisdictions under the applicable law and ethical rules. The determination of the need for legal services and the choice of a lawyer are extremely important decisions and should not be based solely upon advertisements or self-proclaimed expertise. No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers

Sign Up To Receive Our
Advisories and Compliance Alerts

Sign up for our email list to receive notifications regarding new advisories and news