The first three rounds of USAC audits have cost some $250 million, yet in 2016, only $8 million of questionable funding was recovered. Many RoR carriers across the country have been subjected to audits where the cost of the audit surely exceeded the recovery of any questionable USF payments. Combined, these factors lead us to conclude that the USAC audit process must be significantly reformed, including focusing on demonstrably problematic programs and bad actors, and the utilization of the “materiality” threshold in accordance with generally accepted auditing standards.