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Why Your COP is Your Best Friend for Audit Protection

Shelly’s REPACK project has been wrapped up, reimbursed, allocated, and completely done for six years. She owns the whole shebang — the land the station lives on, the tower structure and the station itself.

During the project she’d hired out a PM group to handle the financial paperwork and deal with the FCC, but she’d managed the vendors, equipment ordering and installation on her own. Most of her conversations with the many participants had taken place over email, outside of a few phone calls, so she figured if she ever needed to go back and find something, it’d be in her inbox somewhere.

Besides that, all her invoices and Forms 399 were saved in a folder somewhere on her old computer — the one that crapped out a couple of years ago. But she’d backed everything up on an external hard drive so it’s all in there somewhere. No problem.

But here she is, six years later, looking at a letter from the FCC asking some very specific questions about the new transmitter she’d had installed at her station six years ago.

What are the model and serial numbers of the transmitter installed? What’s the invoice number from the supplier? Who installed it? Can she prove that she paid the installation vendor the same amount that she’d been reimbursed? Was an electrical permit required in her jurisdiction for that installation’s scope of work? How about a building permit?

Shelly has the answers to all of those questions… probably. Somewhere. She’s spent all day scouring through her old emails. She found the original invoice from the supplier that has the transmitter’s model number, but not the serial number. She found an email between her and her contractor to schedule installation, but the contractor indicates in that email that the installation technician is a subcontractor. She tried to plug in her external hard drive with all those old files into her new laptop but keeps getting an error message that includes the word “corrupted.” Not a great sign.

If the FCC had asked those questions six years ago, it would have been a lot easier to find those answers. It would still take a little digging, but when all that documentation was still pretty fresh at least it was close by. Now she’s not sure she can find those answers — but not finding those answers is clearly not an option.

Shelly needs a COP. She actually needed one back in 2021 when she finished her project.

Compiling a COP is standard practice for any type of construction project.

Not just for REPACK stations. Not just for broadcast stations. Not even just communications generally. If a construction project has a before and an after of any kind, it needs a correlating COP.

A COP (pronounced “Cee Oh Pea”) is a Closeout Package. It’s basically every document and photo related to a construction project put together in a way that’s organized and searchable. For REPACK stations, the express purpose of a REPACK COP is specifically to protect against audits.

For broadcast stations in general, the purpose of an industry-standard COP is also to act as audit protection, but it can additionally serve as a performance indicator, for example, or it can serve as historical reference material the next time your tower needs maintenance or a modification. Each COP is specific to the project — and you can really put whatever you want into your COP that you’ll want to have readily available if you need it in the future.

Every station already has COP materials. All those emails, all those invoices, those proofs of payments that are just kind of floating around in someone’s inbox, on someone’s desktop, hard copies on people’s desks — all of those materials are the things that make up a COP. It’s the compilation of all those documents that define the Package in Closeout Package.

Finishing the COP should be the very last step of a project. Of course, it doesn’t hurt to gather materials throughout the life of the project — but compiling it all into a single location, a single document, a single source of truth, and putting it somewhere safe and easily accessible is what truly marks the conclusion of a project.

In Shelly’s case, she had all of her COP materials available somewhere. But she never put them together — never packaged those materials at the end of her REPACK project. She thought that the fact those answers existed was enough. She could find them later.

But the more time that passes after a project, the less available that information becomes. The best time to put together a COP is immediately after the conclusion of a project.

If all you want your COP to contain are financial documents related to the FCC REPACK project, then that’s what your COP will be. But it needs to contain all documents related to the FCC REPACK project.

If you want an installation COP as a standalone or in addition to your REPACK financials COP, you can do that, too. But it’ll need to contain pre and post photos, performance test results, testing equipment calibration proofs, tower technician certifications, Bills of Lading, Bills of Material — it needs to be thorough.

If the purpose of a COP is to provide yourself with a quick way to find information related to your project — and that is, indeed, the purpose of a COP — then a COP with missing documents and gaps of information is really no good at all.

If Shelly had actually put together her COP in 2021 at the conclusion of her project but hadn’t included the transmitter’s model and serial numbers in her installation COP, then that COP wouldn’t be doing her any good when the FCC’s questions came along in 2028. And, to clarify, that’s not a random number.

And they made it clear in their public notice that it can also conduct audits throughout the life of the REPACK project at any point before the 10-year period begins.

“Audit” here can mean a couple of different things. The FCC may come along and audit a station’s REPACK financials to verify that the funds that were reimbursed were actually used for the purposes that were reported. They could ask for payment confirmations to show that reimbursed funds went to the vendors they were supposed to go to. They could come along and ask for engineering documentation that justifies that kind of equipment deployed to repack a station.

But they can also conduct physical audits. It’s one thing to send in an invoice for a new antenna — it’s quite another thing to prove that the antenna that was reimbursed is actually currently installed on site. The FCC may want to conduct a physical audit to verify that the equipment that was reimbursed and reportedly installed at a station is, indeed, installed at the station.

And they can do any type of audit between right now and 2023. They already have conducted a few audits so far. But consider this: the FCC is currently swamped in paperwork. Everyone’s submitting their various applications, Forms 399, invoices, and on and on, all at the same time.

At some point that paperwork flood will dry up. After all the financials are completed and everyone is reimbursed for their REPACK project, the FCC will then have time to go back and take a second look. They’ll have the time to audit.

Besides that, the FCC is not the only entity that can audit a station. If a station has a landlord other than the entity that owns the station, then that landlord can ask any questions they want to ask related to their property. If the jurisdiction where the station is physically located has its own requirements for safety or zoning or permitting, they can also audit a station against their own identified standards.

A well-put-together, thorough and accurate COP is what stands up to any kind of audit from any source.

Literally, no one wants to deal with a COP. The people who are getting paid to compile COPs don’t like COPs. The people who get paid to review and audit COPs don’t like COPs. Station owners who have to either put together their own COP or pay someone else to do it certainly don’t like COPs.

It’s a necessary evil — and it’s your best friend for audit protection.

COPs are basically like accident insurance. You hope you never need it. But the worst time to regret not having gotten it is when you need it badly but don’t have it.

The worst time to realize you should have put together your COP earlier is when someone’s asking a question that you can’t find the answer to. Shelly hasn’t ever heard the phrase “COP” or “Closeout Package” before, but she is regretting the day she thought about finding all of her documents and putting them in one place, but chose not to. Whether she knows it or not, what Shelly needs and regrets not having is a COP.

The last COP we put together for a client was a financials-only REPACK COP. And that beast came in at well over 5,700 pages. That’s just invoices, proofs of payments, Forms 399, reconciliation matrices, allocation history documentation.

We printed off that 5,700-page COP. Here’s what that looks like printed out.

That’s not even getting into the industry-standard installation COP — pre-construction photos, post-construction photos, performance test results, safety documentation, tower technician certifications, and so on. That’s not even getting to jurisdictional and engineering deliverables like a structural analysis, construction permits, zoning documentation, FAA requirements.

To put together a COP is to sift through a ton of information — and it is truly necessary to sift through all that information in order to get your COP to the ultimate goal of thoroughness and accuracy.

Then once you have everything in one place, it has to be usable. It doesn’t matter if you have a data dump in a single folder or document if you can’t actually find any information. If Shelly had combined every document into a single .pdf but didn’t organize it in a way that made sense, then she still wouldn’t be able to find answers to the questions posed by the FCC.

A COP is a tool. It should be doing work for the person or entity completing a project. By the end of a project and the conclusion of COP compilation, you should be able to find the answer to any question related to your project in 30 seconds or less. That’s what your COP should be doing for you.

If you choose to compile your own COP, by all means. It’s your station. But that is truly unnecessary, a huge time-consuming task and may ultimately end up being detrimental to your COP.

That does mean that you’ll want to get your COP as complete as possible before the reimbursement deadline so you don’t end up either paying out of pocket or spending a lot of your own time compiling your COP. Or even worse — ending up like Shelly.

Don’t neglect your COP. You have the materials already, whether you package them or not. You have the reimbursement opportunity, and that opportunity is there for a reason — the FCC actually wants you to compile a COP.

And of course, you know how to reach us. We can put together your COP in a format that is logical, organized, thorough, and searchable. We’re a resource to you, and we are here to alleviate the dreaded headache of putting together your closeout package.

Let’s talk about your COP.

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