20240515Lifeline Biennial Audit Report.pdf

RECEIVED
Wednesday, May 15, 2024 11:27:24 AM
IDAHO PUBLIC
UTILITIES COMMISSION
11 NELSON MULLINS NELSON MULLINS RILEY & SCARBOROUGH LLP
ATTORNEYS AND COUNSELORS AT LAW
101 Constitution Avenue, NW
Suite 900
Debra McGuire Mercer Attorney Washington, DC 20001
T: [phone] T: [phone] F: [phone]
[e-mail] nelsonmullins.com
May 15, 2024
Via EMAIL TO SECRETARYATUC.IDAHO.GOV
Jan Noriyuki
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
RE: Sage Telecom Communications, LLC d/b/a TruConnect
Lifeline Biennial Audit Report
Case No. SAG-T-19-01
Dear Ms. Noriyuki:
Pursuant to 47 C.F.R. § 54.420 of the Federal Communications Commission's ("FCC")
rules, Sage Telecom Communications, LLC d/b/a TruConnect("TruConnect")provides a copy
of its Lifeline Biennial Audit Report ("Report") as issued May 1, 2024. This Report covers the
audit period of January 1, 2021 through December 31, 2021.
If you have any questions, or if I may provide you with additional information, please do
not hesitate to contact me. Thank you for your assistance.
Respectfully submitted,
Debra McGuire Mercer
CALIFORNIA I COLORADO I DISTRICT OF COLUMBIA I FLORIDA I GEORGIA I ILLINOIS I MARYLAND I MASSACHUSETTS I MINNESOTA
NEW YORK I NORTH CAROLINA I OHIO I PENNSYLVANIA I SOUTH CAROLINA I TENNESSEE I TEXAS I VIRGINIA I WEST VIRGINIA

REPORT OF INDEPENDENT ACCOUNTANTS ON APPLYING
AGREED-UPON PROCEDURES
TruConnect Communications, Inc.
DMOSSADAMS

din MOSSADAMS
Report of Independent Accountants
To Management of TruConnect Communications, Inc., the Federal Communications Commission,
and the Universal Service Administrative Company:
We have performed the procedures enumerated in the attached Schedule of Agreed-Upon
Procedures on the schedules and information contained with the following documents (the "Subject
Matter") of TruConnect Communications, Inc. (Company, ETC, or Carrier) as of and for the year
ended December 31, 2021, prepared in accordance with the Federal Communications Commission's
(FCC or Commission) Biennial Audit Plan, Universal Service Fund — Lifeline Program: General
Standard Procedures for Biennial Independent Audits Required Under the Lifeline Reform Order (the
"FCC Rules"):
Appendix A— Requested Documentation
Appendix B—Background Questionnaire
Appendix C— Internal Control Questionnaire
Appendix D—Requested Documentation: One-Per-Household Sample
Appendix E— Requested Documentation: Subscriber Sample
Appendix F—Compliance Requirements
Management of TruConnect Communications, Inc. is responsible for the Subject Matter.
TruConnect Communications, Inc. has agreed to and acknowledged that the procedures performed
are appropriate to meet the intended purpose of assessing the Company's compliance with the
FCC's rules related to the provision of Lifeline services and the receipt of funding under the FCC's
Universal Service Fund— Lifeline Program. This report may not be suitable for any other purpose.
The procedures performed may not address all the items of interest to a user of this report and may
not meet the needs of all users of this report and, as such, users are responsible for determining
whether the procedures performed are appropriate for their purposes.
The procedures and the associated findings are enumerated in the Schedule of Agreed-Upon
Procedures attached to this report.
We were engaged by TruConnect Communications, Inc. to perform this agreed-upon procedures
engagement and conducted our engagement in accordance with attestation standards established by
the Government Auditing Standards. An agreed-upon procedures engagement involves performing
specific procedures that the engaging party has agreed to and acknowledged to be appropriate for
the intended purpose of the engagement and reporting on findings based on the procedures
performed. We were not engaged to and did not conduct an examination or review engagement, the
objective of which would be the expression of an opinion or conclusion, respectively, on the Subject
Matter as of and for the year ending December 31, 2021. Accordingly, we do not express such an
opinion or conclusion. Had we performed additional procedures, other matters might have come to
our attention that would have been reported to you.
1

We are required to be independent of TruConnect Communications, Inc. and to meet our other
ethical responsibilities in accordance with the relevant ethical requirements related to our agreed-
upon procedures engagement.
This report is intended solely to report the findings of the procedures enumerated in the attached
Schedule of Agreed-Upon Procedures and is not suitable for any other purpose.
In compliance with the FCC Rules, this report does not contain any personally identifiable information
or individually identifiable customer proprietary network information.
(11�� 71�" -UP
Overland Park, Kansas
May 1, 2024
2

SCHEDULE OF AGREED-UPON PROCEDURES
We performed the following procedures for Objectives I, II, III, IV and V contained in the FCC's
Biennial Audit Plan, Universal Service Fund — Lifeline Program: General Standard Procedures for
Biennial Independent Audits ("Biennial Audit Plan") to schedules and information contained within
Appendices A—E prepared by the Company as of and for the year ending December 31, 2021.
Objective I: Carrier Obligation to Offer Lifeline
Procedure 1
Moss Adams LLP inquired of management on January 12, 2024, and obtained the Carrier's policies
and procedures for making Lifeline service available to qualifying low-income consumers as provided
by the carrier in response to Request #4 of Appendix A (Requested Documentation) of the FCC's
Biennial Audit Plan.
Moss Adams LLP examined the Carrier's policies and procedures, and compared those policies and
procedures, including management's responses to the inquiries, to the Commission's Lifeline rules
set forth in Appendix F of the FCC's Biennial Audit Plan.
Moss Adams LLP noted no discrepancies between the Carrier's policies and procedures,
management's responses to the inquiries, and the Commission's Lifeline rules.
No exceptions noted.
Procedure 2
Moss Adams LLP inspected five examples of the five available carrier marketing materials describing
the Lifeline service (i.e., print, audio, video, and Internet materials used to describe or enroll in the
Lifeline service offering, including standard scripts used when enrolling new subscribers, application,
and certification forms), as provided in response to Request #4, #6, and #7 of Appendix A of the
FCC's Biennial Audit Plan.
Moss Adams LLP noted the Carrier marketing materials inspected included the following:
i. The service is a Lifeline service, which is a government assistance program;
ii. The service is non-transferable;
iii. Only eligible subscribers may enroll;
iv. Only one Lifeline discount is allowed per household; and
V. The ETC's name or any brand names used to market the service.
No exceptions noted.
Procedure 3
a. Moss Adams LLP reviewed the Carrier's responses to the background questionnaire regarding
the Carrier's policies, inquired of management on January 12, 2024, and obtained the Carrier's
policies and procedures 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.
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SCHEDULE OF AGREED-UPON PROCEDURES
Moss Adams LLP verified the policies are designed to (1) allow subscribers to make notifications
of the subscriber's intent to cancel service and prevent the Carrier from claiming ineligible
subscribers on the FCC Form 497 or subscribers who wish to cancel service as required by 47
C.F.R. § 54.410(d)(3)(ii) and (iv), and (2) prevent the Carrier from claiming ineligible subscribers
on the monthly Snapshot Report or subscribers who wish to cancel service.
Moss Adams LLP noted no discrepancies between the Carrier's responses to the background
questionnaire, Carrier's policies and procedures, management's responses to the inquiries, and
the Commission's Lifeline rules.
b. Moss Adams LLP identified one customer care number which was provided in response to
Request#8 of Appendix A of the FCC's Biennial Audit Plan, was identified in marketing materials
provided in response to Request#6 of Appendix A of the FCC's Biennial Audit Plan, or was listed
on the one website provided in response to Request#7 of Appendix A of the FCC's Biennial Audit
Plan.
Moss Adams LLP called the customer care number and noted (1) the telephone number was
operational, (2) used an interactive voice response system, and (3)that it was possible to reach a
live customer care operator.
No exceptions noted.
Procedure 4
Moss Adams LLP noted the ETC offers Lifeline service and does not collect and assess a monthly
fee from its subscribers. For the 60 subscribers randomly selected from the listing created out of the
Combined Master Listing and sampling selection pursuant to Section Il, item#23 of the Biennial Audit
Plan, Moss Adams LLP inspected the subscriber's usage records for two judgmentally selected
months subsequent to the expiration of the waiver (i.e., May 2021), June and November 2021, as
provided in response to Request#1 of Appendix E of the FCC's Biennial Audit Plan and determined if
the subscriber used the service as defined by 47 C.F.R§ 54.407(c)(2), within 30 days.
No exceptions noted.
Procedure 5
Moss Adams LLP noted the ETC offers Lifeline service but does not collect and assess a monthly fee
from its subscribers. Moss Adams LLP inspected the carrier's records of subscribers listed with no
usage in the cure period and ensured that the customers were not included in the monthly Lifeline
Claim System.
No exceptions noted.
Procedure 6
Moss Adams LLP noted the ETC offers Lifeline service but does not assess and collect a monthly fee
from its subscribers. Therefore, this procedure is not applicable.
No exceptions noted.
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SCHEDULE OF AGREED-UPON PROCEDURES
Procedure 7
Moss Adams LLP inspected applicable policies and procedures regarding de-enrollment from the
program, including when the ETC de-enrolls subscribers based on lack of eligibility, duplicative
support, non-usage, and failure to recertify, as further described below.
a. Moss Adams LLP inspected policies and procedures for de-enrollment where ETC had
information indicating that a Lifeline subscriber no longer met the criteria to be considered a
qualifying low-income consumer under 47 C.F.R. §54.409, as provided in response to Request#4
of Appendix A of the FCC's Biennial Audit Plan, as well as de-enrollment letters provided in
response to Request#11 of Appendix A of the FCC's Biennial Audit Plan.
Moss Adams LLP noted the policies and procedures detailing the process for communications
between the subscriber and ETC regarding de-enrollment included, but were not limited to
(1) notifying subscribers of impending termination of service; (2) allowing subscribers to
demonstrate continued eligibility in 30 days for failure to demonstrate eligibility; (3) de-enrolling
the subscriber from Lifeline service in five business days for failure to demonstrate eligibility, and
(4) and removal from NLAD within one business day of de-enrollment. Moss Adams LLP noted
there were no areas that were not in compliance with 47 C.F.R. § 54.405(e)(1) of the
Commission's rules.
b. Moss Adams LLP inspected the Carrier'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).
Moss Adams LLP noted the policies and procedures stated that the ETC will de-enroll
subscribers from Lifeline service 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 47 C.F.R. § 54.405(e)(2) of the Commission's rules. Moss
Adams LLP noted the policies and procedures also required the removal from NLAD within one
business day of de-enrollment from the Lifeline service.
c. Moss Adams LLP inspected the Carrier's policies and procedures for de-enrolling subscribers for
non-usage (i.e., where a Lifeline subscriber fails to use Lifeline service for 30 consecutive days),
including the process of how the Carrier 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 Request#17 of Appendix A of the FCC's Biennial Audit Plan.
Moss Adams LLP examined the written policies and procedures and non-usage termination
notifications to verify if the termination notifications explain that the subscriber has 15 days
following the date of the impending termination to use the Lifeline service.
Moss Adams LLP noted no instances where the non-usage termination notices did not comply
with the § 54.405(e)(3) of the Commission's rules. In addition, Moss Adams LLP confirmed the
policies and procedures also addressed the carrier's responsibility to de-enroll the subscriber
after the 15 day non-usage period.
d. Moss Adams LLP reviewed the Carrier's policies and procedures for de-enrolling a Lifeline
subscriber at the customer's request.
5

SCHEDULE OF AGREED-UPON PROCEDURES
Moss Adams LLP confirmed the policies and procedures required de-enrollment from Lifeline
service within two business days and removal from NLAD within one business day after
de-enrollment from Lifeline service.
No exceptions noted.
Objective II: Consumer Qualification for Lifeline
Procedure 1
Moss Adams LLP reviewed the procedures the Carrier had in place to ensure it accurately completed
the LCS Claims Report, including management's responses to inquiries made on January 12, 2024.
The procedures or processes included the following:
• The process for determining how to ensure accurate claims for subscribers are reflected on
the monthly Claims reports. The Carrier initiates their claims process by identifying and
downloading a list of subscribers from the Carrier billing system that were active on the first
day of the preceding claim month. Each subscriber goes through a series of validation checks
to verify the subscriber is eligible to be claimed. The Carrier does not use a date range or cut-
off date to determine which subscribers were included in filing the LCS Claims.
• The process for determining the accurate claim amount of non-Tribal Lifeline, Tribal Lifeline,
and Tribal Link Up; and
• 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.
No exceptions noted.
Procedure 2
For Opt-out States only, Moss Adams LLP obtained the Lifeline Claims System (LCS) Report and
Subscriber Listing from the company in response to Request#1 of Appendix A and compared its total
number of subscribers to the number of subscribers reported on the Final Combined Master List
created in the Sample Selection section of the FCC's Biennial Audit Plan.
Moss Adams LLP confirmed the agreement of data (name, subscriber ID, phone number, and
address) between the LCS or Subscriber listing and Final Combined Master List.
Moss Adams LLP noted discrepancies between the LCS total number of subscribers and the
Combined Master List of the Sample Selection section of the FCC's Biennial Audit Plan of twenty-six
subscribers. Moss Adams LLP investigated where the variances included more subscribers claimed
than were included in the Subscriber Listing but made no updates to the Combined Master Listing as a
result.
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SCHEDULE OF AGREED-UPON PROCEDURES
Procedure 3
For NLAD States only, Moss Adams LLP obtained from USAC the NLAD Snapshots and combined
LCS Claims Report for subscribers active for each study area for March, May, August, and
December 2021 in accordance with the sampling requirements as described in Section Il, Item #23 of
the 2021 Lifeline Biennial Audit Plan. Moss Adams LLP compared the data for discrepancies. Potential
discrepancies are no rate claimed but subscriber is still active, subscriber was claimed, however,
NLAD indicates that service was not initiated or subscriber has no record in NLAD, high rate claimed
for subscriber than is justified given the subscriber's service type, or subscriber's trial/nontribal status.
Moss Adams LLP noted no discrepancies related to no rate claimed but subscriber is still active,
subscriber was claimed, however, NLAD indicates that service was not initiated or subscriber has no
record in NLAD, high rate claimed for subscriber than is justified given the subscriber's service type, or
subscriber's tribal/non-tribal status.
No exceptions noted.
Procedure 4
Moss Adams LLP inquired of management on January 12, 2024, and obtained Carrier policies and
procedures for limiting Lifeline support to a single subscription per household as provided by the
carrier in response to Request#4 of Appendix A of the FCC's Biennial Audit Plan.
Moss Adams LLP examined and compared the carrier policies and procedures, including any
management responses, with the Commission's Lifeline rules set forth in section 54.409(c)
(Appendix E of the FCC's Biennial Audit Plan).
Moss Adams LLP noted no discrepancies between the Carrier's policies and procedures,
management's responses to the inquiries, and the Commission's rules.
No exceptions noted.
Procedure 5
Moss Adams LLP used computer-assisted audit techniques to examine the Combined LCS and
NLAD Snapshot Reports created in accordance with sampling requirements as described in the 2021
Lifeline Biennial Audit Plan per Section Il, item #23 and noted one hundred ninety-eight thousand two
hundred fifty-three duplicate addresses with different subscribers claimed for the same month.
Moss Adams LLP created a list of one hundred ninety-eight thousand two hundred fifty-three
duplicate addresses with different subscribers claimed for the same month.
Procedure 6
Moss Adams LLP randomly selected sixty subscribers from the list of one hundred ninety-eight
thousand two hundred fifty-three duplicates completed in Objective II Procedure 5 and requested
copies of the one-per-household certification form for each of the selected subscribers using
Appendix D.
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SCHEDULE OF AGREED-UPON PROCEDURES
a. Because subscribers must only complete a one-per-household certification form if existing
Lifeline recipients reside at the same address, Moss Adams LLP determined the selected
subscribers were not the first subscribers residing at the address based on the Lifeline start
date in the subscriber listing (i.e., the selected subscribers should be the second or
subsequent subscribers residing at the address based on the Lifeline start date in the
subscriber listing). Moss Adams LLP verified the selected subscriber accurately completed a
one-per-household certification on the correct form, FCC Form 5631, the Lifeline Program
Household Worksheet. Moss Adams LLP noted thirty of the selected subscribers did not
accurately complete a one-per household certification on the correct form, FCC Form 5631,
the Lifeline Program Household Worksheet due to the First Waiver Order issued on
March 17, 2020 (DA 20-285) and continuing through successive Orders until June 30, 2022
(DA 22-691).
Moss Adams LLP noted no instances where there were missing or incomplete certifications.
No exceptions noted.
Obiective III: Subscriber Eligibility Determination and Certification
Procedure 1
Moss Adams LLP inquired of management on January 12, 2024, and obtained the Carrier's policies
and procedures for ensuring that its Lifeline subscribers are eligible to receive Lifeline services as
provided by the Carrier in response to Request #4 of Appendix A (Requested Documents) of the
Lifeline Biennial Audit Plan. In addition, Moss Adams LLP obtained the ETC's policies and
procedures for training employees and agents for ensuring that the ETC's Lifeline subscribers are
eligible to receive Lifeline services, including any policies regarding how the company ensures
employees and agents have completed the training.
Moss Adams LLP examined the Carrier'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 47 C.F.R. § 54.409 and 54.410 (Appendix F of the FCC's Biennial Audit Plan).
Moss Adams LLP noted no discrepancies between the Carrier's policies and procedures,
management's responses to the inquiries, and the Commission's rules.
a. Moss Adams LLP inspected the ETC's policies and noted evidence of policies and
procedures that the ETC must verify the eligibility of each low-income consumer prior to
providing Lifeline service to the consumer or providing that consumer with an activated
device intended to enable access to Lifeline service.
b. Moss Adams LLP inspected the ETC's policies to determine the process for ensuring
subscribers are eligible to receive Lifeline services and have completed all forms necessary
to receive service.
c. Moss Adams LLP inspected the ETC's policies for information regarding the timing,
frequency, and evidence of completion of the initial and any subsequent Lifeline subscriber
eligibility and certification trainings required of the ETC's employees.
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SCHEDULE OF AGREED-UPON PROCEDURES
d. Moss Adams LLP noted the ETC operates in states that participate in NLAD and inspected
the ETC's policies regarding:
i. Training requirements and ETC policies for ensuring employees and agents are
trained on the use and interaction with the NLAD, including limiting access to NLAD
to select individuals.
ii. The process for ensuring only subscribers vetted by NLAD are claimed for
reimbursement on the LCS Claims Report.
e. Moss Adams LLP noted the ETC operates in NLAD opt-out states, and inspected the ETC's
policies regarding:
i. Training requirements and ETC policies for ensuring employees and agents are
trained on the use and interaction with state administrators and or databases,
including limiting access to any databases to select individuals.
ii. The process for ensuring only subscribers vetted by a state administrator are claimed
for reimbursement on the LCS Claims Report.
No exceptions noted.
Objective IV: Activities of Enrollment Representatives
Procedure 1
Moss Adams LLP inquired of management on January 12, 2024, and obtained the Carrier's policies
and procedures for ensuring that its enrollment representatives are enrolled with USAC. Moss
Adams LLP examined and compared the Carrier policies and procedures, including management
responses, with the Commission's Lifeline rules set forth in sections 54.406. Moss Adams LLP noted
no discrepancies between the Carrier's policies and procedures, management's responses to the
inquiries, and the Commission's rules.
a. Moss Adams LLP inspected the ETC's policies to look for evidence as to whether it includes
a policy or procedure that the ETC's enrollment representatives must register with USAC
prior to the enrollment representative providing information directly or indirectly to the NLAD
or the National Verifier.
b. Moss Adams LLP inspected the ETC's policies to determine the process for ensuring
enrollment representatives and their direct supervisors are not compensated based on the
number of consumers who apply for or are enrolled in the Lifeline program.
c. Moss Adams LLP examined documentation (general ledger, payroll register, etc.) for
evidence of commission-based compensation and noted no discrepancies between the
ETC's policies and procedures and the Commission's rules.
d. Moss Adams LLP reviewed documentation associated with third-party marketing
organizations to determine that there is no indication that payments will be issued based on
Lifeline customer enrollment volume.
No exceptions noted.
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SCHEDULE OF AGREED-UPON PROCEDURES
Objective V: Annual Certifications and Recordkeeping by Eligible Telecommunications
Carriers
Procedure 1
Moss Adams LLP inquired of management on January 12, 2024, and obtained the Carrier's policies
and procedures for ensuring the Carrier has made and submitted the annual certifications required
under sections 54.416 (i.e., FCC Form 555) and 54.422 (i.e., FCC Form 481) of the Commission's
rules, as provided in response to Request #4 of Appendix A (Requested Documents) of the FCC's
Biennial Audit Plan.
Moss Adams LLP examined the Carrier's policies and procedures and compared those policies and
procedures, including management's responses to the inquiries, with the Commission's Lifeline rules
set forth in 47 C.F.R. § 54.416 and §54.522 in Appendix F of the FCC's Biennial Audit Plan.
Moss Adams LLP noted no discrepancies between the Carrier's policies and procedures,
management's responses to the inquiries, and the Commission's Lifeline rules.
No exceptions noted.
Procedure 2
Moss Adams LLP examined the ETC's FCC Form 555 that was filed in January 2022, following the
audit period of January 1 — December 31, 2021, provided by the Carrier in response to Request#12
of Appendix A of the FCC's Biennial Audit Plan.
Moss Adams LLP verified the Carrier made all of the following certifications and that an officer of the
ETC certified that they understood the Commission's Lifeline rules and requirements and that the
Carrier:
a. Has policies and procedures in place to ensure that its Lifeline subscribers are eligible to
receive Lifeline services;
i. In instances where an ETC confirms consumer eligibility by relying on income or eligibility
databases, as defined in 47 C.F.R. § 54.410(b)(1)(i)(A)or(c)(1)(i)(A), the representative
must attest annually as to what specific data sources the ETC used to confirm eligibility;
b. Is in compliance with all federal Lifeline certification procedures; and
c. Is in compliance with the minimum service levels set forth in 47 C.F.R. § 54.408.
Moss Adams LLP noted no instances where an officer of the ETC did not certify their understanding
of the Commission's Lifeline rules and requirements.
No exceptions noted.
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SCHEDULE OF AGREED-UPON PROCEDURES
Procedure 3
Moss Adams LLP examined the ETC's organizational chart provided by the carrier in response to
Request #5 of Appendix A of the FCC's Biennial Audit Plan and verified that the certifying officer on
the FCC Form 555 was an officer per the organizational chart.
No exceptions noted.
Procedure 4
Moss Adams LLP noted that the subscriber count per the FCC Form 555 were all reported as zeros
as required after December 2020 per the judgmentally selected months of April, June, August, and
October 2021 LCS Claims Reports provided by the carrier in response to Request#13 of Appendix A.
No exceptions noted
Procedure 5
Moss Adams LLP noted that the non-usage data reported on the FCC Form 555 for the months of
May, August, November 2021 did not agree with the detailed non-usage results provided by the
carrier in response to Request#9 of Appendix A of the FCC's Biennial Audit Plan.
No exceptions noted.
Procedure 6
Moss Adams LLP reviewed the Carrier's FCC Form 481 as provided by the Carrier in response to
Request#12 of Appendix A of the FCC's Biennial Audit Plan. Moss Adams LLP verified that the ETC
reported all the information and made all the certifications required by 47 C.F.R. § 54.422(a), (b).
No exceptions noted.
Procedure 7
Moss Adams LLP reviewed supporting schedules related to the Carrier's FCC Form 481, as provided
by the Carrier in response to Requests #14 and #15 of Appendix A of the FCC's Biennial Audit Plan.
Moss Adams LLP verified that the data reported on the FCC Form 481 agreed with supporting
schedules.
No exceptions noted.
Procedure 8
Moss Adams LLP inquired of management on January 12, 2024, and obtained the Carrier's policies
and procedures for maintaining records that document compliance with the Lifeline program rules, as
provided by the Carrier in response to Request#4 of Appendix A of the FCC's Biennial Audit Plan.
Moss Adams LLP examined and compared the carrier policies and procedures, including any
management responses, with recordkeeping rules set forth in 47 C.F.R. § 54.417 and noted no
discrepancies the policies and procedures and the Commission's rules.
No exceptions noted.
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