Sometime last quarter, a controller at a mid-size VoIP provider finished his Form 499 and wondered why the universal service line on every invoice kept inching upward. He had followed the rulebook: apply the FCC’s safe-harbor ratio of 64.9% to VoIP revenue and 37.1% to wireless sales, multiply those totals by the quarterly contribution factor, and remit the money. What he didn’t realize until a traffic study told the real story is that his network sends barely one-third of its traffic across state lines. The other two-thirds never should have been taxed at the interstate rate.
The Universal Service Fund keeps broadband flowing to rural areas, school districts, and low-income households. To pay for that mission, the FCC sets a contribution factor every three months; for 3Q 2025, the factor is 36.0%. Providers multiply that percentage by the interstate and international portion of their telecom revenue. Safe harbor enters the picture only when a carrier cannot or will not analyze its call records. Convenient? Absolutely. Accurate? Rarely. Safe-harbor ratios were designed to keep tiny carriers in compliance, yet they have become the default for companies large enough to know better.
Imagine you invoice $2 million in VoIP services this quarter.
Apply the 36% contribution factor, and the gap becomes stark: roughly $ 467,000 in USF liability with safe harbor versus $ 238,000 with real data. That is $229 000 you could have plowed into marketing, fiber, or debt reduction instead of sending it to the fund.
A traffic study is not a spreadsheet trick; it is a disciplined, four-step audit:
Because each call is accounted for, you can prove the ratio you report. If a regulator questions your figures, ATS has the data to back it up.
Beyond just providing a traffic study to reduce contributions and customer bills, ATS offers near real-time traffic analysis into everyday workflows so that finance, product, and compliance teams all see the same live number.
A deeper feature list lives on the ATS Traffic Study service page, and you can browse how-to articles in our Compliance Hub.
One such client is Phone.com, a cloud-based phone systems and VoIP provider based in New Jersey that provides communication services for small and medium-sized businesses across the country. They had reached out to us about rising USF costs and were interested in how a traffic study could benefit them. In the end, their Percent of Interstate Usage came back at 31.3% — effectively cutting their USF fees by more than half. Check out the full case study for more information.
If the study fails to uncover at least ten% in USF reduction, we tear up the invoice. There is no fine print, just a handshake.
Regulation is unavoidable, but overpaying the USF is optional. A precise traffic study turns raw call logs into hard-dollar savings, and ATS wraps that analysis in tools your finance team will actually enjoy using. Measure, verify, save, then put those dollars back where they belong.