USAC Audit Survival Guide for USF Contributors


Are you worried about being audited by the Universal Service Administrative Company (USAC)? 

The primary purpose of a USAC audit is to ensure compliance with Federal Communications Commission (FCC) rules, FCC orders, and the FCC Form 499-A Instructions. Many (but not all) USAC audits are randomly selected.  According to USAC’s own website, the audit selection process is designed to produce a sample of auditees that can vary widely in size and revenue type.  What this means is that no company is considered “safe” or out of the line of fire based on its small size or lack of revenue. 

If you’re concerned, please contact us.  The CommLaw Group has the knowledge, experienced professionals, and a variety of tools to help!

The CommLaw Group’s Guide to Surviving a USAC Audit

As we discuss in our Primer on USAC Audits & FCC Appeals, once USAC opens up an audit of your company, there is a high degree of likelihood the audit will conclude without some adverse and costly audit decisions.  Often times, negative outcomes are pre-ordained due to USAC’s tendency to interpret and apply FCC rules and precedent broadly, and with the goal of capturing more USF-assessable revenue.  Once an audit decision is final, aggrieved companies must weigh the costs, benefits, likelihood of success and, importantly, the length of time and uncertainty of the Audit Appeals process.  As detailed in the linked Primer, the deck is heavily stacked against the industry and in favor of the Government. 

Our Firm recommends performing a pre-audit compliance & revenue reporting optimization review to arm your company with the facts and options:  (1) facts about the likely outcome of a USAC audit resulting from existing policies & practices and (2) options to mitigate exposure, thus reducing the financial impact and impositions in the event of an audit. 

Do You Need a USF Compliance Review?  Could Your Company Benefit by Performing a Pre-Audit Review?

To determine whether The CommLaw Group can help your communications organization comply with applicable FCC and state regulatory requirements, ask yourself the following question.

  • Do you have internal controls in place related to your Form 499 reporting?
  • Do you have coordination between your accounting and reporting teams?
  • 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???          

If you are concerned about your compliance or, perhaps, looking to gain a competitive edge by ensuring your company is not over-reporting USF-assessable revenue, please contact Jonathan S. Marashlian at or by phone: 703-714-1313.  Learn more about our USAC Compliance, Audit Preparation and Defense practice.

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

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