FCC Should Take Action to Better Manage Persistent Fraud Risks in the Schools and Libraries Program

In 2017, the Federal Communications Commission’s Office of Inspector General (OIG) reported that FCC’s ability to deter and detect alleged Erate program fraud has been severely limited since the program’s inception due to a lack of certain controls. Also, as recently as February 2020, a number of E-rate program participants pled guilty to defrauding the program by billing for equipment and services that were not provided, and obtaining more than $2.6 million in program funds to which they were not entitled. GAO was asked to review fraud risk management in the E-rate program. This report addresses: (1) the E-rate program’s key fraud risks; (2) the extent to which FCC and USAC are managing fraud risks in accordance with leading practices; and (3) the extent to which FCC and USAC face challenges in effectively employing data analytics to support fraud risk management activities. GAO recommends:

• The Chairman of FCC should direct and coordinate with the Chief Executive Officer of the Universal Service Administrative Company (USAC) to comprehensively assess fraud risks to the E-rate program, including implementing their respective plans for developing periodic fraud risk assessments, examining the suitability of existing fraud controls, and compiling fraud risk profiles following the timelines described in this report. The assessments should be informed by the key fraud risks identified in this report from closed court cases, prior risk assessments, and OIG reports, among other sources. (Recommendation 1)
• The Chairman of FCC should ensure that FCC and USAC follow the leading practices in GAO’s Fraud Risk Framework when designing and implementing data-analytics activities to prevent and detect fraud as part of their respective antifraud strategies for the E-rate program. (Recommendation 2)
• The Chairman of FCC should direct the Chief Executive Officer of USAC to clearly define and fully document the data fields in all relevant E-rate program computer systems to help improve FCC’s ability to understand and use data to manage fraud risks. (Recommendation 3)