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Tuesday, October 18, 2016

Expand the audits!

You know I hate audits, but today I'm going to call for more audits.  Or at least broader audits.  Hear me out, and I think you'll agree.

It all goes back to the Improper Payments Information Act, which is the source of the random audits.  The purpose of the act is to identify improper payments with an eye towards reducing improper payments.  What is an "improper payment"?
The term ‘‘improper payment’’—
(A) means any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements....
The current IPIA audits certainly identify overpayments, but I'm not aware of any checks on underpayments.  I'd like to see some audits of invoices that have been "passed zero" or reduced, to make sure that no underpayment took place.

And while we're at it, let's have some audits of FRNs denied or reduced by PIA.  Because the IPIA says:
The term ‘‘payment’’ means any payment (including a commitment for future payment...).
I'm not a lawyer, but that looks to me like a Funding Commitment Decision Letter is a payment.  (Isn't that why the FCDL triggers the ADA?)

A bright IDER

OK, now it's time to save everybody some work.  The total failure of the 498 process and the difficulties in issuing PINs are making it impossible for a lot of applicants to get FY 2015-2016 BEARs in on time.  This was obvious in September, and was pointed out to the FCC and USAC at the DC training.

But I understand why we haven't yet seen an automatic invoice deadline extension of all 2015-2016 FRNs.  The FCC and USAC are afraid that as soon as they give an extension, applicants will take their feet off the accelerator.  It makes sense in a "our convenience is more important than properly disbursing funds" kind of way to keep applicants fearful of missing that deadline for as long as possible.

But now, it's time to give the extension.  Starting this week, applicants will begin flooding USAC with extension requests, which will automatically be granted.  Why not save everybody some paperwork and just grant the extensions now?  USAC is clearly overwhelmed, so let's not add a raft of extension requests to their plate.