PIA Review Process
Overview of the PIA Review
Process
Program Integrity Assurance (PIA) is the process used by USAC to review
applications for compliance with program rules and policies. During this
process, USAC reviews the information on your Form 471 and may contact you with
additional questions on specific items.
The review process has two components:
- Initial Review, which includes a Services Review
- Final Review, which includes a Quality Assurance (QA) review process as an
additional check on the work done during Initial Review
Initial Review
After your Form 471 has been assigned to an initial reviewer, the initial
reviewer prepares the questions that USAC must ask based on the information you
provided (or did not provide) on your application. In a limited number of cases,
the information on the Form 471 is sufficient to complete the review without
applicant contact. In most cases, USAC must request more information.
Once the questions have been prepared, the initial reviewer contacts you
using your preferred mode of contact.
-
If your preferred mode of contact is email or fax, the initial reviewer‚s
first contact is the email message or fax containing the list of questions that
require a response.
-
If your preferred mode is telephone, the initial reviewer will call you and
ask for your email address or fax number, and will then email or fax you the
list of questions.
-
In all cases, USAC provides written questions and asks for written
responses to those questions.
In general, you have 15 days from the date of the email or fax to provide
responses to USAC's questions. (For more information on the specific summer and
winter periods when this procedure is modified, refer to the Deadlines
for Information Requests guidance on the USAC website.)
-
If USAC has not received a response after seven days, USAC sends you a
reminder and forwards a copy of the reminder to your state E-rate
coordinator.
-
If USAC does not receive a response after 15 days, USAC will continue to
process your application with the information on hand, which may lead to a
modification or denial of funding.
The Services Review is based on the information you provided
in the Item 21 Attachment. During the Services Review, the initial reviewer
verifies the eligibility of the products and services requested and the accuracy
of the amounts in the funding request. If the initial reviewer has questions
that cannot be answered with existing information, those questions will be
included in the Initial Review list of questions. However, USAC may also ask
additional questions later.
You always have the following options:
- You can ask for clarification. If you don't understand one
or more questions, ask your initial reviewer what the question means or what
information USAC expects in your response.
- You can ask for more time to respond. USAC can grant a
limited extension of time to respond to questions. However, if you ask for more
time, your initial reviewer will set aside your application and start other
reviews while you work on your response, so he or she may not be able to return
to your application quickly once you provide the information.
- You can ask to speak with a manager. If you feel that you
are not communicating successfully with your initial reviewer, please ask to
speak to a manager. You will not be penalized if you make this request, and the
manager can help you understand the questions USAC is asking and the responses
USAC expects to receive.
Initial Review modifications and denials
Once Initial Review has been completed, the initial reviewer may recommend
that a funding request be modified or denied based on the information supplied
during the review. Some examples of modifications are:
- Removal of ineligible products and services
- Removal of ineligible recipients of service
- Reduction in number of months of service
If the initial reviewer concludes that a funding request should be modified
or denied, you will be contacted. The initial reviewer will inform you of the
result of the review and give you an opportunity to provide additional
information if you disagree with the conclusion. (If you agree with the initial
reviewer's determination, you do not have to provide a response.) This
additional information will be reviewed as well before the Initial Review
process is finished.
Final Review
Final Review is a review by USAC of the work done during Initial Review. Each
step of the Initial Review process is itself reviewed by a final reviewer to
verify that the correct procedures were followed, the appropriate questions were
asked, and complete answers were received. If the final reviewer has a concern
about any part of the Initial Review process, the application is returned to the
initial reviewer for follow-up work.
The result of this process is that you may be contacted after your Initial
Review with what may appear to be additional or repetitive questions. If the
questions you are being asked seem new or repetitive, there are two likely
explanations:
- Your initial reviewer is no longer with USAC, and the new initial reviewer
assigned to complete the review may need additional information.
- Your answer to the original question was not complete.
In both cases, make sure you understand what information is being requested
and provide the information as quickly and accurately as possible.
The Quality Assurance (QA) process is a second level of
review to verify that all parts of the review were done correctly. A much
smaller number of applications go through the QA process. Again, applications
that undergo QA review may be returned to the initial reviewer for
follow-up.
It is important to understand that the review process is not linear. At any
point during the process, an application can be returned to an earlier stage
because of work that was not completed correctly or information that is missing.
If you are following the progress of your application using the Form
471 Application Status Tool, do not be alarmed if your application seems to
move „backward‰ ˆ that is, to an earlier status. If you do see such a movement,
monitor your preferred mode of contact carefully in case an initial reviewer
attempts to contact you.
In summary, to be prepared for PIA review, be sure to do the following:
- Check your Form 471 and your Receipt
Acknowledgment Letter (RAL) to make sure all of your entries are correct. If
you find a mistake, submit a RAL correction by following the instructions in the
RAL.
- If you have not already done so, submit your Item 21 Attachment. You can
file online, by email, by fax, or on paper by following the Item
21 Attachment guidance on the USAC website.
- Organize all of the documentation related to your application and have it
readily available to assist you in answering any questions.
- Monitor your preferred mode of contact so that you will know when PIA
attempts to contact you.
- Answer all questions promptly and completely.
- Ask for more time to respond if you need it.
- If you are having problems, ask to speak to a manager.
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