Federal Communications Commission DA 17-755
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Lifeline and Link Up Reform and Modernization
)
)
) WC Docket No. 11-42
ORDER
Adopted:  August 10, 2017 Released: August 10, 2017
By the Chief, Wireline Competition Bureau:
1. In this Order, the Wireline Competition Bureau (Bureau) denies the motions of 
TruConnect, Cox Communications, Inc. (Cox), and Tag Mobile LLC (Tag) (collectively Carriers) filed in 
this docket seeking an extension of time to submit a copy of their respective final attestation reports 
pursuant to the Lifeline Program Biennial Audit Plan.
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2. The Commission’s rules require that all eligible telecommunications carriers (ETCs) that 
receive $5 million or more annually from the Lifeline Program obtain an independent biennial audit of 
their compliance with the Lifeline Program rules.
2
  ETCs that were required to complete the current 
independent biennial audits were notified on August 10, 2016.  The carriers were given until August 10, 
2017 to conduct the required audit procedures and file the final attestation report with the Commission, 
Universal Service Administration Company (USAC), and any relevant state and Tribal governments.
3. On August 8, 2017, TruConnect filed a motion for an extension of the filing deadline for 
its final attestation report.
3
  On August 9, 2017, Cox and Tag filed a motion for an extension of the filing 
deadline for their final attestation reports.
4
  Tag requests a 5-day extension, TruConnect requests a 14-day 
extension, and Cox requests a 6-week extension.
5
  Tag states that “good cause” exists for the extension 
because Tag “needs additional time.”
6
  TruConnect states that during the yearlong engagement period the 
carrier had an initial independent auditor end a contract, requiring the engagement of a second audit firm.
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TruConnect also states that this transition was made more difficult by employee turnover, causing 
historical knowledge to be lost and delaying the completion of the report.
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  Cox states that it has engaged 
Deloitte & Touche LLP (Deloitte) for the “past seven months” to complete Cox’s audit.
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  Cox adds that 
Deloitte submitted its “draft Agreed-Upon Procedures Lifeline Audit Report of Cox and Cox’s response 
                                                     
1
TruConnect Motion for Extension, WC Docket No. 11-42 (filed Aug. 8, 2017) (TruConnect Motion); Cox 
Communications Motion for Extension, WC Docket No. 11-42 (filed Aug. 9, 2017) (Cox Motion); Tag Mobile LLC 
Motion for Extension, WC Docket No. 11-42 (filed Aug. 9, 2017) (Tag Motion).
2
47 CFR § 54.420.
3
TruConnect Motion, at 1.
4
Cox Motion, at 1; Tag Motion, at 1.
5
Tag Motion, at 1; TruConnect Motion, at 1; Cox Motion, at 1.
6
Tag Motion, at 1.
7
TruConnect Motion, at 1.
8
Id.
9
Cox Motion, at 1.
Federal Communications Commission DA 17-755
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to [USAC] on August 8, 2017.”
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  However, due to the required 30-day USAC review period, Cox will 
not be able to submit the final audit report to the Commission by the deadline.
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4. We conclude that granting an extension of the Carriers’ deadlines to file their final 
attestation reports is not warranted under the present circumstances.  Extensions of time are not routinely 
granted,
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and we do not believe that circumstances cited by the Carriers warrant a grant of additional 
time.  The Carriers were notified by USAC of their obligation to complete a Lifeline biennial audit on 
August 10, 2016 and given one year to complete the audit.  Especially considering the ample time the 
Carriers received to plan for and conduct the biennial audit, delays caused by disputes with contractors 
and employee churn do not warrant an extension of the one-year time period originally given.  
Additionally, the procedures and required review and response periods were communicated to the 
Carriers at the beginning to the yearlong engagement process.  That time period has been more than 
sufficient for other carriers required to fulfill the biennial audit requirement.  We expect the Carriers to 
file their respective final attestation reports by August 10, 2017.
5. Accordingly, IT IS ORDERED that, pursuant to sections 4(i), 4(j), and 5(c) of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 154(j), and 155(c), and Sections 0.91, 
0.291, and 1.46 of the Commission’s Rules, 47 CFR §§ 0.91, 0.291, and 1.46, the motions of TruConnect 
and Cox Communications ARE DENIED.
6. IT IS FURTHER ORDERED that, pursuant to section 1.102(b)(1) of the Commission’s 
rules, 47 CFR § 1.102(b)(1), this Order SHALL BE EFFECTIVE upon release.
FEDERAL COMMUNICATIONS COMMISSION
Kris Anne Monteith
Chief
Wireline Competition Bureau
                                                     
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Id.
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Id.
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47 CFR § 1.46.