John Sarkis

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Staying De Minimis with USF Traffic Studies

Posted by John Sarkis on Jun 7, 2022 10:41:17 AM

In February, WISPA urged the FCC to update its Universal Service Fund (USF) programs to better accommodate small broadband-only providers who deliver needed internet access to millions of Americans in high-cost areas and in the digital divide.

Each quarter hundreds of small communications providers in America overpay their USF Fees. A volatile contribution factor, along with a high Safe Harbor rate are to blame.

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Topics: USF

The Federal Government is Preparing to Funnel Billions to State Broadband Offices

Posted by John Sarkis on May 2, 2022 1:46:17 PM

The federal government has been investing big-time into nationwide broadband access for underserved communities. With the passage of the American Rescue Plan Act (ARPA) and the Infrastructure Investment and Jobs Act (IIJA), state governments are beginning to develop plans to connect local communities with high speed, affordable broadband. 

Historically, broadband funding has been distributed and managed by federal entities such as the USAC, with programs such as the Connect America Fund, which dispersed funds directly to internet providers. This time, state governments are managing grants and making sure that their local communities have access to high speed and affordable broadband. 

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Topics: Regulatory, Broadband, connect america fund, State Funding

There's Still Time to Lower USF Fees Before Your 499A Filings

Posted by John Sarkis on Mar 1, 2022 9:00:00 AM

 

Time after time, carriers contact us about wanting to do something to lower their skyrocketing USF Fees.

Some carriers may feel like they are at the mercy of an endless cycle of a volatile contribution factor that has risen drastically in the past decade -from 15.5 percent in the first quarter of 2011 to 31.8 percent in 2021.

A solution that carriers overlook is their ability to reduce their Federal USF tax by means of a Traffic Study.

By using the Safe Harbor Rate, you can be spending twice as much as you should on USF Fees when filing your 499s. With the deadline for carriers to submit their 499As around the corner, the time to complete a Traffic Study is now.

Here's a direct quote from a recent USAC Webinar;

The best (easiest) time to switch from using the Safe Harbor percentage to traffic studies is with the 1st quarter filing of the year ... Keeping methodology consistent for all quarters simplifies annual revenue reporting on the applicable Form 499-A due the following April.

These spikes in USF fees can be managed by ditching the Safe Harbor rate when you file your 499s, and instead performing a traffic study.

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Topics: USF, Regulatory, Cost Savings, FCC

Changes to Performance Testing Sample Size Approved for 1Q and 2Q 2022

Posted by John Sarkis on Jan 24, 2022 1:13:25 PM

Earlier this month, the NTCA- otherwise known as the Rural Broadband Commission, filed a petition for waiver requesting the Wireline Competition Bureau (Bureau) to extend the aid provided by the previous December 2020 Waiver Order. The Rural Broadband Commission explained in the petition that broadband providers continue to face challenges such as supply chain issues as a direct result of the Covid-19 pandemic.

The main requests of the NCTA were as follows;

  • The Commission should continue to allow A-CAM/RBE/Alaska Plan carriers to only pre-test 70% of the USAC-selected sampled locations for the first two quarters of 2022
  • Extend the “simple” waiver request for A-CAM/RBE/Alaska Plan carriers
  • Extend the pre-testing period for A-CAM/RBE/Alaska Plan carriers
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Topics: Broadband, FCC, connect america fund

USF Traffic Studies - White Paper

Posted by John Sarkis on Dec 13, 2021 10:57:40 AM

"A person doesn’t know how much they have to be thankful for - until they have to pay taxes on it."

Whether you’re a large ILEC, or a small rural voice provider, with every 499 submitted to the FCC carriers and their customers contribute a percentage of their international or interstate calls to the USF. While the USF has proven it’s importance with the introduction of rural broadband support and other funding grants, there’s an ongoing dilemma in regards to how carriers contribute to the USF.

Much of this dilemma stems from the FCC’s Contribution Factor and Safe Harbor Rate that many providers default to using to file their 499s.

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Topics: USF, Regulatory, FCC

How to Ensure Success in the Next Phase of Performance Measures Testing

Posted by John Sarkis on Nov 4, 2021 10:30:00 AM

Complying with the USAC’s requirements can be stressful. However, being non-compliant during the pre-testing phase isn’t the end of the world. In fact - it’s part of the process in most providers' deployment journeys. 

As we jump into the fourth quarter of ACAM-I pretesting and prepare for the upcoming 2022 official testing, it’s important that providers determine what tactics they used to be successful this past year.

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Topics: Telecom Data Analytics, Regulatory, Broadband, FCC, stamper box, connect america fund

Translating Data Into Invoices For International Customers

Posted by John Sarkis on Oct 19, 2021 1:00:00 PM

 

Phone calls have no boundaries, borders, or language barriers. However, billing for them does. 

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Topics: Telecom Data Analytics, Inter-Carrier Billing, Cost Savings, Data Driven

I Rarely Get Subpoena Requests; Why Should I Worry About Them?

Posted by John Sarkis on Sep 3, 2021 12:23:45 PM

If your company received a lawful request for specific Call Detail Record from three years ago to help with a current criminal investigation, would you be able to fulfill the request?

In our regulatory work, we’ve worked with carriers who get many subpoena requests, and we’ve had carriers that can’t remember the last time they got one. We’ve found that smaller providers don’t receive too many warrants or requests, but larger ISPs are routinely asked for this information. 

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Topics: Regulatory, Cloud Storage

USF Safe Harbor Rate is Costing Carriers Money

Posted by John Sarkis on Aug 10, 2021 11:19:32 AM

 

It's no question that the Universal Service Fund (USF) has proven it's value in creating an all-inclusive broadband network. However, the rising costs of USF fees have caused many industry professionals to call for a change in how service providers contribute to the fund. 

In our regulatory work, we're often shocked at how many providers don’t know that there are ways to cut their overall USF contribution to be a fraction of what it is now. 

To give a brief overview of the USF, it’s split between four separate funds;

  • Low-income Lifeline fund
  • Rural Healthcare fund (RHC)
  • E-Rate: For Schools and Libraries
  • High-cost fund
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Topics: USF, Regulatory, Cost Savings, FCC

Tandem Rehoming; How It's Done, and Why You Should Consider It.

Posted by John Sarkis on Jun 22, 2021 12:35:44 PM

The ongoing adoption of a full IP network and changing regulatory environment demands that telecom service providers examine their network infrastructure to determine how they can change operations to increase efficiency and profitability. Many communications service providers are constrained by legacy tandem networks that are difficult and expensive to maintain. This has caused telcos to consolidate their older tandem switches to extend other’s life cycles or upgrading to more modern tandems. In each case, the process of moving network lines from one switch to another has been coined with the term rehoming

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Topics: Rehome