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A.   a3TechnicalTechnical Document Style9Wg  2  1.   a4TechnicalTechnical Document Style8bv{ 2  a.   a1TechnicalTechnical Document StyleF!<  ?  I.   2ea7TechnicalTechnical Document Style(@D i) . a8TechnicalTechnical Document Style(D a) . PleadingHeader for numbered pleading paperP@n   $] X X` hp x (#%'0*,.8135@8:Second Report and Order regarding auction design and information availability during simultaneous multiple round auctions.  \X-x2. LongForm Application Instructions  xThe OIG review indicated some inaccuracies in the instructions regarding the preparation  x[of FCC Form 401 ("longform application"). The longform application is the vehicle by  xwhich successful bidders apply for a narrowband PCS license. Longform applications  xare required within ten business days after high bidders are announced by public notice.  x.General instructions regarding requirements for longform applications were provided in  x=the Public Notice, dated August 17, 1994, announcing the auction. Detailed instructions  x\regarding longform application completion were provided in the Bidder's Information Package.""$0*%%""Ԍ xԙThe auditors found that several winning bidders (six applicants out of a total of nine)  xsubmitted individual longform applications for multiple licenses. In fact, several  xapplicants submitted single longform applications for frequencies in each of the five  xmarkets. These applicants were notified in writing by the Narrowband Commercial Radio  xBranch that "further documentation" was required, and that a "complete application for  xeach market and frequency block" should be submitted. In addition, applicants were  x>reminded that 24.11 of the Commission's Rules states that "an applicant must file an application for an initial authorization in each market and frequency block desired."  xDuring the OIG examination of the applications, the auditors reviewed the instructions  xprovided to the applicants in the Public Notice announcing the auction, and in the Bidder's  xInformation Package providing detailed instructions on longform application preparation.  xThe auditors noted that no mention is made in these sources of 24.11 of the Commission  xRules, or the rule's requirement that individual applications be submitted for "each market  xand frequency block." In fact, the "sample" longform application provided in the  xyBidder's Information Package shows multiple markets and frequency blocks on the same longform application.  xBoth of the above areas were discussed with FCC auction personnel. With respect to the  x/first issue, the OIG was informed that the Commission intended to make activity rule  x@waiver information available in future auctions. During the Major Trading Area  xyBroadband PCS license auction, which began December 5, 1994, information about each  xLbidder's maximum eligibility and remaining waivers was made available along with round  xby round auction results. The release of this information adequately addressed the first  xissue, and the Inspector General recommended that the Commission continue to release such information in future simultaneous multiple round auctions.  \^- x With respect to the second issue, the OIG was informed that steps were being taken to  x0improve the longform instructions in future auctions. For example, a new bidder  xkinformation package has been developed which clarifies the requirement for individual  xapplications. In addition, a new form (Form 600) was developed to include filing  xinstructions which clearly indicate this requirement. The Inspector General concluded that these steps will adequately address this problem in future auctions .""$0*%%""Ԍ \-  $ԙ2.XxREPORT ON THE COMPLIANCE WITH, AND EFFECTIVENESS OF,   REQUIREMENTS RELATED TO LIMITATION ON USE OF APPROPRIATED   FUNDS TO INFLUENCE CERTAIN FEDERAL CONTRACTING AND FINANCIAL TRANSACTIONS. (# xThe report was issued March 31, 1995.  xzThe Office of Inspector General (OIG) performed an audit to evaluate the compliance  xwith, and the effectiveness of, the requirements imposed by 31 U.S.C.  1352 on the FCC  x"and on persons requesting and receiving Federal contracts from the FCC using appropriated funds. 31 U.S.C.  1352 requires, among other things, that:   Xx1. None of the funds appropriated by any Act may be expended by the recipient   of a Federal contract to pay any person for influencing or attempting to influence   #an officer or employee of any agency, a Member of Congress, an officer or   ^employee of Congress, or an employee of a Member of Congress in connection   with the award, extension, continuation, renewal, amendment or modification of any Federal contract.(#   Xx2. Each person who requests or receives a Federal contract in excess of $100,000 must disclose lobbying with other than appropriated funds.(#   0Xx3. The head of each agency must submit a semiannual report to the Secretary of   the Senate and the Clerk of the House of Representatives. These reports must   include information with regard to any payments made and must be filed no later than May 31 and November 30 of each year.(#   Xx4. The Inspector General must prepare and submit to Congress each year an   evaluation of the compliance by the agency with, and the effectiveness of, the   requirements imposed on the agency and on persons requesting or receiving Federal contracts.(#  xThe auditors made inquiries of key personnel to ascertain what controls and/or procedures  x0regarding 31 U.S.C.  1352, and sections 52.20311 and 52.20312 of the Federal  xAcquisition Regulation (FAR) were in place. Inquiries were also made to officials at  x>OMB on the certification and disclosure of payments. Auditors obtained copies of all  xZFCC contracts which exceeded $100,000. These were reviewed and analyzed to determine whether required procedures were being followed.""$0*%%""Ԍ xjԙThe auditors determined that the Commission was in compliance with 31 U.S.C.  1352,  xand that the Commission established adequate controls to ensure certification and  xdisclosure of payments made to influence certain federal transactions. However, the  xauditors found that the semiannual report required to have been filed by November 30,  x1994, had not been filed. Responsible FCC officials were notified and took appropriate action to correct this oversight.  xIn compliance with provisions of 31 U.S.C.  1352, the OIG submitted to the Secretary  x!of the Senate and to the Clerk of the House of Representatives the required annual evaluation of FCC compliance with the Act.  \ -  q3.XxAUDIT OF THE ADVISORY COMMITTEE ON ADVANCED TELEVISION SERVICE. (# xThe report was issued December 19, 1994.  x[The Advisory Committee on Advanced Television Service was empaneled by the Federal  xkCommunications Commission (FCC) on October 1, 1987, to develop and recommend  xpolicies, standards, and regulations to facilitate the orderly and timely introduction of  xadvanced television services in the United States. The Committee is chartered in  xLaccordance with the Federal Advisory Committee Act (FACA), and its parent committee  \|- x{is composed of 25 voting members, as well as an unspecified number of ex officio members, throughout government and industry. x  xThis Office of Inspector General audit was performed to provide an independent  xassessment of the integrity of Committee funds. Audit emphasis was placed on evaluating  xcompliance with internal controls for handling deposits and ensuring that all disbursements  x[were valid and supportable. All cash receipts, bank charges and disbursements from the  xperiod of July 1, 1992, through November 30, 1994, were examined and traced back to monthly bank statements and journals maintained by the bookkeeper.  xResults of the audit reflect that the internal controls established over the Committee's  x<funds were being properly administered. All cash receipts, interest accrued to the account,  xbank charges, and disbursements were reconciled from the monthly bank statement to the  xaccounting journals. As of November 30, 1994, the monthly account statement from the  x]bank reflected a balance in the Committee's account which reconciled with figures maintained by the Committee.""$0*%%""Ԍ  \-  4.XxCOMMISSION ACTION ON OFFICE OF INSPECTOR GENERAL   RECOMMENDATIONS REGARDING THE FREQUENCY COORDINATOR PROGRAM.(#  xIn the Communications Amendments Act of 1982, Congress provided the FCC with  xyguidelines to manage the spectrum for private land mobile services. Congress authorized  xthe use of nonFederal Government advisory coordinating committees (frequency  xLcoordinators) for assigning frequencies to parties seeking to broadcast and receive using  x"private land mobile and fixed station equipment. Congress also encouraged the  x^Commission to "develop rules or procedures for monitoring the performance of  \ -coordinating committees."  xIn 1992 the OIG issued two audit reports which addressed deficiencies in the FCC's  \ - xmonitorship of frequency coordinators. The two reports, entitled Audit Report on User  \- xFees for Frequency Coordinator Services and Audit Report on the User Satisfaction With  \- xyFrequency Coordinator Services, contained a total of thirteen audit recommendations. In  xthese reports, the OIG found that the FCC was neither monitoring and evaluating the  xservice provided by frequency coordinators to the public, nor examining the cost for providing that service.  \- xOOn September 29, 1993, in its Report on the Followup Audit of the Frequency  \- xLCoordinator Program, the OIG found that the FCC had not addressed ten of the thirteen  xoriginal recommendations contained in the prior audit reports. Accordingly, four additional recommendations for corrective action were made.  \n- xOn March 22, 1995, the Acting Inspector General received the 1994 Annual Report of  \j- xPrivate Land Mobile Frequency Coordinator Performance from the Chief of the newly  xlcreated Wireless Telecommunications Bureau. The annual report indicates that the  xCommission is now addressing the recommendations for corrective action made in the  xLearlier OIG audit reports. The FCC is now taking significant steps to ensure that private  x[citizens are afforded accurate and timely frequency coordination services at a reasonable  xcost. For example, the report cites a reduction of 87% in the cost charged by the largest  x=frequency coordinator, the National Association of Business and Educational Radio, Inc.  x(NABER), from $140 to $17 for processing an enhanced specialized mobile radio (ESMR)  xlicense. Such a reduction is a direct result of the Commission's proactive approach of  \6#- xobtaining and examining documentation from individual frequency coordinators whose  x.revenues exceed expense margins by over 10%. NABER was asked to submit plans for"0$0*%%""  xreducing fees charged to their customers. In its response, NABER identified "ways in which it intended to bring coordination fees more in line with its expenses."  \-  xThe Land Mobile Branch in Gettysburg, Pennsylvania, undertook an eight week review  xof Coordinator return rates in Fiscal Year (FY) 1994. The review was initiated in  xresponse to an OIG recommendation, and was intended to insure that the coordinators  xwere serving the public in a responsible manner. A Public Notice was issued June 22,  x]1994, providing the public with the results of the study, and the FCC subsequently  xrequested each Frequency Coordinator with an error rate over 10% to submit a plan for corrective action.  xjThe Land Mobile Branch also initiated an evaluation of the frequency coordinators' speed  \ - xof service. The Commission's 1986 Report and Order required that 90% of inservice and  x<interservice coordination requests be processed within 20 workdays. The evaluation found  xthat a majority of coordinators met this processing standard. Most failures to meet the standard were attributed to delays caused by unusual processing fluctuations.  y,K INVESTIGATIONS   \-   \-  hK OVERVIEW   xInvestigative matters pursued by this office are generally initiated as a result of complaints  xNalleging fraud, waste, abuse, corruption or mismanagement by FCC employees, or  xaffecting the programs or operations of the Commission. Upon receipt of a complaint  xwhich alleges an administrative or criminal violation, the OIG usually conducts a  xpreliminary inquiry to determine if an investigation is warranted. Investigations may  xinvolve possible violations of regulations regarding employee responsibilities and conduct,  xFederal criminal law, and other regulations and statutes pertaining to the activities of  x\Commission employees. Investigative findings may lead to criminal prosecution, civil prosecution, or administrative action.  \!< INVESTIGATIVE ACTIVITY   x>During this reporting period, the OIG received thirtythree complaints or requests for  xassistance. As a result, the office opened four investigations, two of which have been"$ 0*%%#"  xclosed and two of which are still pending. The two open investigations involve matters  x referred to the U.S. Department of Justice: one to the Public Integrity Section of the  x]Criminal Division, and one to a United States Attorney's Office. Seven preliminary  xinquiries were conducted to determine if investigations should be opened, and five of these  xzwere closed without initiating formal investigations. Two preliminary inquiries remain  x pending, and one preliminary inquiry pending from the previous reporting period was closed without initiating a formal investigation.  xkSix matters were referred to other FCC components, and one was referred to another  xxOffice of Inspector General. The OIG responded to five requests for assistance from other  xLinvestigative organizations, and no action was appropriate with respect to ten complaints received in the OIG. xThe following investigations were closed:  \-  (1)XxAt the request of a senior management official, the OIG investigated an allegation   @of misuse of an official vehicle by an employee. Using surveillance techniques,   lthe OIG corroborated the allegations and recommended administrative action. The   1recommendation was followed, and administrative action was taken against the employee. (#  \-  (2)XxA confidential source reported conversion and misuse of government property by   ]nonemployees. An OIG investigation corroborated the allegations. The results of   the investigation were reported to management, and the investigation was closed after appropriate corrective action was taken or planned. (#  x|Two investigations opened during the reporting period were referred to the U.S.  xDepartment of Justice pursuant to section 4(d) of the Inspector General Act, and the OIG  xis continuing to investigate the possible violations of Federal criminal law. The first  x0involves an alleged conflict of interest by a former FCC employee, and the second involves the possible forgery of official FCC records by a nonemployee.  x\Preliminary inquiries conducted with respect to six complaints determined that formal  xinvestigations were not warranted. A complaint that employees in several FCC Field  xZOffices had taken improper enforcement action against certain amateur radio operators was  xkclosed after a preliminary inquiry found that the complaint was based upon inaccurate  x!information. A complaint, received during the last reporting period, that two FCC  xemployees had improperly denied licenses and taken other actions against an applicant was""$ 0*%%""  xclosed after the preliminary inquiry determined that the two employees had acted in accordance with applicable statutes and regulations.  xPreliminary inquiries were conducted based on separate complaints that the FCC had  x0improperly approved the transfer of radio station licenses. No improprieties in the  xhandling of either matter were disclosed and no further investigation was conducted. A  xcomplaint by a subcontractor in an FCC contract regarding possible wrongdoing by the  xprime contractor and FCC employees was determined to involve only a contractual dispute  xbetween the two contractors. A complaint concerning the hiring of a consultant in one  xof the Bureaus was resolved when a preliminary inquiry indicated no irregularities in the personnel action.  xTwo preliminary inquiries remain open. One involves an allegation of improper conduct  x[by an FCC employee, and the other concerns an allegation of mismanagement in an FCC program.  xThree complaints were referred to the Common Carrier Bureau. Other complaints were  xreferred to the Compliance and Information Bureau, the Office of General Counsel, and  xthe Acting Secretary of the Commission. A complaint was referred to the Office of  xInspector General at the Department of Health and Human Services. In addition, the  xOffice of Inspector General responded to inquiries or requests for assistance from the  x>Federal Bureau of Investigation, the U.S. Postal Inspection Service, and the Office of Inspector General from the U.S. Department of Agriculture.  xDuring the reporting period the Office of Inspector General, in cooperation with the  xOffice of Managing Director, undertook a review of the FCC's workers' compensation  x/program to identify possibly fraudulent claims. This review included consulting with  xNpersonnel in the Office of Inspector General at the U.S. Department of Labor with  xexpertise in workers' compensation fraud cases. The Office of Inspector General will continue to work with FCC management to insure the integrity of this program.  xThe OIG also submitted for comment to the Office of General Counsel a recommendation  xthat Section 709 of Title 18, U.S.C., be amended to protect the name of the FCC from  xbeing used to defraud investors. The statute protects a number of Federal agency names  x>from being used fraudulently in advertisements to suggest or imply endorsement by a  xFederal agency. FCC programs involving lotteries and auctions are increasingly attracting  xscam artists and con men who use telemarketing and other promotions to lure unwary  x-investors into fraudulent schemes, most notably those involving wireless cable. It is hoped""$ 0*%%""  xthat abuses of this sort which involve the false use of the term "FCC" in advertisements  xor solicitations can be quickly eliminated by utilizing the injunctive remedy provided by 18 U.S.C.  709.  y,K MANAGEMENT AND ADMINISTRATION   \B-   \<-  xThe Office of Inspector General at the FCC has undergone significant change since the  xlast Semiannual Report. Former Inspector General James Warwick, who retired from  x.Federal service on November 11, 1994, succumbed to a long illness on April 4, 1995, in  xySeattle, Washington. Mr. Warwick had been the FCC Inspector General from 1989 until his retirement in 1994.  xH. Walker Feaster III was appointed Acting Inspector General on November 14, 1994.  xyMr. Feaster has served the Commission since 1974 in various positions within the Office  xof Managing Director and within the former Private Radio Bureau. Since 1990 he served as the Associate Managing Director for Program Analysis.  xIn October 1994 Stephanie Dunscomb joined the OIG audit staff. Ms. Dunscomb was an  xauditor in the OIG of the U.S. Department of Transportation from June 1992 until she  x.transferred to the FCC on October 3, 1994. In April 1995, the Counsel to the Inspector  xGeneral and Director of Investigations, Robert Andary, accepted a position as Inspector  xGeneral of the Federal Labor Relations Authority, effective May 8, 1995. Mr. Andary has served the OIG since May 1992.  xThe Acting Inspector General has completed a draft strategic plan to ensure effective audit  xMcoverage of the Commission's programs and operations through September 1999. In  xFebruary 1995 the Acting Inspector General circulated the draft strategic plan to the  xChairman and the Commissioners, and to the Chiefs of all the FCC's Bureaus and Offices. The OIG is currently in the process of preparing its final strategic plan.  x In the strategic plan, the OIG attempts to assess and describe the risks and problems  xfacing the FCC in fulfilling its mission, and to identify and select the audit strategies and  xapproaches for addressing and helping to resolve those risks and problems. Specific FCC  xprograms and operations are identified, based upon their nature and complexity, for review  x|by the FCC Office of Inspector General. The objective of this review will be to"$ 0*%%F#"  xdetermine whether the programs and operations are vulnerable to waste, fraud, abuse, and  xMmismanagement; whether they are efficient, effective, and economical; and whether programmatic and operational goals and objectives are being achieved.  x The plan was designed to serve as the basis for OIG activities for Fiscal Years 1995,  x1996, 1997, 1998, and 1999. The OIG will update and revise the plan in January 1997.  x[The listings and priorities in this plan will also contribute to improvements in the ongoing  xLdevelopment of the OIG audit universe, and will be the basis for future OIG annual audit  x!plans. Therefore, this strategic plan will assist the OIG to better address the audit requirements of its customers. x  xOn March 1, 1995, the House Appropriations Committee's Subcommittee on the  xLDepartments of Commerce, Justice, and State, the Judiciary, and Related Agencies, held  xa hearing in room H310 of the Capitol. The hearing was titled "Review of Department  x[and Agency Inspectors General Recommendations for Budget Savings." The Inspectors  xMGeneral of the thirteen agencies under the Subcommittee's jurisdiction were invited to  xtestify so that the Subcommittee could obtain their recommendations on ways to make  x.budgetary savings and spending reductions in their agencies, and to find ways to reduce  xZexpenditures through increased efficiency. The Subcommittee hoped to hear some specific  xrecommendations that the Subcommittee could followup on when the agencies testified about their budget requests in the coming weeks.  xThe Acting Inspector General testified before the Subcommittee and submitted a  xcomprehensive written statement. He described OIG activities for FY 1994, and current  x0activities in FY 1995. He also stressed his office's strategic planning process, and  xidentified those programs and operations which are priorities for future audit activity. The  xActing Inspector General responded to questions from the Chairman concerning the FCC  xMreport by the Special Counsel for Reinventing Government, and was asked to identify  xspecific cost savings from the various legislative proposals contained therein. The Acting Inspector General also responded to questions regarding the ongoing spectrum auctions.  xThe inspection program begun during the last reporting period, which was designed to  xprovide the Commission with an independent evaluation of the operations of the FCC's  x35 field offices, has been suspended pending the completion of the Compliance and Information Bureau's reorganization, described in part I of this report.  \."-  h"$K ""$ 0*%%","ԌSPECIFIC REPORTING REQUIREMENTS OF SECTION 5(a) OF  h%KTHE INSPECTOR GENERAL ACT  hJK   \o-   !xThe following summarizes the Office of Inspector General response to the twelve  xspecific reporting requirements set forth in Section 5(a) of the Inspector General Act of 1978, as amended.  ZQ- x1. A description of significant problems, abuses, and deficiencies relating to the  x{administration of programs and operations of such establishment disclosed by such  ZE -activities during the reporting period.  \? -   xNo such problems, abuses, or deficiencies were disclosed during the reporting period. x  Z'- x2. A description of the recommendations for corrective action made by the Office during  Z!- xthe reporting period with respect to significant problems, abuses, or deficiencies identified  Z-pursuant to paragraph (1). xNo recommendations were made. See the response to paragraph (1).  Z- x3. An identification of each significant recommendation described in previous semiannual reports on which corrective action has not been completed.  \-   ]xIn an audit report issued September 30, 1994, entitled "Report on Internal Controls  x and Compliance related to the General Ledger and Treasury Financial Reports for the  xLFiscal Year ended September 30, 1993," OIG auditors concluded that the FCC is in noncompliance with GAO financial accounting and reporting requirements.   xIn another audit report issued September 30, 1994, entitled "Report on Internal  xControls and Compliance Related to the Budget Operations for the Fiscal Year ended  xSeptember 30, 1993," OIG auditors reported that FCC budget execution, internal control,  xjand reporting system procedures do not conform to the requirements and regulations for Federal agencies and commissions.   NxBoth audit reports were fully summarized in the last Semiannual Report. The FCC  x\is now in the process of converting to a new accounting system which is designed to  x/address the findings of financial and accounting reporting deficiencies and the related"$0*%%d#"  xLrecommendations made by the Inspector General in these audit reports. The conversion to the new accounting system will be implemented by and effective on October 1, 1995.  Z- x\4. A summary of matters referred to prosecutive authorities and the prosecutions and  Z-convictions which have resulted.   |xTwo investigations opened during the reporting period were referred to the U.S.  xDepartment of Justice pursuant to section 4(d) of the Inspector General Act. The first  x0involves an alleged conflict of interest by a former FCC employee, and the second  x1involves the possible forgery of official FCC records by a nonemployee. Both  xinvestigations are ongoing; therefore, prosecution has not been initiated in either case and no convictions have resulted.  \ -  5.xA summary of each report made to the head of the establishment under section  Z -(6)(b)(2) during the reporting period.   xNo report was made to the Chairman of the FCC under section (6)(b)(2) during the reporting period.  Z- x6. A listing, subdivided according to subject matter, of each audit report issued by the  xOffice during the reporting period, and for each audit report, where applicable, the total  xdollar value of questioned costs (including a separate category for the dollar value of  xunsupported costs) and the dollar value of recommendations that funds be put to better use.  \r-   xEach audit report issued during the reporting period is listed according to subject matter and described in part III, above.  ZZ-7. A summary of each particularly significant report.   xEach audit report issued during the reporting period is summarized in part III, above.  ZB- L   x=8. Statistical tables showing the total number of audit reports with questioned costs and  Z6!-the total dollar value of questioned costs.  \0"-  \*#- x The required statistical table can be found at Attachment A to this report. "$$0*%%""Ԍ Z- x9. Statistical tables showing the total number of audit reports with recommendations that  Z-funds be put to better use and the dollar value of such recommendations.  \- x The required statistical table can be found at Attachment B to this report.  Z- x10. A summary of each audit report issued before the commencement of the reporting  xperiod for which no management decision has been made by the end of the reporting  xperiod (including the date and title of each such report), an explanation of the reasons  xsuch management decision has not been made, and a statement concerning the desired  Z-timetable for achieving a management decision on each such report. xNo management decisions fall within this category.  Z -  x11. A description and explanation of the reasons for any significant revised management  Z -decision made during the reporting period.  \- x No management decisions fall within this category.  Z- x-12. Information concerning any significant management decision with which the Inspector  Z-General is in disagreement. xNo management decisions fall within this category.