FCC Record, Volume 26, No. 7, Pages 4843 to 5761, March 28 - April 08, 2011 Page: 5,100
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that, in administering the TRS Fund, RLSA complies with all relevant and applicable federal financial
management and reporting statutes, as required by Section 64.604(c)(5XiiiXH) of the Commission's
rules. The OMB Circular A-123 framework should also include internal and external controls designed
to identify and protect against risks and vulnerabilities to safeguard TRS Funds and resources.6 Within
30 days of the date of this letter please submit a plan, subject to Commission approval, for implementing
the internal control structure required by OMB Circular A-123. In addition, within 60 days of the date of
this letter please submit procedures, subject to Commission approval, for administering the TRS fund on
an ongoing basis, which are compliant with OMB Circular A-123.7
Second, Section 64.604(c)5XiiiXE) of the Commission's rules requires RLSA to "establish
procedures to verify payment claims."' Consistent with this rule, RLSA is directed to develop written
policies and procedures governing its activities and functions as the current Fund administrator, including
procedures to review and verify the minutes of use submitted by each provider for payment each month.
The policies and procedures should ensure that RLSA reviews and verifies, on a monthly basis, all call
data submitted each month by each provider, including all of the data currently required to be filed and
any additional data the Commission may require in the future, to ensure that the minutes submitted are
legitimate and that the correct amounts of funds are disbursed, and to detect call patterns that suggest
fraud. RLSA shall ensure providers do not submit improper costs or improper minutes for the annual rate
setting process. RLSA shall also ensure that providers do not submit improper minutes for monthly
payments. RLSA shall further establish formal anti-fraud policies and procedures that identify proactive
measures that RLSA is taking to combat potential waste, fraud, and abuse in the TRS program. Please
submit these policies and procedures, subject to Commission approval, within 60 days of the date of this
letter. In addition, please submit within 60 days of the date of this letter and subject to Commission
approval, a proposed list of additional written policies and procedures that RLSA will implement (along
with a proposed implementation timeline) to better safeguard the monies of the TRS Fund. On a going-
forward basis, RLSA shall coordinate, and secure approval of, any proposed change to its policies or
procedures with the Commission before making such changes.
Third, concerning the annual submission of cost and demand data used to determine the
compensation rates and Fund size, RLSA is directed to establish written policies and procedures to
frequently review the submissions of TRS providers seeking compensation from the TRS Fund. Section
64.604(c)(5) of the Commission's rules states that, "TRS providers shall provide the administrator with
true and adequate data necessary to determine TRS fund revenue requirements and payments."9 The
Commission's rules also require TRS providers to provide RLSA with total TRS minutes of use, total
interstate TRS minutes of use, total TRS operating expenses and total TRS investment in general
accordance with Part 32 of the Commission's rules.'0 In addition, Section 64.604(cX5) requires TRS
providers to provide "other historical or projected information reasonably requested by the administrator
SSee 47 C.F.R. 64.604(c)X5iii)H); TRS Agreement, C. 4.0. RLSA's obligation to follow the Commission's
TRS rules, including those referenced in this letter, also extends to any subsequent Commission amendments to the
substance or numbering of those rules.
6 These measures, for example, should protect against the Video Relay Service program participant billing of
fraudulent and/or non compensable minutes.
7 See TRS Agreement, C. 4.0, 5.0.
' See 47 C.F.R. 64.604(c)(5)(iii)(E).
9 See 47 C.F.R. 64.604(c)(5).
o See id.
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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/m1/272/: accessed March 23, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.