FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,099
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Federal Communications Commission
Washington, D.C. 20554
April 5, 2011
Rolka Loube Saltzer Associates
One S. Market Square, 12th Floor
Harrisburg, PA 17101
Re: Telecommunications Relay Service Fund Financial and Accounting Internal Controls
Dear Mr. Rolka:
With this letter, the Federal Communications Commission (Commission) congratulates Rolka
Loube Saltzer Associates (RLSA) on its selection to administer the Telecommunications Relay Service
(TRS) Fund. The Commission looks forward to working with RLSA to ensure that the TRS Fund
continues to advance throughout the United States the goal of providing the benefits of communications
technologies and services to individuals who are deaf-blind, or who have hearing or speech disabilities.'
In addition, this letter provides instructions to RLSA as the new TRS administrator, to integrate specific
measures into its internal controls structure over its finance and accounting operations, to ensure
transparency of operations, and to provide efficient and effective operations. These steps will facilitate
the integrity of the TRS fund and combat potential waste, fraud, and abuse so that the Commission and
program stake holders can be assured TRS monies are being used in an efficient, effective, manner.
First, as the administrator of the TRS Fund, RLSA is directed to implement effective internal
controls over its TRS operations, including the administration of the TRS Fund and compliance with
applicable laws and regulations.2 In particular, RLSA shall implement an internal controls structure
consistent with the standards and guidance contained in the Office of Management and Budget (OMB)
Circular A-123, including the methodology for assessing, documenting, and reporting on internal controls
specified in Appendix A of OMB Circular A-123.3 This appendix requires, among other things,
establishing a "Senior Management Council" charged with assessing the effectiveness of internal
controls, preparing a risk assessment of TRS operations, and properly documenting TRS administrative
procedures.4 An internal control structure compliant with OMB Circular A-123 is critical to ensuring
' 47 U.S.C. 225(b (1). The Twenty-First Century Communications and Video Accessibility Act (CVAA) revises
the definition of TRS to include telecommunications access for individuals who are deaf-blind. Twenty-First
Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-260, 124 Stat. 2751 (2010) (as
codified at 47 U.S.C. 715). See also Amendment of Twenty-First Century Communications and Video
Accessibility Act of 2010, Pub. L. I 111-265, 124 Stat. 2795 (2010), also enacted on October 8, 2010 (S. 3828, 111 "
Cong.) making technical corrections to the CVAA.
2 TRS Fund Administration Services Agreement, CON 11000003, C. 4.6 - 4.7 (March 7, 2011) (TRS
3 See Office of Management and Budget, Management's Responsibility for Internal Control, Circular No. A-123,
Appendix A (Dec. 21, 2004) (available at http://www.whitehouse,gov/omb/circulars a123 rev) (OMB Circular No.
A-123); TRS Agreement at i C. 4.0 5.0.
See OMB Circular No. .4-123 at Appendix A. III, Assessing Internal Control Over Financial Reporting; TRS
Agreement, C. 4.0
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United States. Federal Communications Commission. FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011, book, April 2011; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc52169/m1/271/: accessed May 24, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.