The Universal Service Administrative Company (USAC) responded for the first time to an FCC rulemaking. USAC's 291 page detailed comments provide an insight into their perspective on a variety of issues. While recognizing the need for improvement to continue to streamline the application and invoicing process, the USAC Board of Directors has confidence that USAC has administered their responsibilities in an "…efficient, effective and competitively neutral manner….and have responded quickly and capably to the many changes to the Schools and Libraries Program.…" However, USAC does understand that the program complexities have created "difficulties" for some program beneficiaries.