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

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

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 Records 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

CALEA Compliance and Cost Reimbursement

Posted by Ryan Guthrie on Mar 3, 2020 11:00:00 AM

Did you know that the costs of complying with federal, state and local subpoenas can be passed along to the requesting authorities?

The big providers of telephone, cable, and data services process hundreds of law enforcement requests for data every month. If you are a smaller provider, you may not get that many requests but when you do it’s a major disruption to your operation. We have had several requests from smaller clients to support them in their efforts to comply with subpoena requests so we thought we would summarize how the CALEA process works.

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Topics: Regulatory, Big Data

CAF Broadband Performance Testing

Posted by Ryan Guthrie on Nov 14, 2018 1:41:13 PM

A few months ago the FCC released order DA 18-710 specifying the network performance testing and reporting required for ISPs who receive support from the Connect America Fund (CAF). The order is nearly 40 pages, but in this post we will summarize the requirements and provide some options for how ISPs can comply.

Who Must Comply?

Recipients of CAF high-cost universal service support, including:

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Topics: Regulatory, FCC, stamper box, connect america fund

Case Study - USF Traffic Analysis

Posted by Ryan Guthrie on Aug 14, 2018 12:19:51 PM

In February 2018, an up and coming VoIP service provider contacted us about performing a USF traffic analysis before their next quarterly filing. With the 'Safe Harbor' rate set at 64.9% and the quarterly contribution factor increasing to an all time high of 19.5%, D3 Unified Communications decided it was time to explore the option of performing a traffic study.

Within 1 week, we had a data sample from D3 and provided a free high level estimate of what their actual PIU would be if we completed the traffic study. Our quick analysis on the data estimated that their actual PIU would be less than half of the 'Safe Harbor' rate of 64.9%. The decision to perform the traffic study became an easy one to make as the savings were very evident.

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Topics: USF, Regulatory, Case Study, FCC

What Are 'Intermediate Providers' in the Rural Call Completion World?

Posted by Ken Babcock on Jun 19, 2018 10:25:18 AM

The Improving Rural Call Quality and Reliability Act of 2017 (“RCC Act”) was signed into law by President Trump on February 26, 2018.

The primary thrust of the Act was designed to focus attention on the quality and reliability of communication services provided to rural areas of the United States by entities referred to as Intermediate Providers.

The new law defines Intermediate Providers as follows:

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Topics: Regulatory, Rural Call Completion, FCC