HomeMy WebLinkAbout20170814Boomerang Wireless FCC Biennial Report.pdfA\
WIRELESS
I il ' l;r ili i' ,_;
August 2,2017
ldaho Public Utilities Commission
P.O. Box 83720
Boise, lD 8372O-OO74
RE: Docket No. GNR-T-L7-OL - FCC Biennial Report filed on behalf of Boomerang Wireless, LLC dlbla
enTouch Wireless
Dear Staff,
Boomerang Wireless, LLC has filed the biennial audit report with the FCC and USAC which is the report
issued by the independent CPA firm, Curtis, Blakely & Co., PC, regarding the biennial audit
corresponding to the calendar year 2015. Please find attached a copy of the Final Biennial Audit report.
lf you have any questions regarding this filing, please contact me at (319) 294-6080 or
regulatorv@ ento uchwireless.com
Respectfully su
Jul Carter
Compliance Officerlatory &
Boomerang Wireless, LLC d/b/a enTouch Wireless
'1
HIAWATHA, IOWA
INDEPENDENT ACCOUNTANT'S REPORT
ON APPLYING AGREED-UPON PROCEDURES
For the Year Ended December 31, 2015
PC
Independent Accountant' s Report
On Applying Agreed-Upon Procedures
Boomerang Wireless, LLC
For the Year Ended December 31,2015
To the Management of Boomerang Wireless,LLC, the Universal Service Administrative Company (USAC), and
the Federal Communications Commission (FCC or Commission) (the responsible and specified parties):
We have performed the procedures enumerated in Attachment A, which were agreed to by the FCC's Wireline
Competition Bureau @ureau) and Office of Managing Director (OMD) in the Lifeline Biennial Audit Plan or as
otherwise directed by the Bureau, solely to assist you in evaluating Boomerang Wireless, LLC's compliance with
certain regulations and orders governing the Low Income Support Mechanism (also known as the Lifeline Program) of
the Universal Service Fund, set forth in 47 C.F.R. Part 54, as well as other program requirements, including any state-
mandated Lifeline requirements (collectively, the Rules) detailed in the Lifeline Biennial Audit Plan for the calendar
year ended December 31,2015. Boomerang Wireless, LLC's management is responsible for compliance with the
Rules. This agreed-upon procedures engagement was conducted in accordance with attestation standards established
by the American Institute of Certified Public Accountants and Generally Accepted Government Auditing Standards
(GAGAS) issued by the Govemment Accountability Offrce (2011 Revision). The sufficiency of these procedures is
solely the responsibility of the Bureau and OMD. Consequently, we make no representation regarding the sufficiency
of the procedures described in Attachment A either for the purpose for which this report has been requested or for any
other purpose.
Specific procedures and related results are enumerated in Attachment A to this report. In compliance with the
Lifeline Biennial Audit Plan, this report does not contain any personally identifiable information or individually
identifi able customer proprietary network information.
No limitations were imposed on us by Boomerang Wireless, LLC or any other affiliate of Boomerang Wireless,
LLC that would affect our findings.
We were not engaged to, and did not, conduct an examination of the subject matter, the objective of which would be
the expression of an opinion on Boomerang Wireless, LLC's compliance with the Rules. Accordingly, we do not
express such an opinion. Had we performed additional procedures, other matters might have come to our attention that
would have been reported to you.
The puqpose of this report is solely to assist the management of Boomerang Wireless, LLC, USAC, and the FCC (the
responsible and specified parties) in evaluating Boomerang Wireless, LLC's compliance with certain regulations and
orders goveming the Lifeline Program, and is not suitable for any other purpose. This report becomes a matter of the
public record upon filing of the final report with the FCC. The final report is not confidential.
U" U4rG)Pc,
Curtis Blakely & Co., P.C.
Longview, Texas
July 26,2017
P.O. Box 5486 r Longview, Texas 75608 o 903.758.0734 r Fax: 903.758.0756 o www.cbandco.com
2403 Judson Road I Longview, Texas 75605
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
Attachment A enumerates the agreed-upon procedures for Boomerang Wireless, LLC, the associated
results, and any management responses obtained in relation to the exceptions identified.
Obiective I: Carrier Obligation to Offer Lifeline. To determine if Boomerang Wireless, LLC has
procedures in place to make Lifeline services available to qualifying low-income consumers with
mandated disclosures regarding requirements to participate in the Lifeline program, and procedures
for de-enrolling subscribers when they are no longer eligible to receive Lifeline services.
Procedure I
We inquired of Boomerang Wireless, LLC's management and obtained Boomerang Wireless, LLC's
policies and procedures in response to Item 4 of Appendix A (Requested Documents) of the Lifeline Biennial
Audit Plan for offering Lifeline service to qualifying low-income consumers.
We examined Boomerang Wireless, LLC's policies and procedures, and compared those policies and
procedures, as well as management's responses to the inquiries, to the Commission's Lifeline rules set forth
in Appendix F of the Lifeline Biennial Audit Plan.
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures, management's
responses to the inquiries, and the Commission's Lifeline rules.
No exceptions were noted.
Procedure 2
We inspected 10 examples of Boomerang Wireless, LLC's marketing materials describing the Lifeline
service (i.e., print, audio, video and web materials used to describe or enroll in the Lifeline service offering,
including application and certification forms), as provided in response to Items 4,6 and 7 of Appendix A of
the Lifeline Biennial Audit Plan. We examined the examples to determine if they included the following:
a.
b.
c.
d.
e.
The service is a Lifeline service, which is a government assistance program;
The service is non-transferable;
Only eligible subscribers may enroll;
Only one Lifeline discount is allowed per household; and
The eligible telecommunications carrier (ETC)'s name or any brand names used to market
the service.
We noted the inspected marketing materials contained the required information.
No exceptions were noted.
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Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
Procedure 3
a. We reviewed the carrier's responses to the background questionnaire regarding the carrier's
policies for (1) how subscribers notify the carrier of the subscriber's intent to cancel service or
give notification that s/he is no longer eligible to receive Lifeline service and (2) when de-
enrollment for such notifications occurs. We verify these policies are designed to (l) allow
subscribers to make the notifications required by 47 C.F.R. $$ 54.410(d)(3XiD and (iv) and (2)
prevent the carrier from claiming ineligible subscribers on the FCC Form 497 or subscribers who
wish to cancel service.
No exceptions were noted.
b. In addition, we called the customer care numbers provided in response to Item 8 of Appendix A,
as well as any customer care numbers identified in the marketing materials provided in response
to Item 6 of Appendix A, or on the websites provided in response to Item 7 of Appendix A.
No exceptions were noted.
Procedure 4
We inspected applicable policies and procedures regarding de-enrollment from the program, including when
Boomerang Wireless, LLC will de-enroll subscribers based on lack of eligibility, duplicative support, non-
usage, and failure to recertiff, as further described below.
a.We inspected Boomerang Wireless, LLC's policy and procedures for de-enrollment where
Boomerang Wireless, LLC has information indicating that a Lifeline subscriber no longer
meets the criteria to be considered a qualifying low-income consumer under 47 C.F.R.
$54.409, as provided in response to Item 4 of Appendix A. We noted whether the policy and
procedures detail the process for communications between the subscriber and Boomerang
Wireless, LLC regarding de-enrollment, including, but not limited to: (1) notiffing subscribers
of impending termination of service; (2) allowing subscriber to demonstrate continued
eligibility; and (3) termination of service for failure to demonstrate eligibility.
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures,
management's responses to the inquiries, and the Commission's Lifeline rules pertaining to de-
enrollment for no longer meeting criteria of a qualifying low-income consumer.
No exceptions were noted.
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Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
b We inspected Boomerang Wireless, LLC's policies and procedures for de-enrolling subscribers
that are receiving Lifeline service from another ETC or where more than one member of a
subscriber's household is receiving Lifeline service (duplicative support). We noted if the
policy and procedures state that Boomerang Wireless, LLC will de-enroll subscribers within
five business days of receiving notification from USAC program management that a subscriber
or a subscriber's household is receiving duplicative Lifeline support, as required by
$5a.a05(e)(2) of the Commission's rules.
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures,
management's responses to the inquiries, and the Commission's Lifeline rules pertaining to de-
enrollment for subscribers that are receiving Lifeline service from another ETC or where more
than one member of a subscriber's household is receiving Lifeline service (duplicative
support).
No exceptions were noted.
c.We inspected Boomerang Wireless, LLC's policies and procedures for de-enrolling subscribers
for non-usage (i.e., where a Lifeline subscriber fails to use Lifeline service for 60 consecutive
days), including the process of how Boomerang Wireless, LLC monitors and identifies
subscribers who are non-users of Lifeline service but enrolled in the program, as well as non-
usage termination notifications provided in response to ltem 18 of Appendix A. We examined
the policy and procedures and non-usage termination notifications to veri$ if the termination
notifications explain that the subscriber has 30 days following the date of the impending
termination notification to use the Lifeline service.
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures,
management's responses to the inquiries, and the Commission's Lifeline rules pertaining to de-
enrolling subscribers for non-usage (i.e., where a Lifeline subscriber fails to use Lifeline service
for 60 consecutive days). We noted that the non-usage termination notification template
complies with section 54.405(e)(3) of the Commission's Rules.
No exceptions were noted.
d. We reviewed Boomerang Wireless, LLC's policy and procedures for de-enrolling a Lifeline
subscriber that does not respond to Boomerang Wireless, LLC's attempts to obtain
recertification, as part of the annual eligibility recertification process, as well recertification
requests provided in response to Item 19 of Appendix A. We examined the policy and
procedures and recertification requests to veriff if the communications explain that the
subscriber has 30 days following the date of the notice to demonstrate continued eligibility or
the carrier will terminate the subscriber's Lifeline service. In addition, we examined the
recertification requests and the carrier's responses to the background questionnaire and
verified that the recertification requests were sent by a method separate from the subscriber's
bill (if a customer receives a bill from the carrier).
@Page 5 of 13
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures,
management's responses to the inquiries, and the Commission's Lifeline rules pertaining to de-
enrolling subscribers that do not respond to attempts to recertify. We noted the inspected notice
of impending de-enrollment template and other communications contained the information
required by section 54.405(e)(a) of the Commission's rules and that the communications were
sent by a method separate from the subscriber's bill.
No exceptions were noted.
Obiective II: Consumer Qualification for Lifeline. To determine if Boomerang Wireless, LLC has
procedures in place to limit Lifeline service to qualifying low-income consumers and ensure that
Lifeline service is limited to a single subscription per household.
Procedure I
We inquired of management and obtained Boomerang Wireless, LLC's policies and procedures for limiting
Lifeline support to a single subscription per household as provided by Boomerang Wireless, LLC in
response to Item 4 of Appendix A. We examined the policies and procedures. We compared management
responses and Boomerang Wireless, LLC's policies and procedures with the Commission's Lifeline rules
set forth in $54.409(c) (Appendix F).
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures for limiting
Lifeline support to a single subscription per household, management's responses to the inquiries, and the
Commission's Lifeline rules.
No exceptions were noted.
Procedure 2
We reviewed procedures Boomerang Wireless, LLC has in place to ensure it has accurately completed the
FCC Form 497 including inquiries of management to describe the process for completing the FCC Form 497.
The procedures or process should include the following:
. The position title of the person responsible for obtaining data for the FCC Form 497;
o The process for determining which subscribers should be included monthly in the FCC Form 497,
including cut-off and billing cycle dates, and only those subscribers active as of the start or end of
the month;
o That a corporate officer signature is required for the FCC Form 497;o That a verification process exists to perform an independent review; that is, the person reviewing or
validating the form's data is different from the person completing the form;
o The billing system name used to generate completion of the form; and
. If applicable, describe the process for completing the Tribal Link Up portions of the FCC Form 497.
The inspected procedures for accurately completing the FCC Form 497 contained the required information.
No exceptions were noted.
@Page 6 of 13
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
Procedure 3
We obtained the Subscriber List in response to Item I of Appendix A and obtained Boomerang Wireless,
LLC's FCC Form a97$) for each study area in the selected states (Arizona, Minnesota, and North Dakota
for September,2015. We examined the number of subscribers claimed on the Form(s) 497 and compared
to the number of subscribers contained on the Subscriber List for each study area noting all were in
agreement.
No exceptions were noted.
Procedure 4
Using Microsoft Excel data sorting and conditional formatting functions, we examined the Subscriber List
and noted if there were any duplicate addresses with different subscribers. We then created a sample list
reflecting these results. This list was then used in Procedure 5.
Procedure 5
From the list completed in Procedure 4 above, we randomly selected 30 subscribers and requested copies
from Boomerang Wireless, LLC of the one-per-household certification form or the original Lifeline
certification form, for each of the selected subscribers. Because subscribers must only complete a one-per-
household certification form if existing Lifeline recipients reside at the same address, the selected
subscribers were not the first subscribers residing at the address based on the Lifeline start date in the
subscriber listing. We verified that the selected subscribers certified to only receiving one Lifeline-
supported service in his/her household using the one-per household worksheet or the original Lifeline
certification form, unless they were the first subscriber in the household. There were no missing or
incomplete certifications and the forms examined included requirements a - d of Attachment A, Objective
II, Procedure 5.
No exceptions were noted.
Obiective III: Subscriber Eligibility Determination and Certification. To determine if Boomerang
Wireless, LLC implemented policies and procedures for ensuring that their Lifeline subscribers are
eligible to receive Lifeline seruices.
Procedure I
We inquired of management and obtained carrier policies and procedures for ensuring that its Lifeline
subscribers are eligible to receive Lifeline services as provided by Boomerang Wireless, LLC in response
to Item 4 of Appendix A. We examined the policies and procedures. We compared management responses
and carrier policies and procedures with the Commission's Lifeline rules set forth in $54.410 (Appendix F).
@Page 7 of l3
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures, management's
responses to the inquiries, and the Commission's Lifeline rules pertaining to ensuring that Boomerang
Wireless, LLC's Lifeline subscribers are eligible to receive Lifeline services.
No exceptions were noted.
a. We inspected Boomerang Wireless, LLC's policies looking for evidence as to whether they
include a policy that Boomerang Wireless, LLC does not retain copies of subscribers' proof of
income or program based eligibility.
We noted Boomerang Wireless, LLC does have a policy to not retain copies of subscribers' proof
of income or program based eligibility.
No exceptions were noted.
b. We inspected Boomerang Wireless, LLC's policies looking for evidence as to whether they
include a policy or procedure that Boomerang Wireless, LLC must fully veriff the eligibility of
each low-income consumer prior to providing Lifeline service to that consumer, and that
Boomerang Wireless, LLC or its agents may not provide the consumer with an activated device
intended to enable access to Lifeline service until that consumer's eligibility is fully verified and
all other necessary enrollment steps have been completed.
We noted Boomerang Wireless, LLC does have a policy that Boomerang Wireless, LLC must
fully verify the eligibility of each low-income consumer prior to providing Lifeline service to
that consumer, and that Boomerang Wireless, LLC or its agents may not provide the consumer
with an activated device intended to enable access to Lifeline service until that consumer's
eligibility is fully verified and all other necessary enrollment steps have been completed.
No exceptions were noted.
Procedure 2
We examined Boomerang Wireless, LLC's policies and procedures for training employees and agents for
ensuring that Boomerang Wireless, LLC's Lifeline subscribers are eligible to receive Lifeline services,
including any policies regarding how the company ensures employees and agents have completed the
training.
Following is a summarization of Boomerang Wireless, LLC's policies and requirements relative to the
above.
New team members are required to complete training prior to engaging in subscriber interaction. Upon
completion of the training, each new team member is required to sign and date a Standard of Engagement
form acknowledging that they meet certain standards required by the company. Included in the training
courses given to new team members are Lifeline introduction, eligibility requirements, documents training,
new customer activation process, zero tolerance and a section on ensuring a successful Lifeline experience.
The last page of course training material includes a Team Member Standards of Conduct form which is
Page 8 of 13 @
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
signed and dated by the Team Member and the Trainer. There are two ways in which information is
exchanged between Boomerang Wireless, LLC and the NLAD: (1) Through NLADs online portal; and
(2) CGM and H20 exchange data through a secure API connection with NLAD. Boomerang Wireless,
LLC's designated NLAD Administrator is responsible for assigning both the NLAD subaccount and NLAD
API credentials for those parties (Boomerang Wireless, LLC employees and vendors, CGM and H20). All
NLAD subaccounts and API credentials are monitored to ensure that only those parties whose job
responsibilities require visibility and/or access to NLAD receive the appropriate permissions.
No exceptions were noted.
Procedure 3
We randomly selected 100 subscribers from the Subscriber List and for the first 50 of the sampled
subscribers, performed the tests described below, for each of the subscriber's certification and recertification
forms.
a. We examined the subscriber certification and recertification forms or other forms of
communication, if any, to verify the forms contain the following information:
Lifeline is a federal benefit and that willfully making false statements to obtain the benefit
can result in fines, imprisonment, de-enrollment or being barred from the program;
ii. Only one Lifeline service is available per household;
iii. A household is defined, for purposes of the Lifeline progftrm, as any individual or group of
individuals who live together at the same address and share income and expenses;
lv A household is not permitted to receive Lifeline benefits from multiple providers;
Violation of the one-per-household limitation constitutes a violation of the Commission's
rules and will result in the subscriber's de-enrollment from the program;
vi. Lifeline is a non-transferable benefit and the subscriber may not transfer his or her benefit
to any other person;
vll.Require each prospective subscriber to provide the following information:
1. The subscriber's full name;
2. The subscriber's full residential address;
3. Whether the subscriber's residential address is permanent or temporary;
4. The subscriber's billing address, if different from the subscriber's residential address;
5. The subscriber's date of birth;
6. The last four digits of the subscriber's social security number, or the subscriber's Tribal
identification number, if the subscriber is a member of a Tribal nation and does not
have a social security number;
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l.
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
7 . If the subscriber is seeking to qualify for Lifeline under the program-based criteria, as
set forth in $54.409, the name of the qualiffing assistance program from which the
subscriber, his or her dependents, or his or her household receives benefits; and
8. If the subscriber is seeking to qualiff for Lifeline under the income-based criterion, as
set forth in $54.409, the number of individuals in his or her household.
viii. Require each prospective subscriber to certify, under penalty of perjury, that:
1. The subscriber meets the income-based or program-based eligibility criteria for
receiving Lifeline, provided in $54.409;
2. The subscriber notified Boomerang Wireless, LLC within 30 days if for any reason he
or she no longer satisfies the criteria for receiving Lifeline including, as relevant, if the
subscriber no longer meets the income-based or program-based criteria for receiving
Lifeline service, the subscriber is receiving more than one Lifeline benefit, or another
member of the subscriber's household is receiving a Lifeline benefit.
3. If the subscriber is seeking to qualify for Lifeline as an eligible resident of Tribal lands,
he or she lives on Tribal lands, as defined in $54.400(e);4. If the subscriber moves to a new address, he or she will provide that new address to
Boomerang Wireless, LLC within 30 days;
5. The subscriber's household will receive only one Lifeline service and, to the best of his
or her knowledge, the subscriber's household is not already receiving a Lifeline service;
6. The information contained in the subscriber's certification form is true and correct to
the best of his or her knowledge;
7. The subscriber acknowledges that providing false or fraudulent information to receive
Lifeline benefits is punishable by law; and
8. The subscriber acknowledges that the subscriber may be required to recertifu his or her
continued eligibility for Lifeline atany time, and the subscriber's failure to recertify as
to his or her continued eligibility will result in de-enrollment and the termination of the
subscriber' s Lifeline benefits pursuant to $ 54.405 (e)(4).
b. We compared Boomerang Wireless, LLC's subscriber eligibility criteria on the certification and
recertification forms or other forms of communication, to the federal eligibility criteria listed in
per 47 C.F.R. $54.409, as well as any additional state eligibility criteria identified in Item 4 of
Appendix A.
c. We verified the subscriber completed all the required elements as identified in Objective tII - 3
a. above, including signature and initialing/checkbox requirements contained in the certification
and recertification forms and other forms of communication.
d. We examined the subscriber's certification/recertification form to verify the forms are dated priorto the end of the selected Form 497 data month. If the provided subscriber
certification/recertification form is the subscriber's initial certification form, we verified that the
initial certification form is dated prior to or on the same day as the Lifeline start date per the
Subscriber List.
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Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
e. If applicable, we verified subscribers who received Tribal Lifeline support certified to residing
on Tribal lands.
f. We reviewed the list of the data source or documentation the ETC reviewed to confirm the
subscriber's eligibility obtained using Appendix E. We veriS the recorded data sources are
eligible data sourcesper 47 C.F.R. $ 54.410, such as (l) income or program eligibility databases,
(2) income or program eligibility documentation, or (3) confirmation from a state administrator.
We noted certification and recertification forms and other forms of communication included in the required
information, were properly dated, and that the data sources are eligible.
No exceptions were noted.
Obiective IV: Annual Certifications and Recordkeeping by Eligible Telecommunications Carriers.
To determine if Boomerang Wireless, LLC has made and submitted to the Universal Service
Administrative Company the required annual certifications, under penalty of perjury, relating to the
Lifeline program by an officer of the company and maintained recordkeeping requirements.
Procedure I
We inquired of management and obtained carrier policies and procedures for ensuring that Boomerang
Wireless, LLC has made and submitted the annual certifications required under $54.416 and $54.422 of the
Commission's rules. We examined these policies and procedures.
We noted no discrepancies between Boomerang Wireless, LLC's policies and procedures, management's
responses to the inquiries, and the Commission's Lifeline rules relative to submitting the annual
certifications.
No exceptions were noted.
Procedure 2
We examined Boomerang Wireless, LLC's FCC Forms 555 that were filed the January following the audit
period. We verified Boomerang Wireless, LLC made all of the following certifications. An officer of
Boomerang Wireless, LLC certified that he or she understands the Commission's Lifeline rules and
requirements and that Boomerang Wireless, LLC:
Has policies and procedures in place to ensure that its Lifeline subscribers are eligible to receive
Lifeline services;
Is in compliance with all federal Lifeline certification procedures; and
a.
b.
@Page 1l of13
c.In instances where Boomerang Wireless, LLC confinns consumer eligibility by relying on
income or eligibility databases, as defined in 47 C.F.R. $54.410(b)(1Xi)(A) or (c)(1)(i)(A), the
representative must attest annually as to what specific data sources Boomerang Wireless, LLC
used to confirm eligibility.
No exceptions were noted.
Procedure 3
We examined Boomerang Wireless, LLC's organization chart provided in response to Item 5 of Appendix A.
We verified that the certifying officer on the FCC Forms 555 for the selected states is an officer per the
organizational chart or other publicly available documents.
No exceptions were noted.
Procedure 4
We verified that the subscriber counts per the FCC Forms 555 for the selected states agree with the total
subscriber counts per the February Forms 497.
No exceptions were noted.
Procedure 5
We verified that the recertification data reported on the FCC Form 555 agrees with the detailed
recertification results provided by the carrier in response to Item 9 of Appendix A.
No exceptions were noted.
Procedure 6
We verified that the non-usage data reported on the FCC Form 555 for the selected month agrees with the
detailed non-usage results provided by the carrier in response to ltem 10 of Appendix A.
No exceptions were noted.
Procedure 7
We reviewed Boomerang Wireless, LLC's annual ETC certification Form 481, as provided in Item 13 of
Appendix A. We verified that Boomerang Wireless, LLC reported all the information and made all the
applicable certifications required by 47 C.F.R. $5a.a22@)(b).
No exceptions were noted.
Page 12 of 13 @
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
Curtis Blakely & Co., P.C.
Agreed-Upon Procedures Report - Attachment A
Boomerang Wireless, LLC
Procedure I
Because Boomerang Wireless, LLC's ETC designation is by state and not by the FCC, Boomerang Wireless,
LLC is not required to provide information about outages, complaints, and compliance with quality standards
so the requirement to review supporting schedules is not applicable.
Procedure 9
We inquired of management and obtained carrier policies and procedures for maintaining records that
document compliance with the Lifeline program rules, as provided by Boomerang Wireless, LLC in response
to ltem 4 of Appendix A. We examined the policies and procedures. We compared the management
responses and carrier policies with recordkeeping rules set forth in 47 C.F.R. 554.417.
No exceptions were noted.
@Page 13 of 13