A few ECF applicants, which have already received ECF reimbursements, have reported receiving emails notifying them that they had been selected for “payment audits.” The emails are coming from Censeo Consulting Group (“Censeo”) that has been engaged by the FCC — not USAC — to “ensure that ECF Program participants are adhering to program requirements and complying with FCC rules.”
The cover email indicates that it is possible that Conseo can complete its audit with the information and documents provided during the ECF application and request for reimbursement processes, but that additional documentation may be required. We expect this means that the audits will focus on the products and services requested, their costs, and their relationship to the “unmet need” of students, staff, and patrons. To date, we have not seen any specific requests for additional information.
With regard to privacy concerns likely to arise with inquiries regarding unmet needs, Censeo’s opening email includes the following paragraph:
We will also adhere to applicable federal and state privacy laws regarding student, school staff, and library patron personally identifiable information and will seek to use anonymized or deidentified information wherever possible. In the event that student, school staff, or library patron personally identifiable information is necessary for this audit, we will request that you first obtain the consent of the parents or guardians for minor students and the consent of legal-aged students, school staff, or library patrons to have access to this information before sharing the information. Any personally identifiable information provided, will be used and safeguarded as required by applicable federal and state privacy laws.
Additional information on the ECF audit program is expected to become available in the coming weeks.