High Cost

Trainings & Outreach

HCLI News - January 2015

Please Note: This is the last issue of HCLI News! The High Cost and Lifeline programs will publish separate newsletters beginning February 2015 to better serve the interests of their unique audiences. Recipients of HCLI News will automatically be subscribed to both the High Cost Reporter and the Lifeline Program News publications. To manage your subscription or unsubscribe, follow the link at the bottom of any newsletter.

HCLI News

Deadlines

Be sure to plan for these important upcoming deadlines for carriers participating in the High Cost and Lifeline programs. Visit the High Cost Program Forms page or the Lifeline Program Forms page on the USAC website for access to forms and instructions.

DUE

PROGRAM

DATA

January 31 Lifeline Program

FCC Form 555

February 2 High Cost and Lifeline Program FCC Form 499-Q
June 16 High Cost Program Connect America Fund ICC Data

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Compliance

Mobility Fund Reminder

High Cost Program

Carriers receiving Mobility Phase 1 support who have reached the milestone(s) necessary to be eligible for subsequent rounds of support must complete FCC Form 690 in order to receive Payment 2 or 3. Please note that this is separate from and in addition to the required annual FCC Form 690 submission. FCC Form 690 can be filed via USAC's E-File system.  Once a carrier has reached FCC Form 690 (see USAC's FCC Form 690 Online User Guide for assistance), the carrier should select either "Create Payment 2 – Form 690" or "Create Payment 3 – Form 690." The system will provide the option to copy data filed in the most recent filing into the current filing. Following completion and certification of the FCC Form 690, USAC will begin the review of the second or third payment requests.

For more information on the Mobility Fund and the requirements for subsequent payments, please see FCC 11-161.

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High Cost and Lifeline Programs BCAP External Audits Begin in January 2015

High Cost and Lifeline Programs

Beginning again this month, USAC has contracted with external audit firms to conduct Beneficiary and Contributor Audit Program (BCAP) audits, which ensure compliance with FCC rules and requirements by identifying areas of non-compliance and amounts of recoverable funds. USAC has worked closely with the FCC to develop and implement this program, and the audits are designed to avoid placing undue demands on auditees.

During the audits, the auditors will obtain documentation to support selected companies' eligibility requirements, line count submissions, and data submissions. A list of requested documentation is available on the Lifeline Program Audit Checklist and on the High Cost Program Audit Checklist.

More information about program audits is available on USAC's website, on the BCAP page in the Program Integrity section for the Lifeline Program and High Cost Program , including:

  • An overview of the BCAP audit process,
  • Common audit findings,
  • Details about audit reporting, and
  • Steps to minimize audit findings.

Many of the companies selected for audit are chosen at random. If your company is selected for an audit, it will receive an announcement letter detailing the purpose, scope, and starting date of the audit. Typically, selected companies will be contacted two to three weeks prior to the start of the audit.

Please feel free to contact the USAC Internal Audit Division by phone at (202) 776-0200 or via email if you have any questions or any concerns about BCAP audits.

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54.314 Annual 2014 Certifications Successful

High Cost Program

This year, USAC successfully received and processed the certifications for 1,789 carriers. More than a third of state commissions (35 percent) and two-thirds of self-certifiers (67 percent) certified using USAC's online E-File system. Carriers and state commissions are strongly encouraged to utilize this system. The system maintains a complete list of carriers under state jurisdiction and allows states to check a box to indicate which carriers need to certify. In addition, previous submissions may be used to prepare subsequent certifications. States and carriers who have used the system report that it is user-friendly and that it simplifies the process. For more information on how to certify online, please see the Online Filing User Guide for 54.314 State Certification or Online Filing User Guide for 54.314 Self-Use Certification, both of which are located on USAC's website on the Forms page.

All carriers are required to be certified by October 1 pursuant to Section 54.314. Carriers subject to state jurisdiction are certified by their states, while those who are not subject to state jurisdiction must self-certify. The certification asserts that all federal, High Cost Program support provided was used in the preceding calendar year and will be used in the coming calendar year only for the provision, maintenance, and upgrading of facilities and services for which the support was and is intended.

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Auditors Report Common Findings

Lifeline Program

USAC's Internal Audit Division conducts audits of carriers who receive Lifeline Program support to ensure compliance with applicable FCC rules, state laws, and program requirements. Below is a list of common non-compliance findings that were identified in recent audits. While this list is not comprehensive, we hope this information will encourage carriers to review their policies and procedures to ensure compliance in the future. The top five findings were (click here for a complete list):

Inadequate Advertising Method

  • Carriers must publicize the Lifeline Program and it must be reasonably designed to reach those likely to qualify for Lifeline Program support throughout the carriers' entire eligible telecommunications carrier (ETC)-designated study areas (47 C.F.R. Section 54.405(b)).

Lack of Subscriber Certification and Recertification Documentation

  • Carriers must obtain and/or maintain subscriber certification and/or recertification documentation (47 C.F.R. Sections 54.410(b)(1)(i), 54.410(b)(2)(ii), 54.410(c)(1)(i), 54.410(c)(2)(ii), 54.410(f)(2)(iii), 54.410(f)(3)(iii), 54.417(a)).

Improper Recertification Process

  • To the extent that a state eligibility database is available to confirm subscriber eligibility, carriers must use the state eligibility database to confirm the initial and/or continued eligibility of subscribers (47 C.F.R. Section 54.410(f)(2)(i)-(iii); DA 12-1626, at 1-2).
  • Carriers must inform subscribers that failure to respond to the carrier's recertification request within 30 days of the date of the request will trigger de-enrollment from the Lifeline Program (47 C.F.R. Section 54.405(e)(4)).
  • Carriers must de-enroll subscribers from the Lifeline Program within five business days after a subscriber failed to respond to the carrier's recertification request by the required deadline (i.e., within 30 days of the date of the request) (47 C.F.R. Section 54.405(e)(4)).

Duplicate Addresses for the Same Subscriber

  • Subscriber listings provided by the carrier to substantiate the total number of Lifeline Program subscribers reported on the FCC Form 497 should not contain the same address for the same subscriber listed more than once (47 C.F.R. Section 54.400(g)).

Improper Non-Usage Process

  • Text messaging is not a method by which subscribers may demonstrate the use of Lifeline Program-supported services (47 C.F.R. Sections 54.405(e)(3), 54.407(c)(2); FCC 12-11, n. 709).

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At The FCC

FCC Releases Report and Order

High Cost Program

The FCC Report and Order FCC 14-190 regarding the Connect America Fund was released December 18, 2014. The Order includes revisions to Connect America Phase II, adjustments to the planned model-based support to price cap carriers, where Phase II support will be available, near-term reforms for rate-of-return carriers and steps to strengthen the uniform national framework for accountability established in the USF/ICC Transformation Order.

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Did You Know

Relinquishment Reminder

High Cost Programs

If your carrier has relinquished its ETC designation, please send us a copy of the relinquishment order via email within a week of the order date. Failure to do so may necessitate recovery (via invoice) of support paid for the time following relinquishment.

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Subscriber Personal Identifiable Information

High Cost and Lifeline Programs

USAC would like to remind carriers to never transmit to USAC via email subscribers' personal identifiable information (PII). If PII must be transmitted, please contact USAC prior to transmission to coordinate a secure method of transmission.

Please also note that at no time will USAC ask carriers or consumers for the full nine digits of Social Security Numbers.

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Revenue Reporting

File FCC Form 499-Q by February 2

High Cost and Lifeline Programs

Each quarter, telecommunications carriers providing international and interstate telecommunications services, interconnected VoIP providers, and payphone providers that are aggregators, among others, are required to file an FCC Form 499-Q (Telecommunications Reporting Worksheet) with USAC. (Telecommunications Reporting Worksheet) with USAC. Note that de minimis exempt telecommunications providers do not need to complete FCC Form 499-Q.

Online users can pull up historical forms, edit and submit changes, and certify online through E-File. All paper FCC Forms 499 should be mailed to:

Universal Service Administrative Co.
Attn: FCC Form 499 Data Collection Agent
700 12th Street, NW
Suite 900
Washington, DC 20005

See USAC's Filing & Managing My 499 page for more details.

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Deadlines

FCC Form 555 Carrier Certification Forms Due January 31

Lifeline Programs

The FCC Form 555 is due to USAC by Jan. 31, annually. However, since January 31 falls on a weekend in 2015, the FCC Form 555 will be due on Monday, February 2, 2015. On this form, ETCs will include the results of the subscriber recertification of their subscriber bases as reported on the February 2014 FCC Form 497. ETCs must also file a copy of their forms with the FCC in Docket 14-171. ETCs can use the FCC's Electronic Comment Filing System to file a copy of the forms they submit to USAC.

USAC recommends using the online FCC Form 555 through USAC's E-File system. In E-File, ETCs may file either a single form submission for ETCs reporting for a single study area code (SAC) or bulk form submissions for ETCs reporting for several SACs. ETCs also have the option to submit paper forms via email. ETCs should use only one submission method to USAC.

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