Federal Communications Commission	DA 23-380
Before the
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554

In the Matter of

GCI Communication Corp.
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File No.:  EB-IHD-19-00028792
CD Acct. No.:  202332080026
FRN:  0001568880
ORDER

Adopted:  May 10, 2023	Released:  May 11, 2023

By the Chief, Enforcement Bureau:

1. The Enforcement Bureau of the Federal Communications Commission (FCC or Commission) has entered into a Consent Decree to resolve its investigation into whether GCI Communication Corp. (GCI) violated the Commission’s Rural Health Care (RHC) Program rules See 47 CFR §§ 54.600-54.680 (2019).  Citations to the CFR refer to the pre-October 1, 2019 version.  
 governing competitive bidding, the determination of urban rates, and the determination of rural rates. See 47 CFR § 54.607 (2019).
  To settle this matter, GCI agrees to a total settlement value of $42,614,595, including (a) a repayment to the Universal Service Fund in the amount of $26,614,595 and (b) a credit of $16,000,000 for GCI’s withdrawal of its Applications for Review related to Funding Years (FY) 2017-2019, GCI filed an Application for Review on November 9, 2018 related to WCB’s October 10, 2018 cost study determination of GCI’s FY2017 rural rates and an Application for Review on November 19, 2020 related to WCB’s October 20, 2020 cost study determinations of GCI’s FY2018 and FY2019 rural rates.  
 currently pending before the Commission.  GCI also agrees to implement enhanced compliance measures in connection with its participation in the RHC Program.  The FCC’s rules governing the RHC Program See 47 CFR §§ 54.600-54.680 (2019).  The RHC Program includes two subprograms: the Telecommunications Program (Telecom Program) and the Healthcare Connect Fund (HCF).  The Telecom Program provides support for the difference between the rural and urban rates for telecommunications services.  See Promoting Telehealth in Rural America, WC Docket No. 17-310, Report and Order, 34 FCC Rcd 7335, 7337, para. 4 (2019) (2019 Report and Order); Federal-State Joint Board on Universal Service, CC Docket No. 96-45, Report and Order, 12 FCC Rcd 8776, 9111-9112 (1997).  The HCF promotes the use of broadband services and the formation of health care consortia by providing a 65% discount on an array of advanced telecommunications and information services such as Internet access, dark fiber, business data, traditional Digital Subscriber lines, and private carriage services.  See 2019 Report and Order, 34 FCC Rcd at 7337, para. 4; see also Rural Healthcare Support Mechanism, WC Docket No. 02-60, Report and Order, 27 FCC Rcd 16678 (2012) (establishing the Healthcare Connect Fund).  While the Consent Decree references the RHC Program generally, the apparent rule violations at issue in the Consent Decree concern the Telecom Program. 
 are vital to protecting the Program and its resources from waste, fraud, and abuse.  This action will help further the Commission’s goal of supporting health care providers in delivering telehealth services to their rural communities.   
2. After reviewing the terms of the Consent Decree and evaluating the facts before us, we find that the public interest would be served by adopting the Consent Decree and terminating the associated investigation into GCI’s compliance with the RHC Program rules.  
3. In the absence of material new evidence relating to this matter, we do not set for hearing the question of GCI’s basic qualifications to hold or obtain any Commission license or authorization. See 47 CFR § 1.93(b).

4. Accordingly, IT IS ORDERED that, pursuant to the authority delegated by sections 0.111 and 0.311 of the Commission’s rules, 47 CFR §§ 0.111, 0.311.
 the attached Consent Decree IS ADOPTED and its terms incorporated by reference.
5. IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED in accordance with the terms of the attached Consent Decree.
6. IT IS FURTHER ORDERED that a copy of this Order and the Consent Decree shall be sent by e-mail to Becky Windt Pearson, Senior Vice President, Law and Corporate Advocacy and General Counsel, GCI Communication Corp., at bwindt-pearson@gci.com, and to John Nakahata, Esq., HWG LLP, counsel for GCI Communication Corp., at JNakahata@hwglaw.com.  

						FEDERAL COMMUNICATIONS COMMISSION




					Loyaan A. Egal
						Chief 
Enforcement Bureau

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Before the
FEDERAL COMMUNICATIONS COMMISSION
WASHINGTON, D.C. 20554

In the Matter of

GCI Communication Corp. 
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File No.:  EB-IHD-19-00028792
CD Acct. No.:  202332080026
FRN:  0001568880
CONSENT DECREE

1. The Enforcement Bureau of the Federal Communications Commission (FCC or Commission) and GCI Communication Corp. (GCI), by their authorized representatives, hereby enter into this Consent Decree for the purpose of terminating the Enforcement Bureau’s investigation into whether GCI Communication Corp. violated the Commission’s Rural Health Care (RHC) Program rules See 47 CFR §§ 54.600-54.680 (2019).  Citations to the CFR refer to the pre-October 1, 2019 version.  
 in connection with competitive bidding, urban rate setting, and rural rate setting.  
2. To resolve this matter, GCI agrees, through this Consent Decree entered on May 10, 2023, to a total settlement value of $42,614,595 that includes (a) a repayment to the Universal Service Fund in the amount of $26,614,595 and (b) a credit of $16,000,000 for GCI’s withdrawal of its Applications for Review and various appeals related to Funding Years (FY) 2017-2019, GCI filed an Application for Review on November 9, 2018 related to WCB’s October 10, 2018 cost study determination of GCI’s FY2017 rural rates and an Application for Review on November 19, 2020 related to WCB’s October 20, 2020 cost study determinations of GCI’s FY2018 and FY2019 rural rates.  
 as listed in Appendix B.  GCI also agrees to enhance its compliance measures in connection with its participation in the RHC Program.  Separately, GCI is also entering into a settlement agreement with the United States, acting through the U.S. Department of Justice, as to related claims.
I. DEFINITIONS
3. For the purposes of this Consent Decree, the following definitions shall apply:
(a) “Act” means the Communications Act of 1934, as amended. 47 U.S.C. § 151 et seq.

(b) “Adopting Order” means an order of the Bureau adopting the terms of this Consent Decree without change, addition, deletion, or modification.
(c) “Bureau” means the Enforcement Bureau of the Federal Communications Commission.
(d) “CD Acct. No.” means account number 202332080026, associated with payment obligations described in Paragraph 27 of this Consent Decree. 
(e) “Commission” and “FCC” mean the Federal Communications Commission and all of its bureaus and offices.
(f) “Communications Laws” means collectively, the Act, the Rules, and the published and promulgated orders and decisions of the Commission to which GCI is subject by virtue of its business activities, including but not limited to the RHC Program Rules.
(g) “Compliance Agreement” means the compliance obligations, program, and procedures attached to this Consent Decree as Appendix A.
(h) “DOJ Settlement” means the agreement entered into on May 10, 2023 by GCI and the United States of America, acting through the U.S. Department of Justice.  
(i) “Effective Date” means the date by which both the Bureau and GCI have signed the Consent Decree and the Bureau has released an Adopting Order.
(j) “First LOI” means the Letter of Inquiry issued by the Bureau to GCI on March 23, 2018. 
(k) “GCI” or “Company” means GCI Communication Corp. and its affiliates, subsidiaries, predecessors-in-interest, and successors-in-interest.
(l) “HCP” means health care provider.  
(m) “Investigation” means the investigation commenced by the Bureau in File Nos. EB-IHD-18-00026254 and EB-IHD-19-00028792 regarding whether GCI violated the RHC Program Rules.
(n) “Parties” means GCI and the Bureau, each of which is a “Party.”
(o) “RHC Program Rules” means Title 47, Code of Federal Regulations, sections 54.600-54.680, section 254 of the Act, and Commission orders related to the provision of service in the RHC Program.
(p) “Second LOI” means the Letter of Inquiry issued by the Bureau to GCI on May 28, 2020. 
(q) “USAC” means the Universal Service Administrative Company, which serves as the administrator for the federal Universal Service Fund. See 47 CFR § 54.701 (2019).

II. BACKGROUND
4. The RHC Program provides financial support to eligible rural health care providers so that all health care facilities—regardless of whether they are located in rural or urban areas—can implement the modern telecommunications systems that are vital to 21st century medical care. See Federal-State Joint Board on Universal Service, Report and Order, 12 FCC Rcd 8776, 8796, para. 35 (1997) (Federal-State Joint Board on Universal Service); see also 47 CFR § 54.602 (2019).
  The Telecommunications Program (Telecom Program) is part of the Commission’s RHC Program and is paid for through the Universal Service Fund (USF or Fund). The RHC Program also includes the HCF which provides a 65 percent discount on eligible expenses related to broadband connectivity to both health care providers and consortia.  See generally Rural Health Care Support Mechanism, Report and Order, 27 FCC Rcd 16678 (2012) (HCF Order); see also 47 CFR §§ 54.630-54.649 (2019).  Beginning in January 2014, rural health care providers receiving support for Internet access received support for these services through the HCF.  See HCF Order, 27 FCC Rcd at 16818-19, para. 354.  
  Through the Telecom Program, eligible rural health care providers can obtain supported services at rates that are no higher than the “urban rate,” defined as the highest tariffed or publicly available commercial rate for a similar service in any city with a population of 50,000 or more people in that state. 47 CFR §§ 54.605, 54.613 (2019).  Anchorage is the only city in Alaska with a population of 50,000 or more people. 
  The carrier providing the eligible service(s) is entitled to support payments from the Fund to account for the difference between the rural rate (the rate for telecommunications services provided to health care providers in rural areas, which is generally higher) and the urban rate (the rate for commercial customers in nearby urban areas, which is generally lower). Id. §§ 54.602, 54.609.  See generally Rural Health Care Support Mechanism, Report and Order, Order on Reconsideration, and Further Notice of Proposed Rulemaking, 18 FCC Rcd 24546 (2003) (2003 Order and Further Notice).    
   
5. Determining Rural Rates.  The Commission’s rules in effect during the relevant period established three methods for a service provider to determine its rural rate.  These methods must be considered in sequential order based on the factual circumstances. See Updated Frequently Asked Questions on Universal Service for Rural Health Care Providers, 12 FCC Rcd 13429, 13433 at part IV, Calculating Amount of Support, Question Nos. 19-21 (1997); see also 47 CFR § 54.607 (2019); The Wireline Competition Bureau Provides Guidance Regarding the Commission’s Rules For Determining Rural Rates in the Rural Health Care Telecommunications Program, Public Notice, WC Docket No. 02-60, DA 19-92, 2019 WL 696572 (WCB Feb. 15, 2019) (Determining Rural Rates Public Notice).
  The first method (Method 1) must be considered if the service provider itself offers comparable services to commercial customers that provide a basis for comparison. 47 CFR § 54.607(a) (2019).  
  If so, the Commission’s rules required that a service provider’s rural rate must “be the average of the rates actually being charged to commercial customers, other than health care providers, for identical or similar services provided by the telecommunications carrier providing the service in the rural area in which the health care provider is located.” Id.  The rates averaged to calculate the rural rate must not include any rates reduced by universal service support mechanisms, but a service provider may consider its pre-discount prices for services provided to E-rate customers in determining its rural rates.  See id. 
  
6. However, where the telecommunications carrier “is not providing any identical or similar services in the rural area,” the second method (Method 2) must be considered. See Updated Frequently Asked Questions on Universal Service for Rural Health Care Providers, 12 FCC Rcd 13429, 13433 at part IV, Calculating Amount of Support, Question Nos. 19-21 (1997); see also 47 CFR § 54.607(b) (2019); Determining Rural Rates Public Notice. 
  Method 2 provided that “the rural rate shall be the average of the tariffed and other publicly available rates, not including any rates reduced by universal service programs, charged for the same or similar services in that rural area over the same distance as the eligible service by other carriers.” 47 CFR § 54.607(b) (2019).
   
7. The last and final method (Method 3) must be considered only if there are no tariffed or publicly available rates for such services in that rural area, or if the carrier reasonably determines that Method 1 or Method 2 for calculating the rural rate is unfair. See Updated Frequently Asked Questions on Universal Service for Rural Health Care Providers, 12 FCC Rcd 13429, 13433 at part IV, Calculating Amount of Support, Question Nos. 19-21 (1997); see also 47 CFR § 54.607(b) (2019); Determining Rural Rates Public Notice.
  In such cases, “then the carrier shall submit for the state commission’s approval, for intrastate rates, or the Commission’s approval, for interstate rates, a cost-based rate for the provision of the service in the most economically efficient, reasonably available manner.” 47 CFR § 54.607(b) (2019).
  Where a carrier sought approval of a state commission for intrastate rates or the Commission for interstate rates, “a justification of the proposed rural rate, including an itemization of the costs of providing the requested service” is required. Id. § 54.607(b)(1).
  
8. Competitive Bidding.  The Commission has repeatedly stated that competitive bidding rules are vital to ensuring that the Fund is “used wisely and efficiently” across USF-funded programs, and that health care providers “are aware of cost-effective alternatives” to ensure fiscal responsibility and to limit waste, fraud, and abuse of the Fund. Federal-State Joint Board on Universal Service, 12 FCC Rcd at 9133-34, paras. 686, 688; see also Schools and Libraries Universal Service Support Mechanism, Fifth Report and Order, 19 FCC Rcd 15808, 15813, para. 13 (2004) (stating that the Commission is committed to deterring inappropriate uses of universal service monies and to rapidly detect and address potential misconduct including waste, fraud, and abuse); HCF Order, 27 FCC Rcd at 16778, paras. 229-30 (“[C]ompetitive bidding furthers the competitive neutrality requirement . . . of the Act by ensuring that universal service support does not disadvantage one provider over another . . . [A]ll entities participating in the [RHC Program] must conduct a fair and open competitive bidding process prior to submitting a request for funding . . . .”); and Schools and Libraries Universal Service Support Mechanism, Third Report and Order and Second Further Notice of Proposed Rulemaking, 18 FCC Rcd 26912, 26940, para. 66 (2003) (Schools and Libraries Third Report and Order) (stating that the competitive bidding process is critical to preventing waste, fraud, and abuse of program resources).
  Fundamental to this is the Commission’s requirement that RHC Program contracts be awarded through a competitive bidding process. 47 CFR § 54.603(a) (2019).  See also Federal-State Joint Board on Universal Service, 12 FCC Rcd at 9133-34, paras. 686, 688 (“Consistent with the Joint Board’s recommendation for eligible schools and libraries, we conclude that eligible health care providers shall be required to seek competitive bids for all services eligible for support pursuant to section 254(h) by submitting their bona fide requests for services to the Administrator [for posting].”).
  The competitive bidding process must be conducted in a manner such that no bidder receives an unfair advantage over another bidder. See, e.g., Request for Review of Decisions of the Universal Service Administrator by MasterMind Internet Services, Inc., Federal-State Joint Board on Universal Service, Order, CC Docket No. 96-45, 16 FCC Rcd 4028 (2000) (Mastermind Order) (finding that the FCC Form 470 contact person influences an applicant’s competitive bidding process by controlling the dissemination of information regarding the services requested and, when an applicant delegates that power to an entity that also participates in the bidding process as a prospective service provider, the applicant impairs its ability to hold a fair and open competitive bidding process).  See also Requests for Review of Decisions of the Universal Service Administrator by Hospital Networks Management, Inc., Manchaca, TX, Verizon Business Services, Arlington, VA, Order, 31 FCC Rcd 5731, 5741, para. 20 (WCB 2016) (“The principles underlying the Mastermind Order and other orders addressing fair and open competitive bidding not only apply to the E-rate program . . . , but also to participants in the rural health care program.  Indeed, the mechanics of the bidding processes in the rural health care and E-rate programs are effectively the same.”) (internal citation omitted); Request for Review, Franciscan Skemp Waukon Clinic, Waukon, IA, Order, 29 FCC Rcd 11714, 11717, para. 9 (WCB 2014) (finding that signing a Telecom Program contract before the expiration of the 28-day waiting period impairs the applicant’s ability to hold a fair and open competitive bidding process).  
  The Commission has held that the RHC Program rules, “including the competitive bidding rules, apply to all applicants and service providers.” HCF Order, 27 FCC Rcd at 16737, para. 126.  
  As service providers have long been aware, the Commission will take action against such service providers that seek to secure an unfair advantage in competing for contracts supported by the USF or otherwise engage in conduct that threatens to damage the integrity of USF programs in violation of the Commission’s rules. Service providers have been on notice that funding commitments resulting from contracts awarded in violation of the competitive bidding rules will be rescinded and the disbursed funds recovered.  In 2007, the Commission noted that “the danger of waste, fraud, and abuse by service providers is as great as the danger of such conduct by rural health care providers” and advised that “funds disbursed from the . . . rural health care support mechanism[] in violation of a Commission rule that implements the statute or a substantive program goal should be recovered.  Sanctions, including enforcement action, are appropriate in cases of waste, fraud, and abuse”  Comprehensive Review of the Universal Service Fund Management, Administration, and Oversight, Report and Order, 22 FCC Rcd 16372, 16386-88, paras. 26, 30 (2007) (Comprehensive Report and Order).  See, e.g., HCF Order, 27 FCC Rcd at 16737, para. 126 (“To the extent there are violations of the competitive bidding rules, such as sharing of inside information during the competitive bidding process, USAC will adjust funding commitments or recover any disbursed funds through its normal process.”).  Mastermind Order, 16 FCC Rcd 4028; see also Request for Review of Decisions of the Universal Service Administrator by Joseph M. Hill, Trustee in Bankruptcy for Lakehills Consulting, LP., CC Docket No. 02-6, Order, 26 FCC Rcd 16586 (2011).
  The Commission has repeatedly made clear that compliance with its bidding rules is a prerequisite for receipt of payments from the Fund and that those who violate the competitive bidding rules are not entitled to funding. See, e.g., HCF Order, 27 FCC Rcd at 16737, para. 126; Comprehensive Report and Order, 22 FCC Rcd at 16388, para. 30. 
  
9. Determining Urban Rates.  The “urban rate” for a service is a rate no higher than the highest tariffed or publicly-available rate charged to a commercial customer for a functionally similar service in any city with a population of 50,000 or more in that state. See 47 CFR § 54.605(a) (2019).   
  To reduce administrative burdens, at the time of the apparent violations, service providers and health care providers could obtain and use urban rates from a list of acceptable urban rates from USAC’s website. See 2003 Order and Further Notice, 18 FCC Rcd at 24573, para. 53.  The website, previously available at www.usac.org/rhc/telecommunications/tools/UrbanRates/search.asp, is no longer available.  
  If an urban rate other than one posted on USAC’s website was used, a health care provider was required to follow standard processes by submitting documentation of that urban rate to USAC with its Form 466.  Section 54.609 of the Commission’s rules provides that the amount of support that is available through the Telecom Program for an eligible service is based on the difference, if any, between the urban rate and the rural rate charged for the service as defined by the Commission’s rules. See 47 CFR §§ 54.605, 54.607, 54.609 (2019).
  
10. GCI Investigation.  GCI is a company that was incorporated in Alaska on May 23, 1990. Response to Letter of Inquiry from Stephen Miller, Harris, Wiltshire & Grannis LLP, to Rakesh Patel and David Sobotkin, FCC Enforcement Bureau, at 2 (Apr. 27, 2018).  
  It is an indirect, wholly owned subsidiary of Liberty Broadband Corporation. Liberty Broadband Corporation, Annual Report (Form 10-K), at I-2 (Feb. 26, 2021).  
 
11. GCI provides telecommunications services to health care providers through the RHC Program.  GCI is a long-time participant in the RHC Program and received more USF funding in the Telecom Program in FY2012 through FY2021 than any other service provider. Information on file in EB-IHD-18-00026254 and EB-IHD-19-00028792.   
  
12. On March 23, 2018, the Enforcement Bureau sent GCI a Letter of Inquiry (First LOI). Letter of Inquiry from Rakesh Patel, FCC Enforcement Bureau, to Ronald Duncan, Chief Executive Officer (CEO), GCI, and Jennifer Bagg, Harris, Wiltshire & Grannis LLP (Mar. 23, 2018) (First LOI).
  As part of the First LOI, the Enforcement Bureau sought to understand GCI’s involvement in the RHC Program beginning January 1, 2015.  To that end, the First LOI sought responses and documents related to how GCI determined its rural rates, its participation in the competitive bidding process, and its setting of urban rates. First LOI, at 10.  

13. In December 2019, GCI voluntarily disclosed to the Bureau that it had received an allegation from a former employee of a competitive bidding violation involving GCI’s RHC Telecom Program contract with Eastern Aleutians Tribe.  GCI produced relevant documents to the Bureau on January 28 and February 28, 2020.  
14. In light of this issue, GCI conducted an investigation of the bid documents, offers, and amendments for all contracts active from January 2015 to 2019, including those that were bid prior to 2015 but still active in 2015.  GCI presented its findings to EB on February 24, 2020, including by voluntarily disclosing additional competitive bidding violations.  GCI produced these contracts and associated documents on April 17, 2020.   
15. In the course of FY2020 bid compliance work, GCI learned that it had accidentally understated the urban rate it charged to certain HCPs because it did not charge for the Anchorage hub port.  GCI voluntarily disclosed this issue to the Bureau in the February 24, 2020 meeting discussed above.   
16. In December 2019, GCI also discovered and disclosed to the Bureau that the litigation hold placed on certain of its employees’ email boxes in connection with receipt of the Letter of Inquiry had been inadvertently released, and that GCI had deleted mailboxes and destroyed laptops of relevant employees when they left the company.  GCI reinstated the holds soon after discovering the error.  In addition to these document preservation failures, GCI also failed to preserve relevant RHC Program documents, resulting in the loss of an unknown number of documents relevant to the Investigation.  
17. Subsequently, on May 28, 2020, the Enforcement Bureau sent GCI a second Letter of Inquiry (Second LOI). Letter of Inquiry from Rakesh Patel, FCC Enforcement Bureau, to John Nakahata and Jennifer Bagg, Harris, Wiltshire & Grannis LLP (May 28, 2020).
  As part of the Second LOI, the Enforcement Bureau sought to understand GCI’s RHC Program document retention policies, procedures, and practices for the period of time beginning in January 2015.
18. In connection with the First LOI and Second LOI, GCI made a series of document productions, provided narrative responses and documents responsive to the Bureau’s Requests for Information, and fully cooperated in the Bureau’s interviews of GCI employees and officers.  Based on these and GCI’s voluntary disclosures, the Parties agree that these efforts and actions support the following: 
· Violations of the RHC Program Rules governing the determination of rural rates in connection with rural rates set during FY2015-FY2016:
o GCI charged certain rural rates that were not in compliance with the three methods established by Commission rules for setting rural rates.  In instances where GCI’s rural rates did not accord with Method 1 or 2, GCI did not seek and receive cost-based rate approval from the Commission under Method 3.  
· Violations of the RHC Program Rules governing the competitive bidding process in connection with five contracts signed with HCPs in 2015 and 2016: 
o Eastern Aleutian Tribes.  GCI made a substantial change to the monthly recurring charge (MRC) in its contract with Eastern Aleutian Tribes in 2015 While the contract was signed outside of the applicable statute of limitations, GCI requested payment from the Fund in connection with this contract within the tolled statute of limitations.  
 after the contract had already been signed by the health care provider.  Without any additional Form 465 filing, GCI increased the satellite service price by 33%; the total MRC for service to all Eastern Aleutian Tribes clinics increased from $297,738 to $393,038. GCI Medical Services Agreement HC-425 (Draft), GCI-00053944-00053953; GCI Medical Services Agreement HC-426 (Apr. 10, 2015), GCI-00053443-0053452.  
  This cardinal change GCI admits that this is a cardinal change that violates Commission rules.  Nov. 19, 2021 GCI Presentation, at 7; Apr. 21, 2021 GCI Presentation, at 12.  
 to the initial contract was effectuated without competitive bidding in violation of RHC Program rules and Commission precedent.  The contract was for a five-year term at an estimated annual recurring charge of $4,716,456; the value of the contract over the five-year term is $23,582,280. GCI Medical Services Agreement HC-426 (Apr. 10, 2015), GCI-00053443-0053452. 
  GCI received $9,789,574.09 in payments from the USF in connection with this contract. Information on file in EB-IHD-18-00026254 and EB-IHD-19-00028792.  

o Norton Sound Health Corporation (NSHC).  GCI apparently contracted with NSHC for a longer term than was identified during the competitive bidding process.  In May 2015, GCI and NSHC signed a five-year contract (HC-429) using the rates listed in the proposal for a three-year term for an estimated annual recurring charge of $1,148,400; the value of the contract over the five-year term is $5,742,000. GCI Medical Services Agreement HC-429 (May 7, 2015), GCI-00053676-00053685.  
  GCI received $1,139,856 in payments from the USF in connection with this contract. Information on file in EB-IHD-18-00026254 and EB-IHD-19-00028792.  
  
o Southcentral Foundation, St. Paul clinic (SCF-St. Paul).  In July 2015, GCI and SCF signed a five-year contract (HC-439) that included the St. Paul clinic.  In April 2016, the parties signed an amended contract (HC-439-2) for one of the St. Paul circuits at a price and service level that were in neither the proposal nor the original contract.  The value of the contract amendment over the remaining 53 months of the contract term was approximately $1,557,140.  GCI received $425,713.86 in payments from the USF in connection with this amended contract for the St. Paul clinic. Id.   
  
o Frontier Community Services (FCS).  In November 2016, FCS and GCI entered into a five-year contract (HC-487-01) that included services added after the competitive bidding period had closed and after GCI had been awarded the contract.  The total MRC in HC-487-01 is $6,900. The MRC for the two services added in the November 11, 2016 pricing addendum is $2,300.  GCI Healthcare Service Order HC-487-01 (Nov. 18, 2016), GCI-00001558-1568.
  The value over the life of the five-year contract is $414,000.  GCI received $189,733.62 in payments from the USF in connection with this contract. Information on file in EB-IHD-18-00026254 and EB-IHD-19-00028792.  
 
o Southcentral Foundation, Wasilla clinic (SCF-Wasilla).  In July 2015, GCI and SCF signed a one-year contract (HC-440) for 100 Mbps service at the Wasilla clinic at $5,200/month. GCI Medical Services Agreement HC-440 (July 8, 2015), GCI-00053795-00053804.  
  The proposal did not contain either the one-year term or the related price. A Proposal for Southcentral Foundation (June 25, 2015), GCI-00053704-00053721. 
  The estimated value of the one-year contract is $62,400.  GCI received $38,612.93 in payments from the USF in connection with this contract. Information on file in EB-IHD-18-00026254 and EB-IHD-19-00028792.  
  
· Violations of the RHC Program Rules governing the determination of urban rates charged to HCPs in FY2015 through FY2019:
o During the Commission’s investigation, GCI disclosed that the urban rate it had charged to certain HCPs was too low. Letter from John Nakahata and Jared Marx, Harris, Wiltshire & Grannis LLP, to Sarah McNally and Carla Conover, FCC Enforcement Bureau, at 4-5 (Oct. 7, 2020) (Oct. 7, 2020 Letter); January 15, 2021 GCI subpoena response.  
  GCI admits that this resulted in excessive rural rate reimbursement amounts being requested and received by GCI from the USF Oct. 7, 2020 Letter; July 12, 2021 GCI Presentation, at 6.
 in violation of 47 CFR § 54.609. Section 54.609(a) states:  “The amount of universal service support provided for an eligible service to be funded from the Telecommunications Program shall be the difference, if any, between the urban rate and the rural rate charged for the service, as defined herein.”  47 CFR § 54.609(a) (2019).  
  For FY2015-FY2019, the incorrect rate calculation resulted in excess payments of $457,852.65. Oct. 7, 2020 Letter, at 4-5; January 15, 2021 GCI subpoena response.  
  
III. TERMS OF AGREEMENT
19. Adopting Order.  The provisions of this Consent Decree shall be incorporated by the Bureau in an Adopting Order.
20. Jurisdiction.  GCI agrees that the Bureau has jurisdiction over it and the matters contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree.
21. Effective Date; Violations.  The Parties agree that this Consent Decree shall become effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this Consent Decree shall have the same force and effect as any other order of the Commission.  Any violation of the Adopting Order or of the terms of this Consent Decree shall constitute a separate violation of a Commission order, entitling the Commission to exercise any rights and remedies attendant to the enforcement of a Commission order.  
22. Termination of Investigation.  In express reliance on the covenants and representations in this Consent Decree and the DOJ Settlement and to avoid further expenditure of public resources, the Bureau agrees to terminate the Investigation and to resolve all claims for repayment to the Universal Service Fund arising from certain matters through FY2019 that were the subject of the Investigation, as identified in Appendices C, D, and E.  In consideration, GCI agrees to the terms, conditions, and procedures contained herein, and to withdraw its Applications for Review and various appeals, as listed in Appendix B.  The Bureau also agrees, on behalf of itself and the Wireline Competition Bureau, that the audit of FY2017 funding requests for services provided by GCI that USAC initiated on or about June 23, 2020 will be terminated.  The Bureau further agrees on behalf of itself, the Wireline Competition Bureau, and the Office of the Managing Director that, in the absence of new material evidence, none of the Bureau, the Wireline Competition Bureau, or the Office of the Managing Director will use the facts developed in the Investigation through the Effective Date, or the existence of this Consent Decree or DOJ Settlement, to institute any new proceeding on its own motion against GCI concerning the matters as identified in the Appendices, or to set for hearing the question of GCI’s basic qualifications to be a Commission licensee or hold Commission licenses or authorizations based on the matters that were the subject of the Investigation. See 47 CFR § 1.93(b) (2019).
 
23. Admission of Liability.  GCI admits solely for the purpose of this Consent Decree and for Commission civil enforcement purposes related to this Consent Decree, and in express reliance on the provisions of Paragraph 22 herein, that its actions in Paragraph 18 violated sections 54.603, 54.605, 54.607, 54.609, and 54.615 of the Commission’s rules, See id. §§ 54.603, 54.605, 54.607, 54.609, and 54.615.  
 and that it accepts sole responsibility for those actions.  
24. Compliance Agreement.  For purposes of settling the matters set forth herein, GCI agrees that it shall implement the Compliance Agreement attached as Appendix A, designed to ensure future compliance with the RHC Program Rules and with the terms and conditions of this Consent Decree.
25. Section 208 Complaints; Subsequent Investigations.  Nothing in this Consent Decree shall prevent the Commission or its delegated authority from adjudicating complaints filed pursuant to section 208 of the Act 47 U.S.C. § 208.
 against GCI or its affiliates for alleged violations of the Act, or for any other type of alleged misconduct, regardless of when such misconduct took place.  The Commission’s adjudication of any such complaint will be based solely on the record developed in that proceeding.  Except as expressly provided in this Consent Decree, this Consent Decree shall not prevent the Commission from investigating new evidence of noncompliance by GCI with the Communications Laws.
26. Settlement Amount.  GCI agrees to a global settlement with the FCC’s Enforcement Bureau and with the U.S. Department of Justice resulting in a net cash payment of $40,851,657 as follows:
(a) GCI agrees to a Settlement Amount of $42,614,595 (Settlement Amount) to fully resolve the Bureau’s Investigation.
· GCI will repay $26,614,595 to the Universal Service Fund (Repayment Amount).
· The Commission will credit GCI $16,000,000 for withdrawal of its Applications for Review and various appeals related to Funding Years FY2017-FY2019, as listed in Appendix B, upon GCI’s withdrawal of those Applications for Review and appeals. GCI’s Application for Review filed on November 9, 2018 related to WCB’s October 10, 2018 cost study determination of GCI’s FY2017 rural rates and an Application for Review on November 19, 2020 related to WCB’s October 20, 2020 cost study determinations of GCI’s FY2018 and FY2019 rural rates.  

(b) Pursuant to the DOJ Settlement, GCI agrees to pay to the United States $40,242,546 that shall be offset by GCI’s payment of $26,005,484 to the USF pursuant to this Consent Decree.  The DOJ Settlement resolves certain civil or administrative monetary claims the United States has against GCI under, among other rules and laws, the False Claims Act, related to the covered conduct as defined in the DOJ Settlement. 
27. Repayment Amount.  GCI agrees to pay $26,614,595 (Repayment Amount) to the Universal Service Fund and complete the withdrawals specified in Paragraph 26(a) within thirty (30) calendar days of the Effective Date.  GCI acknowledges and agrees that upon execution of this Consent Decree, the Settlement Amount shall become a “Claim” or “Debt” as defined in 31 U.S.C. § 3701(b)(1). Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996).
  Upon an Event of Default, all procedures for collection as permitted by law may, at the Commission’s discretion, be initiated.  GCI shall send electronic notification of the Repayment Amount payment to Meghan Ingrisano, Chief, Fraud Division, Enforcement Bureau, Federal Communications Commission, 45 L Street NE, Washington, D.C. 20554, or her successor or designee, with a copy submitted electronically to Meghan Ingrisano at Meghan.Ingrisano@fcc.gov, on the date said payment is made.  Below are instructions that payors should follow based on the form of payment selected. For questions regarding payment procedures, please contact the Financial Operations Group Help Desk by phone at 1-877-480-3201 (option #1).
 
· Payment by wire transfer must be made to ABA Number 021030004, receiving bank TREAS/NYC, and Account Number 27000001.  In the OBI field, enter the FRN(s) captioned above and the letters “FORF”.  In addition, a completed Form 159 FCC Form 159 is accessible at https://www.fcc.gov/licensing-databases/fees/fcc-remittance-advice-form-159.
 or printed Commission Registration System (CORES) form Information completed using the Commission’s Registration System (CORES) does not require the submission of an FCC Form 159.  CORES is accessible at https://apps.fcc.gov/cores/userLogin.do.
 must be faxed to the Federal Communications Commission at 202-418-2843 or e-mailed to RROGWireFaxes@fcc.gov on the same business day the wire transfer is initiated.  Failure to provide all required information in Form 159 or CORES may result in payment not being recognized as having been received.  When completing FCC Form 159 or CORES, enter the Account Number in block number 23A (call sign/other ID), enter the letters “FORF” in block number 24A (payment type code), and enter in block number 11 the FRN(s) captioned above (Payor FRN). Instructions for completing the form may be obtained at http://www.fcc.gov/Forms/Form159/159.pdf. 
  For additional detail and wire transfer instructions, go to https://www.fcc.gov/licensing-databases/fees/wire-transfer. 
· Payment by credit card must be made by using CORES at https://apps.fcc.gov/cores/userLogin.do.  To pay by credit card, log-in using the FCC Username associated to the FRN captioned above.  If payment must be split across FRNs, complete this process for each FRN.  Next, select “Manage Existing FRNs | FRN Financial | Bills & Fees” from the CORES Menu, then select FRN Financial and the view/make payments option next to the FRN.  Select the “Open Bills” tab and find the bill number associated with the CD Acct. No.  The bill number is the CD Acct. No. with the first two digits excluded (e.g., CD 1912345678 would be associated with FCC Bill Number 12345678).  After selecting the bill for payment, choose the “Pay by Credit Card” option.  Please note that there is a $24,999.99 limit on credit card transactions.
· Payment by ACH must be made by using CORES at https://apps.fcc.gov/cores/userLogin.do.  To pay by ACH, log in using the FCC Username associated to the FRN captioned above.  If payment must be split across FRNs, complete this process for each FRN.  Next, select “Manage Existing FRNs | FRN Financial | Bills & Fees” on the CORES Menu, then select FRN Financial and the view/make payments option next to the FRN. Select the “Open Bills” tab and find the bill number associated with the CD Acct. No.  The bill number is the CD Acct. No. with the first two digits excluded (e.g., CD 1912345678 would be associated with FCC Bill Number 12345678).  Finally, choose the “Pay from Bank Account” option.  Please contact the appropriate financial institution to confirm the correct Routing Number and the correct account number from which payment will be made and verify with that financial institution that the designated account has authorization to accept ACH transactions.
28. Event of Default.  GCI agrees that an Event of Default shall occur upon the failure by GCI to pay the full amount of the Repayment Amount or complete the withdrawals specified in Paragraph 26(a) on or before the due date specified in this Consent Decree.
29. Interest, Charges for Collection, and Acceleration of Maturity Date.  After an Event of Default has occurred under this Consent Decree, the then unpaid amount of the Settlement Amount shall accrue interest, computed using the U.S. Prime Rate in effect on the date of the Event of Default plus 4.75%, from the date of the Event of Default until payment in full.  Upon an Event of Default, the then unpaid amount of the Settlement Amount, together with interest, any penalties permitted and/or required by the law, including but not limited to 31 U.S.C. § 3717 and administrative charges, plus the costs of collection, litigation, and attorneys’ fees, shall become immediately due and payable, without notice, presentment, demand, protest, or notice of protest of any kind, all of which are waived by GCI.
30. Waivers.  As of the Effective Date, GCI waives any and all rights it may have to seek administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest the validity of this Consent Decree and the Adopting Order.  GCI shall retain the right to challenge Commission interpretation of the Consent Decree or any terms contained herein.  If either Party (or the United States on behalf of the Commission) brings a judicial action to enforce the terms of the Consent Decree or the Adopting Order, neither GCI nor the Commission shall contest the validity of the Consent Decree or the Adopting Order, and GCI shall waive any statutory right to a trial de novo.  GCI hereby agrees to waive any claims it may otherwise have under the Equal Access to Justice Act See 5 U.S.C. § 504; 47 CFR §§ 1.1501–1.1530 (2019).
 relating to the matters addressed in this Consent Decree.
31. Severability.  The Parties agree that if any of the provisions of the Consent Decree shall be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not containing the particular unenforceable provision or provisions, and the rights and obligations of the Parties shall be construed and enforced accordingly.
32. Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any court of competent jurisdiction, it shall become null and void and may not be used in any manner in any legal proceeding.
33. Subsequent Rule or Order.  The Parties agree that if any provision of the Consent Decree conflicts with any subsequent Rule or order adopted by the Commission (except an order specifically intended to revise the terms of this Consent Decree to which GCI does not expressly consent) that provision will be superseded by such Rule or order.
34. Successors and Assigns.  GCI agrees that the provisions of this Consent Decree shall be binding on its successors, assigns, and transferees.
35. Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall constitute a final settlement between the Parties with respect to the Investigation.  
36. Modifications.  This Consent Decree cannot be modified without the advance written consent of both Parties.
37. Paragraph Headings.  The headings of the paragraphs in this Consent Decree are inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent Decree.
38. Authorized Representative.  Each Party represents and warrants to the other that it has full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent Decree and to bind the Party to its terms and conditions.
39. Counterparts.  This Consent Decree may be signed in counterpart (including electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and all of the counterparts together shall constitute one and the same fully executed instrument.



________________________________
Loyaan A. Egal
Chief
Enforcement Bureau



________________________________
Date



________________________________
Rebecca Windt Pearson
Senior Vice President, Law and Corporate Advocacy, and General Counsel
GCI Communication Corp.



________________________________
Date


	Federal Communications Commission	DA 23-380

	8	
APPENDIX A

COMPLIANCE AGREEMENT FOR GCI COMMUNICATION CORP.

	PREAMBLE:  In accordance with the terms set forth in the Settlement Agreement and the Consent Decree (as defined herein), GCI Communication Corp. (GCI) agrees to the undertakings described in this Compliance Agreement, including reasonable steps to ensure that its future participation in the Rural Health Care Program complies fully with all Rural Health Care Program Rules. 
1. Definitions.
For the purposes of this Compliance Agreement, the following definitions shall apply:

“Act” means the Communications Act of 1934, as amended.

“Commission” or “FCC” means the Federal Communications Commission and all of its bureaus and offices.

“Compliance Agreement” means this document, titled “Compliance Agreement for GCI Communication Corp.,” which is incorporated as Appendix A to the Consent Decree.

“Compliance Manual” means the Compliance Manual required by Section 5.

“Consent Decree” means the Consent Decree between GCI and EB, executed simultaneously with this agreement, to which this Compliance Agreement is attached and incorporated as Appendix A. 

“Covered Personnel” or “Covered Person” means all employees and officers of GCI who perform, supervise, oversee, or otherwise conduct any activities that relate to GCI’s responsibilities under the RHC Program Rules, except for employees that solely perform activities involving network operations or maintenance or technical support.  For purposes of Section 5 (Compliance Manual) and Section 6 (Compliance Training Program), Covered Personnel shall also include any personnel used by any Covered Third Party.             

“Covered Third Party” or “Covered Third Parties” means any agent or independent contractor of GCI contracted to perform activities that relate to GCI’s responsibilities under the RHC Program Rules, including responses to Requests for Proposals, except for outside legal counsel and agents or independent contractors that solely perform activities involving network operations or maintenance, technical support, or data analytics.                                        

“Days” shall mean calendar days (unless otherwise specified).

“EB” means the Enforcement Bureau of the Commission.  

“Effective Date” means the effective date of the Consent Decree, to which this Compliance Agreement is attached and incorporated as Appendix A.

“GCI” or “Company” means GCI Communication Corp. and its successors in interest or assigns. 

“GCI Compliance Plan” means the compliance plan required by Section 4.

“GCI Compliance Hotline” or “Compliance Hotline” shall mean the toll-free telephone number described in Section 4(b).  

“OIG” means the Office of the Inspector General of the Commission.

“OGC” means the Office of General Counsel of the Commission.

“Operating Procedures” means the standard internal operating procedures and compliance policies established by GCI to implement the Compliance Agreement.

“Parties” means GCI and the FCC, each of which is a “Party.”

“RHC Program Rules” means Title 47, Code of Federal Regulations, sections 54.600-54.680, section 254 of the Act, as amended, and Commission orders related to the provision of service in the RHC Program.

“Settlement Agreement” means the Settlement Agreement entered into by the United States, acting through the U.S. Department of Justice, and GCI on May 10, 2023.

“USAC” means the Universal Service Administrative Company, which serves as the administrator for the federal Universal Service Fund. 

“WCB” means the Wireline Competition Bureau of the Commission.

2. Term of Compliance Agreement.
 (a) The obligations set forth herein shall apply for a period of three years from the Effective Date or for such longer period as may be provided under this section.  If GCI does not materially comply with this Compliance Agreement and all RHC Program Rules, as reasonably determined by the FCC, during any twelve (12) month period, the obligations set forth herein may be extended, in the discretion of the FCC, by an additional year.  Further, such obligations shall continue (including during any extension period) until GCI has materially complied with this Compliance Agreement and all RHC Program Rules for one (1) consecutive twelve (12) month period, subject to the limitation set forth in subsection (b) of this section.  A determination that GCI has complied with the obligations in this Compliance Agreement is not intended to and shall not constitute a determination that GCI has complied with any or all RHC Program Rules for any other purpose.

(b) The obligations of this Compliance Agreement shall not remain in effect beyond the seventh anniversary from the Effective Date, except as otherwise provided under this subsection.  If by such date, GCI has not materially complied with this Compliance Agreement and with all Rural Health Care Program Rules, as determined by the FCC, then GCI shall remain subject to the remedies provided for in Section 12, at the discretion of the FCC, and the parties may also renegotiate an extension of this Compliance Agreement to address any noncompliance by GCI, to the extent they deem such an extension to be appropriate or desirable.

3. Compliance Officer. 
(a) Within thirty (30) days after the Effective Date, GCI shall designate a senior corporate manager with the requisite corporate and organizational authority to serve as a Compliance Officer to discharge the duties set forth in this Compliance Agreement.  The Compliance Officer must have knowledge of and experience with the RHC Program Rules prior to assuming his/her duties.  The Compliance Officer shall report directly to the President, CEO, General Counsel, or Vice President of Ethics and Compliance of GCI, and shall not be, or be directly or indirectly subordinate to, the Chief Financial Officer or Vice President of Operations, or have any responsibilities for legal counsel functions for GCI.
(b) The Compliance Officer shall be responsible for, without limitation, implementing and administering this Compliance Agreement and ensuring that GCI complies with its terms and conditions (including taking corrective action as necessary).  GCI shall ensure that Covered Third Parties will be subject to the Compliance Officer’s oversight.
(c) GCI shall provide the Compliance Officer with adequate staffing to support the Compliance Officer in fulfilling the Compliance Officer’s responsibilities.
(d) GCI shall provide written notice to the FCC of the identity of the initial Compliance Officer within ten (10) days of that appointment.  Thereafter, GCI shall provide written notice to the FCC within ten (10) days of any changes in the identity of the Compliance Officer, or any actions that could adversely affect the Compliance Officer’s ability to perform the Officer’s duties under this Compliance Agreement.  
4. GCI Compliance Plan and Compliance Hotline. 
(a)	GCI agrees that it shall, within ninety (90) days after the Effective Date, develop and implement a compliance plan (GCI Compliance Plan) designed to ensure future compliance with the RHC Program Rules and containing the terms and conditions set forth herein.  GCI shall provide copies of the GCI Compliance Plan and submit any revisions to the FCC in a monthly report.  The GCI Compliance Plan shall expressly incorporate the requirements of this Compliance Agreement, including, without limitation, the operating procedures described in Section 5, the training required in Section 6, and the audits required by Section 10.

(b)	GCI Compliance Hotline:  GCI shall maintain a compliance hotline (or establish one within thirty (30) days after the Effective Date if such a hotline does not exist on the Effective Date) to receive complaints and tips from the public, as well as from Covered Personnel, about potential fraudulent or other irregular activity associated with GCI’s Rural Health Care Program participation.  GCI shall publish the Compliance Hotline conspicuously on the first page of its website in a prominent location, and also affirmatively make enrolled customers aware of the Compliance Hotline and its purpose through other reasonably effective means.  GCI shall also publish this Compliance Hotline in a prominent location in the Compliance Manual.  The Compliance Hotline shall allow anonymous reporting.  Complaints and tips received shall be promptly forwarded to the Compliance Officer and investigated.
  
5. Compliance Manual.  Within ninety (90) days after the Effective Date, the Compliance Officer shall develop and, to the extent consistent with applicable law, distribute electronically or in hard copy a Compliance Manual to all Covered Personnel and Covered Third Parties.  The Compliance Manual shall explain the RHC Program Rules, set forth the Operating Procedures that Covered Personnel and Covered Third Parties shall follow to help ensure GCI’s compliance with the RHC Program Rules, and include the information described in subsection (b) of this section.  The requirements of subsections (b)(i) and (b)(ii) of this section shall be applicable to all Covered Personnel, whether employed by Covered Third Parties or by GCI.  The phone numbers for the GCI Compliance Hotline, the Commission’s whistleblower hotline, and the USAC whistleblower hotline shall be displayed in a prominent location in the Compliance Manual.  GCI shall periodically review and revise the Compliance Manual as necessary to ensure that its contents remain current and accurate.  To the extent consistent with applicable law, GCI shall distribute electronically any revisions to the Compliance Manual promptly to all Covered Personnel and Covered Third Parties. 
(a)	Any agreements between GCI and Covered Third Parties shall contain provisions to ensure that the terms of this Compliance Agreement are satisfied.  Any agreements between GCI and Covered Third Parties that are in effect on the Effective Date shall be modified to comply with this section.

(b)	To the extent consistent with applicable law, GCI shall require that Covered Third Parties be subject to the following additional requirements, as to which GCI will exercise reasonable oversight, each of which shall be set forth in its agreements with those parties.  All agreements between GCI and Covered Third Parties shall include the following terms:  

(i) Covered Third Parties or their Covered Personnel who are suspected (based on credible evidence) of violating RHC Program Rules, failing to comply with the terms of the Company’s Compliance Manual, or otherwise violating provisions of their agreements with GCI required by this Compliance Agreement shall be subject to immediate suspension or termination by GCI or by the Covered Third Party, as the case may be, pending investigation. 
(ii) Covered Third Parties or their Covered Personnel who become aware of any known or suspected fraud or noncompliance with RHC Program Rules or other violations of their agreements with GCI required by this Compliance Agreement are required to promptly report such suspicions to the GCI Compliance Officer, GCI Compliance Hotline, the Commission’s whistleblower hotline or to the USAC whistleblower hotline.  
(iii) Each Covered Third Party shall ensure that any of their Covered Personnel, as well as any other sales personnel or their direct supervisors (whether acting as employees or agents or independent contractors of the Covered Third Party) that perform any activities relating to GCI’s participation in the RHC Program, receive the training described in Section 6 and provide certifications verifying that training to the Compliance Officer within thirty (30) days after receipt of the training materials.
(iv)  Each Covered Third Party shall make available to GCI, the Commission and USAC upon request access to all documents and records relating to its work for GCI as it pertains to the Rural Health Care Program, without requirement for GCI consent.  Each Covered Third Party shall also cooperate with audit requests (formal or informal) by GCI, the Commission or USAC to verify compliance with its agreements with GCI pertaining to the Rural Health Care Program and with the RHC Program Rules.
6. Compliance Training Program.  GCI shall establish and implement an electronic Compliance Training Program for Covered Personnel consistent with this section, which may be tailored to a Covered Personnel’s role and responsibilities with respect to the RHC Program.  Covered Personnel shall complete their Compliance Training within thirty (30) days after GCI adopts the Compliance Manual, but in no event more than one hundred twenty (120) days after the Effective Date.  Any training completed within the 6 months prior to the date on which GCI adopts the Compliance Manual satisfies this requirement, provided that it meets the requirements below.  Any employee who becomes a Covered Person after the initial Compliance Training Program is completed shall be trained within thirty (30) days.  For those Covered Personnel who are employees or officers of Covered Third Parties (or their contractors, third party agents, or other individuals or entities working on their behalf), the training shall be substantially similar to that provided to GCI employees.  Each Covered Person who has completed training shall complete a standardized certification attesting to completion of the training.  Covered Third Parties will relay such certifications to the Compliance Officer monthly.
(a) The Compliance Training Program shall instruct all Covered Personnel about the RHC Program Rules, the Compliance Manual, and any additional requirements for Covered Personnel set forth under this Compliance Agreement.  As part of the Compliance Training Program, Covered Personnel shall be advised of GCI’s obligation to report under Section 8 of this Agreement any suspected, alleged, or known fraud or noncompliance with the RHC Program Rules or this Compliance Agreement.  In addition, Covered Personnel and any others receiving the training shall be instructed on how to disclose such noncompliance to the GCI Compliance Officer.  Training on the reporting procedures shall include the email and telephone number of the Compliance Officer, as well as numbers for providing that information anonymously to the GCI Compliance Hotline, the Commission’s whistleblower hotline, and the USAC whistleblower hotline.  The training package shall also emphasize the potential ramifications of failing to comply with RHC Program Rules.  The training package shall explain that no person who submits reports or concerns about known, alleged, or suspected fraud or noncompliance shall be subject to any retaliation by GCI or Covered Third Parties, except that GCI may take any lawful personnel action in cases involving information that the person knew was inaccurate or false.  GCI shall include a provision in every contract with any Covered Third Party barring any such retaliation. 
(b) GCI shall maintain a list of Covered Personnel, including the dates on which they began or ended service as Covered Personnel and the dates of any training.  GCI shall provide to the FCC such information upon request.  GCI and its Covered Third Parties shall repeat compliance training on an annual basis and provide the Commission with annual certifications from each Covered Person (or any other person for whom training is required by this agreement) certifying that each has received annual training pursuant to the Compliance Training Program.  GCI shall periodically review and revise the Compliance Training Program for Covered Personnel as necessary to ensure that it remains current and complete and to enhance its effectiveness.
7. Fraud and Noncompliance Detection and Monitoring.
(a)	Within ninety (90) days after the appointment of the Compliance Officer, but in no event later than one hundred twenty (120) days after the Effective Date, GCI’s Compliance Officer shall create procedures to investigate potential Rural Health Care Program fraud and noncompliance with the RHC Program Rules, and this Compliance Agreement.  Among other activities, the Compliance Officer shall: 

(i)	Establish a program of periodic “spot checks” to ensure that Covered Third Parties are complying with all their obligations.
(ii)	Investigate promptly potential fraud or other irregularities based upon customer complaints, complaints by Covered Third Parties, information obtained through the “spot checks,” or any other credible information, including complaints to the GCI Compliance Hotline. 

(b)	During the term of this Compliance Agreement, GCI will include in the annual compliance reports under Section 11(a) a section containing the following metrics:

(i)	The number of investigations opened and the number of investigations closed during the annual reporting period;

(ii)	A list of Covered Personnel terminated by GCI (or by Covered Third Parties) during the annual reporting period for known, alleged, or suspected fraud or noncompliance, the nature of such fraud or noncompliance, and the amount or estimated amounts of Rural Health Care Program disbursements to GCI attributable to such fraud or noncompliance; and 

(iii)	The amount of Rural Health Care Program disbursements (and dates of such disbursements) returned to the Universal Service Fund by GCI attributable to known fraud or noncompliance with RHC Program Rules by Covered Personnel.
  
8. Reporting Suspected Fraud or Noncompliance.  GCI shall provide prompt notification to the FCC (as specified in Section 16) of any known, alleged or suspected fraud or noncompliance with the RHC Program Rules or this Compliance Agreement, including, without limitation, any relating to competitive bidding, within thirty (30) days after their discovery.  In complex cases that require additional investigation, GCI may seek up to an additional thirty (30) days, which shall not be unreasonably denied, to make such a report.  Such notification shall set forth any actions taken by GCI in response to the known, alleged or suspected fraud or noncompliance, including any investigations or inquiries made and any personnel actions taken.  Such reports shall further include a detailed explanation of:  (i) each instance of known, alleged or suspected fraud or noncompliance and the steps that GCI has or will take to investigate or verify any suspicions or allegations of fraud or noncompliance; (ii) the steps that GCI has taken or will take to remedy any such noncompliance after it has been verified; (iii) the schedule on which such remedial actions will be taken; and (iv) the steps that GCI has taken or will take to prevent the recurrence of any such noncompliance.
9. FCC or USAC Compliance Audits.  GCI acknowledges that the FCC or USAC, acting directly or through agents, may review or audit GCI’s compliance with this Compliance Agreement, with the GCI Compliance Plan, and with RHC Program Rules.  GCI shall cooperate with such review or audit by promptly complying with reasonable requests for information or documents (without the requirement of subpoenas except when necessary to protect or comply with requirements regarding third party proprietary or personally identifiable information), permitting reasonable inspection of physical premises and equipment, and making requested and relevant personnel available.  GCI shall maintain records in accordance with the requirements herein in a manner that permits any auditor to evaluate compliance with this Compliance Agreement, the GCI Compliance Plan, and RHC Program Rules.  Audit findings under this section are not subject to the reporting requirements under Section 8, unless or until such findings are final and non-appealable.
10. GCI Independent Audit Reports. 
(a) For each year that this Compliance Agreement is in effect, GCI shall obtain an independent audit that evaluates its performance under this Compliance Agreement and with the Rural Health Care Program Rules.  Except for the last year that this Compliance Agreement is in effect, these audits shall cover the preceding 12-month period, beginning with the 12 months following the Effective Date, and shall be completed no later than three (3) months after the end of the 12-month period being assessed.  An Independent Audit Report shall be submitted to the FCC, together with the Annual Compliance Report required by Section 11 below, no later than four (4) months after the end of the 12-month period being assessed.  During the last year, GCI shall obtain an independent close-out audit that covers the first nine (9) months of that year and shall be completed and submitted to the FCC, together with the Annual Compliance Report required by Section 11 below, no later than thirty (30) days before the end of the that year (unless some other date is mutually agreed upon by the Parties). 
(b) The auditing program established by GCI to fulfill its obligations under this Compliance Agreement shall be consistent with generally accepted government auditing standards (“GAGAS”), including the requirement that such audits be performed by an independent auditor.  The audits should be designed to ensure that GCI is complying with the terms of this Compliance Agreement, the GCI Compliance Plan, and RHC Program Rules. 
11. Annual Compliance Reports.
(a) GCI shall prepare and file annual compliance reports (each an “Annual Compliance Report”) with the FCC.  Each Annual Compliance Report shall be submitted with the Independent Audit Report, as discussed above, and shall cover the same time period as the Independent Audit Report.  Beginning with the third year this Compliance Agreement is in effect, the Annual Compliance Report shall be submitted thirty (30) days before the anniversary of the Effective Date and shall cover as much of the 12-month period prior to the anniversary of the Effective Date as is reasonably possible. 
(b) Each Annual Compliance Report shall include a reasonably detailed description of GCI’s efforts during the relevant period to comply with the terms and conditions of this Agreement.  In addition, each Annual Compliance Report shall include a certification by the Compliance Officer, on behalf of GCI, stating that the Compliance Officer has personal knowledge that GCI:  (1) has established and implemented the GCI Compliance Plan; and (2) is not aware of any instances of any suspected, alleged, or known fraud or noncompliance with the RHC Program Rules or this Compliance Agreement, including, without limitation, any relating to competitive bidding, except for those reported pursuant to the requirements under Section 8.

(c) Each Annual Compliance Report shall include a detailed description of any items identified in Section 7; any overpayments made to GCI during the previous year from the RHC Program; customer complaints; and any ongoing Rural Health Care Program related investigations, legal proceedings and inquiries by state or regulatory agencies.  The Report shall also contain a section that includes the metrics required by Section 7(b).

(d) If the Compliance Officer cannot provide the requisite certification, the Compliance Officer, as an agent of and on behalf of GCI, shall provide the Commission with a detailed explanation of the reason(s) why and describe fully:  (1) each instance of such unreported noncompliance as described in subsection (b)(2) of this section; (2) the steps that GCI has taken or will take to remedy such noncompliance, including the schedule on which proposed remedial actions will be taken; and (3) the steps that GCI has taken or will take to prevent the recurrence of any such noncompliance, including the schedule on which such preventive action will be taken.

(e) Each Annual Compliance Report shall include a headcount of Covered Personnel.

(f) In each Annual Compliance Report, the signatories shall certify that before submitting the Report, they reviewed and took into consideration the Independent Audit Report that covers the same time period.

(g) Each Annual Compliance Report shall include certifications by the Compliance Officer that all required oversight, training, education, reporting and other compliance activities were undertaken in accordance with the requirements of this Compliance Agreement and the GCI Compliance Plan.  In the alternative, the Report shall identify any provision of this Compliance Agreement and of the GCI Compliance Plan with which GCI did not comply during the applicable time period and describe any such noncompliance.  The Report shall also explain the steps taken, and/or those that will be taken (with a timeline specifying when GCI will take them), to correct any noncompliance, to cure any violation, and to ensure future compliance.

(h) The Commission, USAC, and the OIG may each provide comments to GCI’s Compliance Officer and its counsel.  To the extent feasible, such comments will be provided within sixty (60) days of each submitted Annual Compliance Report.  Each entity may request GCI’s counsel to arrange a conference with the Compliance Officer to discuss the details of each annual report. 

12. Remedies for Noncompliance.  
(a) General Provision:  The FCC reserves its right to pursue violations of the terms of this Compliance Agreement and of the RHC Program Rules consistent with its authority under the Act.  GCI acknowledges and agrees that if GCI fails to materially comply with any provision of this Compliance Agreement, the FCC may treat such noncompliance in the same manner as the failure to comply with a rule promulgated by the Commission, as well as avail itself of such other remedies as may be set forth in this section.  Any action taken under this section is without prejudice to the FCC’s application of administrative remedies pursuant to the Act, as reserved by this subsection. 
(b) Suspension of Funding:  To ensure the continued integrity of the Universal Service Fund, GCI acknowledges and agrees that if it fails to materially comply with any provision of this Compliance Agreement, USAC may exercise its authority to suspend action on processing RHC Program funding requests and withhold payment until GCI demonstrates to the satisfaction of the FCC and USAC that it has remedied such noncompliance.  USAC may act under this subsection only upon the direction of the FCC.  USAC shall provide thirty (30) days’ notice to GCI, with a period to cure of no less than thirty (30) days, of any actions taken under this subsection and the grounds therefor.  Suspension of funding shall not result in a default by GCI on its payment obligations under the Consent Decree, but shall extend the payment period by a corresponding amount of time.  Any action taken under this subsection is without prejudice to the FCC’s application of administrative remedies pursuant to the Act. 
(i)  If the FCC determines that GCI has failed to materially comply with any provision of this Compliance Agreement (other than a violation of Rural Health Care Program Rules), the FCC will inform GCI of such determination and may, in its sole discretion, direct USAC to suspend processing of GCI’s funding requests and withhold payments as provided in this subsection (b).  Alternatively, the FCC may, in its sole discretion, postpone such suspension of the processing of GCI’s funding requests and the withholding of payments for a period of time and under such terms as the FCC may specify, except in those cases involving deadlines imposed by this Compliance Agreement, which instead shall be subject to the provisions of paragraph (ii) of this subsection.  If the FCC postpones the suspension of the processing of GCI’s funding requests and the withholding of payments of funding as permitted under the preceding sentence, and if GCI does not meet the terms of such postponement to the satisfaction of the FCC, the FCC may, in its sole discretion, direct USAC to immediately suspend processing of GCI’s funding requests and withhold payments of funding commitments as provided in this subsection.

(ii) GCI may seek extensions of any deadline imposed by this Compliance Agreement by notification in writing to the FCC, to be received by the FCC at least five (5) business days before the deadline date (including an explanation of the reason for the requested extension).  Such an extension request may be granted or not in the sole discretion of the FCC.  If the FCC denies the extension request, or if GCI fails to meet any extended deadline, then the FCC may, in its sole discretion, upon the failure of GCI to meet its deadline, direct USAC to suspend processing of GCI’s funding requests and withhold payments of funding commitments as provided in this subsection (b).
(iii) If a suspension of funding occurs due to material noncompliance with the terms of this Compliance Agreement (other than a violation of Rural Health Care Program Rules), GCI may appeal such suspension by filing an appeal with WCB within thirty (30) days.  For purposes of this subsection, the computation of time shall be as set forth in 47 CFR § 1.4 and the procedures in 47 CFR §§ 54.721 and 54.722 shall be applicable to such appeals.  The decision of the WCB may thereafter be appealed to the full Commission.  If the Commission affirms any suspension of funding, GCI agrees that any such determination and the resulting denial of any payments in connection with such suspension shall not be subject to further administrative appeal at USAC or the FCC. 
(iv) If the Commission affirms any suspension of funding under paragraph (iii) of this subsection, or if a suspension of funding is imposed under this subsection (b) that is not appealed, GCI agrees to withdraw, relinquish, cancel, or restate any funding requests, as the case may be, consistent with any final orders of the FCC (or WCB, if no appeal is made to the full Commission) to the extent permissible under applicable RHC Program Rules, or, if cancellation is not viable, due to previous payments made under the transactions involved, to reduce any existing USAC funding commitments or repay any disbursements to the extent ordered by the FCC or USAC.
13. Violation of RHC Program Rules.  If there is noncompliance with RHC Program Rules, USAC shall take action pursuant to its normal processing procedures, in accordance with FCC rules and orders and USAC procedures.  Any such actions taken by USAC may be appealed as provided by applicable Universal Service Program rules, including those set forth in 47 CFR §§ 54.719 through 54.722. 
14. Document and Record Retention.  GCI shall maintain for inspection all documents and records necessary to support reimbursement claims from the Rural Health Care Program and to demonstrate compliance with this Compliance Agreement, in accordance with the Commission’s record retention policy and RHC Program Rules. 
15. Amendments.  This Compliance Agreement may be amended only by written agreement duly executed by all the parties to this Compliance Agreement.
16. Notifications and Submissions of Reports and Compliance Documents.  All notices, reports, disclosures or other communications required by this Compliance Agreement shall be in writing and sent via E-mail.  Such notices, reports, disclosures or other communications shall be deemed to have been duly given on the day of transmission of the E-mail.  Notifications required to be made to the FCC shall be made to the OIG, OGC, and EB. In addition to E-mail notifications, GCI shall provide hard copies of each Annual Compliance Report (as described in Section 11) to each of the individuals listed below.  Notifications shall be made as follows: 

If to OGC:
General Counsel (or designee)
Federal Communications Commission
45 L Street, NE   
Washington, DC 20554 
Email address of designee:  Paula.Silberthau@fcc.gov; and
                                             Jim.Bird@fcc.gov

If to EB:
Enforcement Bureau Chief (or designee)
Federal Communications Commission
45 L Street, NE
Washington, DC 20554
Email address of designee:  Rakesh.Patel@fcc.gov; and
			      Meghan.Ingrisano@fcc.gov

If to OIG:
Inspector General (or designee)
Office of Inspector General
Federal Communications Commission 
45 L Street, NE 
Washington, DC 20554 
Email address of designee:  Eric.Phelps@fcc.gov; and
                                             Sharon.Diskin@fcc.gov

17.	This agreement may be executed in counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument.



________________________________
Loyaan A. Egal
Chief, Enforcement Bureau
Federal Communications Commission



_______________________________
Date



________________________________
Rebecca Windt Pearson
Senior Vice President, Law and Corporate Advocacy, and General Counsel
GCI Communication Corp.



________________________________
Date


APPENDIX B
Appeals to Be Withdrawn by GCI

October 20, 2017 Appeal to USAC of Denial Notice 
November 19, 2018 Application for Review of WCB Decision Prescribing FY2017 Rates 
(supplemented January 29, 2019 and September 7, 2021)
March 18, 2019 Petition for Reconsideration of 2019 Public Notice re Determining Rural Rates in the RHC Program (WCB, WC Docket Nos. 02-60 & 17-130)
July 12, 2019 Request for Review of Decision of USAC and Petition for Waiver 
October 21, 2019 Petition for Review for 2019 Report & Order re Promoting Telehealth in Rural America (D.C. Circuit, Case No. 19-1217)
November 15, 2019 Request for Review of Decision of USAC and Petition for Waiver
April 20, 2020 Request for Review of Decision of USAC and Petition for Waiver
November 19, 2020 Application for Review of WCB Decision Prescribing FY2018 and FY2019 Rates
December 7, 2020 Request for Review of USAC Decision Approving FY2017 Rates from WCB Decision
May 17, 2021 Request for Review of Decision of USAC
November 23, 2021 Request for Review of Decision of USAC and Petition for Waiver
APPENDIX C
FRNs Released for Disclosed Urban Rate Issues


1556729
1557163
1558190
1560012
1561472
1561734
1561793
1562502
1562512
1562807
1562808
1562809
1562810
1562811
1562856
1564026
1564133
1564375
1564379
1564382
1564383
1564386
1564387
1564388
1564389
1564393
1564394
1564395
1564397
1564398
1564399
1564400
1564738
1566716
1567974
1567976
1568063
1568064
1568065
1568066
1569199
1569200
1569201
1569202
1569676
1569880
1569946
1570069
1570519
1570522
1571079
1571125
1571132
1571140
1571294
1571300
1571309
1571360
1571362
1571415
1571418
1571420
1571422
1571426
1571430
1571432
1571649
1571650
1571651
1572029
1572711
1572750
1572754
1572967
1572974
1573173
1573201
1573202
1573431
1573473
1573479
1573480
1573575
1573781
1573784
1573788
1573798
1573805
1573810
1573811
1573812
1573813
1573814
1573815
1573816
1573817
1573818
1573819
1573820
1573821
1573823
1573824
1573843
1573844
1573845
1573846
1573847
1573852
1573853
1573854
1573863
1573864
1573865
1573866
1573867
1573868
1573869
1573870
1573871
1573872
1573873
1573874
1573878
1574758
1574760
1574761
1574763
1574764
1574765
1574767
1574768
1574769
1574795
1574815
1574818
1574821
1574822
1574823
1574826
1574827
1574829
1574831
1574833
1574834
1575384
1575385
1575386
1575388
1575389
1575390
1575392
1575394
1575395
1575396
1575398
1575399
1575400
1576484
1576497
1576507
1576511
1577150
1577156
1577161
1577164
1577165
1577166
1577167
1577168
1577170
1577171
1577173
1577174
1577478
1577648
1578617
1578619
1578843
1578883
1578888
1578889
1578890
1578892
1578894
1578896
1578898
1578966
1578974
1578976
1578977
1578979
1578985
1578988
1578990
1578992
1578994
1578998
1579277
1579459
1579474
1579822
1579934
1580565
1580569
1580574
1580581
1580583
1580764
1580962
1581191
1581192
1581485
1581487
1581488
1581489
1582078
1582416
1582419
1582511
1582529
1582532
1582535
1582723
1583028
1583075
1583258
1584060
1677354
1678123
1680535
1681575
1681576
1681577
1681578
1681579
1681582
1681583
1681584
1681799
1681800
1682018
1682138
1682220
1682227
1683874
1684117
1686864
1686865
1687108
1687131
1687132
1687144
1687145
1687157
1687158
1687159
1687160
1687162
1687163
1687164
1687233
1687238
1687243
1687255
1687256
1687281
1687486
1687487
1687490
1687517
1687519
1687521
1687547
1687548
1687761
1687762
1687764
1687768
1687769
1687770
1687771
1687772
1687773
1687774
1687775
1687776
1687777
1687778
1687779
1687780
1687781
1687898
1687914
1687949
1687950
1687951
1688019
1688022
1688440
1688494
1688496
1688497
1688498
1688499
1688500
1688501
1688502
1688503
1688505
1688613
1688620
1688624
1688730
1688732
1689337
1689340
1689574
1689577
1689579
1689581
1689583
1689589
1689590
1689591
1689592
1689593
1689594
1689595
1689596
1689597
1689599
1689637
1689643
1689645
1689647
1689651
1689654
1689664
1689668
1689896
1689900
1689903
1690056
1690058
1690062
1690064
1690065
1690071
1690086
1690091
1690144
1690373
1690379
1690387
1690392
1690417
1690542
1690543
1690544
1690548
1691246
1691442
1691443
1692603
1693413
1694657
1694661
1694663
1694664
1694665
1694668
1694670
1694673
1696789
1696854
1696856
1710505
1710533
1710617
1710628
1710634
1710952
1710958
1712653
1713132
1713548
1714016
1714698
1715228
1715441
1720847
1723407
1723414
1723418
1723428
1723434
1723587
1723892
1723898
1724327
1724340
1724342
1724346
1725132
1726002
1726723
1728201
1829473
1829479
1829528
1830891
1830985
1831009
1831012
1831197
1831235
1832901
1833490
1835068
1835072
1835100
1835182
1835294
1835583
1838190
1838192
1838219
1840386
1840399
1840418
1840424
1841740
1841821
1842045
1842648
1844082
1844779
1845016
1845175
1845251
1845795
1846210
1846944
1948722
1950226
1950551
1950823
1950929
1950930
1950937
1950940
1950942
1950945
1950946
1950953
1950954
1951117
1951264
1954460
1955249
1955253
1955257
1955261
1956793

	2	
APPENDIX D
FRNs Released for Rural Rate Issues

All Funding Year 2015 through Funding Year 2019 FRNs

APPENDIX E
FRNs Released for Competitive Bidding Issues


    51021
51022
51023
51024
51025
51026
51027
51028
51029
51030
51031
51032
51033
51034
51035
51036
51037
51038
51039
51040
51041
51042
51043
51044
51045
51046
51047
51048
51049
51050
51051
51052
51053
51054
51055
51056
51057
51058
51059
51060
51061
51062
51063
51064
51065
51066
51067
51068
51069
51070
51627
51738
51739
51740
51741
51742
51743
51744
51745
51746
51747
51748
51941
52272
55642
55643
55644
55646
55647
55811
56025
56026
58411
59636
59637
59638
59639
59640
59641
59642
59643
59644
59645
59646
59647
59664
59671
61417
61418
61419
61420
61421
61422
61423
61424
61425
61426
61427
61428
61429
61430
61431
61432
61433
61434
61435
61436
61437
61438
61439
61440
61441
61442
61443
61444
61445
61446
61447
61448
61644
61645
61646
61647
61648
61649
61650
61651
61652
61653
61654
61655
61656
61657
61880
61881
61882
61957
61958
61959
61960
61961
61962
61963
61964
61965
61966
61967
61968
61969
61970
62191
62192
62193
62194
62195
62196
62197
62198
62199
62200
62201
62202
62203
62204
62205
62206
62207
62208
62209
62210
62211
62212
62213
62214
62215
62216
62217
62218
62219
62220
62221
62222
62468
62469
62631
62824
62951
63162
63678
63679
63680
63681
63682
63683
63684
63685
63686
63687
63688
63689
63690
63691
63692
63693
63694
63695
63696
63697
63698
63874
63875
63876
63877
63878
63879
63880
63881
63882
63883
63884
63885
63886
64086
64087
64088
64089
64090
64091
64092
64286
64549
68882
1210536
1210697
1210819
1210825
1210826
1210834
1210836
1210838
1210839
1210840
1210841
1210843
1210845
1210951
1212336
1212452
1212486
1212674
1212699
1212729
1212733
1212740
1212749
1212754
1212755
1212756
1212767
1212768
1212769
1212827
1212828
1212829
1212837
1212841
1212844
1212847
1212848
1212994
1212995
1212996
1213016
1213023
1213031
1213037
1213039
1213041
1213044
1213482
1213721
1213722
1213724
1213725
1213726
1213727
1213728
1213729
1213733
1213734
1213735
1213746
1213752
1213755
1213775
1213785
1213786
1213787
1213788
1213789
1213790
1213791
1216798
1217574
1219647
1219807
1219823
1219837
1219844
1219848
1219857
1219875
1219911
1219925
1219936
1220078
1220080
1220086
1220192
1220194
1220197
1220717
1220731
1220936
1220979
1220983
1220984
1221390
1221393
1223240
1223249
1223255
1223258
1223263
1223264
1223265
1223266
1223267
1223268
1223269
1223270
1223271
1223272
1223273
1223274
1223275
1223276
1223382
1223415
1223422
1223428
1224905
1224907
1225265
1226101
1226235
1226254
1226292
1226318
1226624
1227281
1227283
1227284
1227285
1227286
1227287
1227288
1227289
1227364
1227369
1227380
1227388
1227834
1234083
1236718
1236819
1236823
1236828
1329202
1331488
1332356
1332363
1332366
1332367
1332412
1332914
1333114
1333257
1333959
1334082
1334517
1334935
1335105
1335106
1335112
1335115
1335119
1335120
1335123
1335124
1335127
1335128
1335131
1335332
1335879
1336087
1336088
1336089
1336090
1336092
1336093
1336095
1336096
1336097
1336098
1336099
1336100
1336101
1336102
1336118
1336119
1336120
1336121
1336122
1336125
1336127
1336130
1336133
1336134
1336136
1336138
1336140
1336141
1336143
1336145
1336151
1336154
1336156
1336157
1336160
1336161
1336162
1336165
1336167
1336170
1336173
1336599
1336603
1336604
1336605
1336717
1336818
1336821
1336822
1336826
1336827
1336990
1336991
1337492
1337531
1337532
1337533
1337534
1337535
1337536
1337624
1337667
1337719
1337721
1337722
1337723
1337726
1337727
1337728
1337729
1338413
1338414
1338415
1338416
1338417
1338418
1338419
1338455
1338458
1338459
1338461
1338463
1338465
1338469
1338471
1338473
1338474
1338475
1338476
1338478
1338479
1338480
1338481
1338482
1338484
1338486
1338488
1338489
1338490
1338716
1338717
1338896
1338931
1339009
1339012
1339018
1339020
1339022
1340836
1340838
1340847
1341679
1342535
1343478
1343726
1353096
1354248
1440314
1440317
1441069
1441132
1441134
1442239
1442536
1443170
1443472
1443727
1445097
1445103
1445119
1445245
1445544
1445548
1445552
1445553
1445562
1445563
1445565
1445567
1445580
1445581
1445583
1445593
1445594
1445595
1445596
1445597
1445598
1445650
1445651
1445655
1445656
1445657
1445659
1445660
1445661
1445670
1445678
1445682
1445685
1445691
1445692
1445696
1445698
1445700
1445706
1445708
1445709
1445710
1445712
1445714
1445716
1445717
1445718
1445719
1450548
1450784
1451313
1452503
1452643
1452797
1452861
1452862
1452886
1452888
1452891
1452892
1453011
1453012
1453014
1453015
1453016
1453482
1453969
1453972
1454166
1454407
1454495
1454496
1454497
1454498
1454499
1454933
1455050
1455090
1455093
1455289
1455411
1455451
1455543
1455961
1455964
1456344
1456345
1456348
1456349
1456350
1456351
1456353
1456354
1456356
1456360
1456414
1456712
1456713
1456763
1456765
1457353
1458027
1458029
1458030
1458032
1458033
1458042
1458043
1458227
1458250
1458252
1458255
1458258
1458259
1458261
1458263
1458287
1458289
1458290
1458293
1458294
1458297
1458300
1458303
1458491
1458492
1458493
1458496
1458497
1458498
1458499
1458500
1458501
1458502
1458503
1458507
1458508
1458510
1458511
1458515
1458519
1460243
1460253
1461882
1462566
1462567
1462570
1463974
1463980
1464581
1464583
1464585
1464588
1464590
1464592
1464593
1464594
1464595
1558190
1560012
1560047
1560056
1560058
1560356
1560359
1560360
1560362
1560363
1560365
1560732
1560733
1560734
1560795
1560796
1560797
1560833
1560834
1560835
1560836
1560837
1560838
1560839
1561472
1561544
1561596
1561701
1561704
1561706
1561707
1561708
1561716
1561720
1561721
1561734
1562062
1562502
1562571
1562800
1562801
1562803
1562804
1562805
1562806
1562807
1562808
1562809
1562810
1562811
1564025
1564026
1564027
1564028
1564029
1564030
1564031
1564083
1564375
1564379
1564382
1564383
1564386
1564387
1564388
1564389
1564393
1564394
1564395
1564397
1564398
1564399
1564400
1564738
1566716
1567974
1567976
1568063
1568064
1568065
1568066
1569199
1569200
1569201
1569202
1569676
1569880
1569946
1570069
1570517
1570519
1570522
1571125*
1571132*
1571294
1571300
1571309
1571340
1571344
1571345
1571346
1571347
1571348
1571364
1571365
1571366
1571367
1571368
1571369
1571370
1571371
1571372
1571462
1571464
1571465
1571466
1571649
1571650
1571651
1571656
1571657
1571769
1572029
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