Home > Program Integrity Assurance > Alternative Discount Verification – Survey Method
Administrative Procedure:
Alternative Discount Verification – Survey Method
Further Detail:
Applicants may survey their student population as an alternative method for calculating their entity’s discount. The survey instrument must contain specific data points to be considered valid, such as name of the family and students, family income-level and family size. The entity also must demonstrate that the majority of the student population completed and returned the survey.
Rules that this furthers:
1. 47 C.F.R. § 54.505(b)(1) requires that “the level of poverty shall be measured by the percentage of their student enrollment that is eligible for a free or reduced price lunch under the national school lunch program or a federally-approved alternative mechanism.”
2. Federally-approved alternative mechanisms include surveys. See e.g., Request for Review of the Decision of the Universal Service Administrator by Academia Claret, et al., CC Docket No. 02-6, Order, 21 FCC Rcd 10703, 10704, DA 06-1907, ¶ 4 n.10 (2006) (citing 34 C.F.R. § 200.78(a)(2)).
3. 47 C.F.R § 54.701(a) requires USAC to “administer[ ] the universal service support mechanisms in an efficient, effective, and competitively neutral manner.”
4. 47 C.F.R. § 54.702(g) requires USAC to take “administrative action intended to prevent waste, fraud, and abuse.”
How this protects against waste, fraud and abuse:
Ensures that eligible entities are using alternative discount method calculations based on income level and family size and that a valid survey method is used to determine discounts for eligible services.