Further Distinctions Between Clerical and Substantive Errors

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The FCC’s Wireless Competition Bureau has released an omnibus ruling addressing 22 appeals of E-rate decisions by the Universal Service Administrative Company (USAC). The disposition of these appeals affirms the distinction between clerical or administrative applicant errors, which Commission staff routinely forgives, and more substantive omissions, which generally defeat an otherwise worthy claim of entitlement.

The FCC forgave the following attempts to correct applications and Item 21 attachments because they were deemed to be clerical and administrative errors: mischaracterization of non-recurring services as recurring services, or vice-versa; misidentification of service providers; use of the wrong filing request number on the FCC Form 471 block 4 worksheet; submission of a corrected Form 471 (and its Item 21 attachment) after the applicable deadline; and accidentally transposing the amounts for eligible and ineligible services from the Item 21 attachment onto the Form 471. In each case, the staff found no evidence of waste, fraud or abuse and remanded the cases to USAC for further consideration. Even so, the staff declined to make a determination as to ultimate eligibility.

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