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Internal Control

Material Source:Net foregin periodicals Author:Brian Hd

“I wouldn’t be surprised if the next step were to get some pricing

information,” said Colleen Boothby, executive director of the Ad Hoc

Telecommunications Users Committee. She also predicted a notice of proposed

rulemaking that proposes more specific rule changes, perhaps in the second half

of 2011.

Harold Feld, legal director of Public Knowledge, said he was “pleased that the

FCC is moving ahead with a targeted data request to find the facts from a very

distorted special access market that is overcharging business customers by an

estimated $10 billion. The nature of the request encourages us to believe that the

FCC is closing in on the key issues, and will be able to propose needed changes to

promote competition and lower prices sooner rather than later.

“We note that while the request is voluntary at this point, the FCC has the

power to compel full and honest responses,” Mr. Feld added. “We expect the FCC

will use that authority if it doesn’t receive the information it needs.”

Larissa Herda, tw telecom, inc.’s chief executive of- ficer, applauded the

FCC’s action. “A healthy wholesale broadband market is the critical tool

businesses need in order to take advantage of the communications technol- ogy

that will allow them to be more efficient and produc- tive in the global economy,”

she said.

Sprint Nextel Corp. commended the FCC for its data request. “Today’s

announcement by the Federal Com- munications Commission that it is issuing a

request for data about the special access market is an important mile- stone in the

Commission’s efforts to fix this broken mar- ket,” said John Taylor, a spokesman for

the carrier. “Sprint has repeatedly indicated that it will provide the data the FCC

needs to make a fact-based, data driven decision in this docket. Because the

nation’s broadband economy depends upon these special access circuits, it is

essential that the Commission get accurate and timely data from both purchasers

2 and sellers of special access.”

Meanwhile, Walter McCormick, president and chief executive officer of

USTelecom, said, “Obtaining com- prehensive data from all service providers is

essential to a fully informed rulemaking process, and to the integrity of agency

decision making. We applaud the Commission for the breadth of its data request.

Our members intend to participate fully and we would hope that all other ser- vice

providers in the special access marketplace do so as well.”

The Government Accountability Office released a report late last month that

calls on the FCC to conduct a risk assessment of the E-rate program, saying

the program’s current internal control structure that was largely instituted by

the Universal Service Administra- tive Company may not properly consider

program risks.

Noting that USAC’s application review process for E-rate is made up of a

number of different types and lev- els of review, the GAO stated it was not clear

that such a model was “effectively and efficiently targeting resources to risks.”

Additionally, the report said controls were not in place to check the accuracy of

USAC’s automated in- voice review process.

“While USAC has expanded and adjusted its inter- nal control procedures, it

has never conducted a robust risk assessment of the E-rate program’s core

processes, although it has conducted risk assessments for other pur- poses, such as

financial reporting,” the GAO wrote. “A risk assessment involving a critical

examination of the entire E-rate program could help determine whether

modifications to business practices and the internal con- trol structure are needed

to appropriately address the risks identified and better align program resources

to risks.”

The report noted that of the 64 fund recipients that were audited more than

once over a three-year period,

36 were cited again in a subsequent audit for violating the same rules.

The agency said the current beneficiary audit pro- cess lacks “documented

and approved” policies and meth- ods. “Without such policies and procedures,

management may not have the assurance that control activities are appropriate

and properly applied,” GAO wrote. “Docu- mented and approved policies and

procedures could con- tribute positively to a systematic process for considering

beneficiary audit findings when assessing the E-rate program’s internal controls