A1: Carriers must complete and submit the FCC Form 481 online with USAC through the E-File system. With questions regarding how to create an E-File account, refer to the E-File user guide. With questions about filing the FCC Form 481 online through E-File, refer to the online filing user guide.
A2: The filing deadline is July 1. The FCC Form 481 must be filed annually to continue receiving High Cost Program support or to begin receiving support in the near future.
A3: Yes, you are able to save your form and come back to it at a later time to change data already entered or add new data. To access a form in progress, log in as usual and a list of forms in progress will display. Simply select the form you would like to continue working on.
A5: FCC Orders related to the High Cost Program can be found on the FCC Orders page of the USAC website. The Connect America Fund Order (FCC 11-161) includes detailed discussion of all FCC Form 481 reporting requirements. Recent orders include a Report and Order (FCC 14-190) and Public Notice (DA 16-362).
A6: Program year means the year that funding is received. This year's filing (due by July 1, 2016) is called Program Year 2017 because the information in the filing will be used for disbursements for 2017. The data filed is from 2015, which is the most recent full calendar year data available.
A7: Those who are designated as Company Officers and General Contacts on the FCC Form 498 are able to view and enter data, and certify the FCC Form 481 for their associated 498 ID in E-File. Company Officers and General Contacts are able to create and manage entitlements for users in E-File. Company Officers are ultimately responsible for entitlements in E-File.
For the FCC Form 481, there are three types of users:
A8: If you are using an older version of Internet Explorer (IE8 or below), you may experience issues while filing. IE10, Firefox, and Chrome are the most compatible browsers. If you have an option, Chrome is the top recommended browser for completing the filing.
A9: For Company Officers or General Contacts with questions about E-File (logging in to E-File, password questions, establishing entitlements, and/or authorized users), please contact Customer Operations via email or at (888) 641-8722. If you are not the Company Officer or General Contact listed on your FCC Form 498, Customer Operations cannot help you with E-File questions. Direct your questions to the Company Officer or General Contact who established you as an authorized user.
For any questions regarding the FCC Form 481, please email the High Cost Program team.
A11: Unfortunately, at this time, carriers are still responsible for providing a revised filing to the relevant state commissions, relevant authority in a U.S. territory, Tribal governments, and the FCC, as appropriate.
A12: If a carrier does not receive High Cost Program support (of any type) or any Lifeline Program support, and does not intend to receive either support in the future, then a carrier is not required to file an FCC Form 481.
A13: State designated ETCs that receive Lifeline Program support must comply with 47 CFR Section 54.422(a) (State Designated). On the FCC Form 481, that means these carriers must complete the Data Collection Form, the Operating Companies and Affiliates (800) section, the Terms and Conditions for Lifeline Program Consumers (1200) section, the Accuracy Certification screen, the Validate Filing screen, and the Certify Filing screen.
A14: That is correct. For the filing due on July 1, 2016, carriers should report data related to 2015 to assure certification for support to be received in Program Year 2017.
A16: "As applicable" means it applies depending on how the ETC receives support. If the ETC gets support on a wire center basis, it should report that. Price cap carriers and rural broadband experiment ETCs will receive support on a census block basis.
A17: ETCs should report how much support was used to improve service quality, service coverage, and service capacity to the extent they can. For voice and broadband, ETCs should report if they used support for voice-only purposes, if they used support for broadband-only purposes, or if they used support for commingled purposes. ETCs should be prepared to justify their explanation.
A18: The progress report should provide an update on the plans laid out in the five-year plan by explaining what a company has done to improve its network using universal service fund support.
A19: The carrier should not complete a new five-year plan but rather file a progress report on the original plan. If there are changes to future years, please specify that within the progress report. The annual update should explain that the carrier has acquired another ETC.
A20: Competitive ETC's are not required to continue to submit progress report updates if they are beyond the fifth year of their five-year plan.
A21: CAF-ICC support is what the ILEC receives from universal service fund and ARC is collected from regular customers. In determining support, the ARC is subtracted from eligible recovery. Since the actual amount received is already net of the ARC, carriers should report whatever CAF-ICC is received.
A22: FCC designated competitive ETCs must file progress reports in accordance with 54.313(a)(1) for their voice service.
A23: Price cap carriers will be exempt from the five-year plan requirement for the July 1, 2016 filing.
Q24: Title 47 CFR Section 54.202(a)(1)(ii) does not specifically state what support should be used to create the original five-year build-out plan. Title 47 CFR Section 54.313(a)(1) states, "A progress report on its five-year service quality improvement plan pursuant to 54.202(a) including maps detailing its progress towards meeting its plan targets, an explanation of how much universal service support was received and how it was used to improve service quality, coverage, or capacity, and an explanation regarding any network improvement targets that have not been fulfilled in the prior calendar year. The information shall be submitted at the wire center level or census block as appropriate."
Are we to include Interstate Common Line Support (ICLS) in the amount of universal service fund support received? CFR Section 54.313 states, "how much universal service support" and does not specifically state whether ICLS should be part of that amount or not.
A24: Try to account for any and all High Cost Program universal service support funds received from USAC. For example, if a carrier is presently receiving ICLS, they should factor ICLS support into the revenue stream for the period of time they expect to receive those funds. Your five-year plan should illustrate how expenditures were made which are consistent with the public interest obligations contained in the Order.
A25: Based on CFR Section 54.202(a), carriers should establish their targeted broadband deployments which address the public interest parameters cited in the FCC Order.
A26: If a carrier receives High Cost Program support (of any type), it is required to file the five-year plan with the FCC Form 481. Price cap carriers will be exempt from the five-year plan requirement for the July 1, 2016 filing.
A27: Submission of a five-year plan is not required for Lifeline Program-only carriers.
A28: Carriers whose ETC certification comes from a state commission should answer "No" for Line 110.
A29: Carriers need only submit an annual update to their existing five-year plan, which is the progress report. Carriers are not required to submit a new five-year plan.
A30: The proposed maps are acceptable. While there is no required format for the maps, the maps must detail progress towards meeting plan targets at the wire center level or census block level, as appropriate.
A31: Yes, this is a requirement that was approved in the instructions through the PRA process. You're encouraged to use a reasonable method to break out the expenses and to retain documentation to justify allocations. Be advised that the document-retention period for the High Cost Program is ten years (Section 54.320(b)). Compliance with document retention is critical to assisting with audits or other reviews conducted by USAC or the FCC.
A32: Progress reports should include a map each year.
A33: All universal service fund support received should be reported, including CAF-ICC.
A34: Although last year's progress report covered 2015 up to the filing date, the subsequent progress reports will cover the previous calendar year. Thus, the map that is filed July 1, 2016, will cover all of calendar year 2015.
A35: Maps would be appropriate if they detailed, at the wire center or census block level, which area has 4/1 or 10/1 speeds, etc. In addition, showing your plan for speed increases in the future would be acceptable as well.
A36: Maps must detail progress towards meeting plan targets at the wire center level (likely for rate-of-return filers) or census block level, as appropriate. There is no official format and no example of the maps. The approach of showing the current service offering and showing plans for unserved areas is appropriate. Note that Zip files cannot be attached to the FCC Form 481.
A37: Companies should use what they booked.
A38: Yes, a progress report should still be submitted (and not a new plan) that provides an explanation about why targets have not been met and which discusses revised targets (if any).
A39: Examples of a completed FCC Form 481 and five-year plan are not available.
A40: Yes, the Program Year 2016 filing of FCC Form 481 reports data from the 2014 calendar year.
A41: The response should be specific to the SAC being reported upon in the respective FCC Form 481.
A42: The question in section 220 seeks to identify as to whether an outage affected more than just the SAC being reported upon.
A43: If there are no unfulfilled service requests to report, enter "0" for Line 320. By entering "0," the system will not display Line 330 and thus no attachment will be required.
A44: The order would only be an unfulfilled order only if the service is offered within the SAC being reported upon.
A46: Yes, this should be reported as an unfulfilled broadband service request. Since 54.313(a)(3) requests, "The number of requests for service from potential customers within the recipient’s service areas that were unfulfilled during the prior calendar year" this would fit within that definition. Also, per Order (DA 14-190), "We clarify that rate of return carriers should report any requests that are deemed unreasonable as unfulfilled requests in their section 54.313 annual reports." Rate of return carriers should have sufficient evidence to demonstrate that unfulfilled requests were in fact unreasonable (paragraph 153).
A47: If a carrier indicates that mobile voice is offered, Line 420 will appear. If you have no complaints, you should populate this field with a "0."
A48: The term "complaints" is used to refer to any formal complaints filed with state regulatory commissions or the FCC.
A49: CFR Section 54.313(a)(5) states, "Certification that it is complying with applicable service quality standards and consumer protection rules."
A50: If you're a wireless carrier who receives High Cost Program support, include your state-wide rate on Line 702.
A51: Independent of how a carrier technically provides broadband service to the end user, whether or not it is through an affiliated ISP, the carrier should report any retail broadband service rates. Per Order (DA 13-1115), such certifications must be made regarding the provision of broadband Internet access either directly or indirectly to end users. Carriers must report all broadband services which meet the public interest obligations in the Order.
A52: For all exchanges, report any effective end user retail rates.
A53: Yes, the carrier would still be required to complete Line 703. Responding to Line 702 only identifies the state-wide rate for residential service. The carrier should populate Line 703 because it identifies other rate elements which the CETC charges to residential end users. Note that the carrier can place "All" in the exchange name (Column 703a2) when reporting a state-wide rate.
A54: For Line 703, state SLC and state universal service fund amounts should be included. Per the OMB approved FCC Form 481 instructions, Line 703b3 should report state SLC amounts and Line 703b4 should report state universal service fund amounts.
A56: Section 700 is for reporting voice services only based on all rates in effect as of January 1 of the reporting year. For the Program Year 2017, due by July 1, 2016, this would be all rates in effect as of January 1, 2016.
Regarding bundled service offerings, report the local service rate as tariffed, if applicable, or as itemized on end-user bills. If a carrier neither tariffs nor itemizes the local voice service rate on bills for bundled services, report the rate of a similar stand-alone local voice service offered in the study area.
A57: There are two ways to approach reporting for wireless carriers: 1) Report basic voice only rate (simplest plan), an equivalent of wireless dial tone; or 2) Follow what is specified in the official OMB approved instructions for the inputs for "Residential Rate." These elements include:
Voice service only
Rate by wire center or census block for each voice telephony service price offering (unless statewide)
All rates in effect as of January 1 of the reporting year for residential local service for all portions of the reporting service area.
If unlimited local service rate is not offered (only measured or message rate plans), report the local service rate which equates to the basic rate recurring charge for local service plus the additional charges incurred for measured service (calculate by the mean number of minutes of message units for all customers subscribing to that rate plan multiplied by the applicable rate per minute or message unit)
If a bundled service offering, report the local service rate as tariffed or as itemized on end-user bills, if applicable, and if not, report the rate of a similar stand-alone local voice service offered in the study area.
A58: If your company does not have a usage allowance, complete the following procedures:
A59: Carriers should only report state-imposed fees, not taxes, on the FCC Form 481.
A60: The service targeted is broadband-only service and not service bundled with any other service. If a carrier does not offer naked DSL as a stand-alone service, they can report a broadband rate equating to their bundled rate minus the average residential R1 rate study area. If there are more than two items in the bundle (such as local, long distance, and broadband), the carrier would need to determine a method for identifying the price of only the broadband component.
A61: Yes, if the rates don't differ between exchanges, then the "All - service name" input in Column B is acceptable.
A62: You may enter up to 1000 characters on Line 910.
A63: Carriers filing in accordance with CFR Section 54.313 need to complete the Tribal reporting section of the FCC Form 481. This requirement is highlighted in the OMB-approved FCC Form 481 InstructionsÂ Â and is also explained in Public Notice (DA 13-1707) (released August 6, 2013). Per the Public Notice, "For 2013, ETC’s that receive high-cost support must complete FCC Form 481 to include the following for those ETC’s that serve Tribal lands, a report on Tribal government engagement pursuant to Section 54.313(a)(9)."
A65: The explanation is optional but can be provided if the carrier wants to elaborate on its compliance.
A66: The most recent published survey was released on April 5, 2016. Public Notice (DA 16-362) states that each ETC, including competitive ETCs providing fixed voice services, must certify in the FCC Form 481 that the pricing of its basic residential voice services is no more than $41.07 (see paragraph 2). In addition, this Public Notice also released broadband rate comparability benchmarks to comply with 54.313(a)(12).
A67: In the December 2014 Connect America Fund Order (FCC 14-190), paragraphs 155-157, the FCC directed USAC to gather additional information when ETCs fail to make the reasonable comparability certification in their annual reports and to transmit that information to the FCC. The FCC indicated that an ETC may present factual evidence explaining the unique circumstances that preclude it from offering service at a rate meeting the requisite benchmark.
Providers whose rates are not in compliance with the reasonable comparability benchmark for fixed voice service should submit to USAC (1) proof that their rates are consistent with any applicable state requirements, and (2) an explanation of the specific costs that a provider believes justify retail rates above the reasonable comparability benchmark. USAC will provide this information to the FCC, which will determine what action, if any, should be taken regarding the non-compliance.
A68: In a December 2014 Order (FCC 14-190), paragraphs 119-123, the FCC created Section 54.313(a)(12) which requires recipients of High Cost Program and/or Connect America Fund support that are subject to broadband performance obligations to submit a broadband reasonable comparability rate certification with their annual Section 54.313 report (FCC Form 481). This requirement is now in effect beginning with the FCC Form 481 to be filed in 2016 (due July 1, 2016), addressing performance during 2015, and annually thereafter. For additional detail on the broadband rate comparability benchmark, please review DA 16-362.
A69: When filers make their reasonable comparability certifications, they can certify to the April 2015 benchmarks (as stated in DA 15-470), rather than the 2016 benchmarks that were released in DA 16-362
A70: The FCC Form 481 Instructions indicate that you have the option to provide this summary information of your Lifeline Program plan by either attaching a document at Line 1210 or entering a website address at Line 1220. The instructions do not indicate you can use both methods. In addition, you can add a website address within the attached document in order to consolidate your responses.
A71: Assuming there are not changes, the applicable speed will be 10/1 for PY2017.
A72: Carriers should provide total net income. When providing the RUS form, carriers should enter this number on Line 31.
A73: PDF format is sufficient. No other format is required.
A74: The OMB approved instructions (page 35) state the following, "Annual Report of Privately Held Rate-of-Return Carriers: Any privately held rate-of-return ETC must file a full and complete annual report of the company's financial condition and operations as of the end of the preceding fiscal year." This reporting can be handled in the following ways:
Annual RUS reports will satisfy this requirement (Operating Report for Telecommunications Borrowers).
If the carrier is not an RUS Borrower, they have two options.
If the company's financial statements are audited in the ordinary course of business, your company must attach either a copy of your audited financial statements or a financial report in a format comparable to an RUS Operating Report for Telecommunications Borrowers, accompanied by a copy of a management letter issued by the independent certified public accountant that performed the company's financial audit.
If the company's financial statements are not audited in the ordinary course of business, your company must attach either a copy of your financial statements which has been subject to review by an independent certified public accountant or a financial report in a format comparable to an RUS Operating Report for Telecommunications Borrowers with the underlying information subjected to a review by an independent certified public accountant and accompanied by an officer certification that: (a) the carrier was not audited in the ordinary course of business for the preceding fiscal year and (b) that the reported data are accurate.
Filers are responsible for attesting to the financial statements for the entire fiscal year of the SAC they own.
A75: The term "number" is included so it would not be required for reviewers to count the entries within the list. A numbered list would be a sufficient response.
A76: In the USF/ICC Transformation Order (FCC 11-161), paragraph 52, it states the following, "We will also require CAF recipients to report on the number of community anchor institutions that newly gain access to fixed broadband services as a result of CAF support." Thus, a carrier should include all community anchor institutions to which the carrier has made broadband available, regardless of whether the community anchor institution chooses to subscribe to the service.
A77: Carriers can include churches as part of the list they provide of newly served community anchor institutions. Churches can be included in this list, but they are not required to be included.
A78: ETCs that will not have audited financials by July 1, 2016, should seek a waiver of the filing deadline.
A79: Although officially not required, if a filer wishes to submit a list of all of the community anchor institutions that were being provided broadband prior to 2015, it may do so. Also, filers can indicate from the drop-down that they have no new community anchors to report in which case an attachment will not be required within the system.
A80: If gross TPIS is available, report the gross amount. Carriers may submit the net amount if the gross amount is not available within the attached financial statements. When a carrier is providing the RUS form, the amount should be entered on Line 18.
A81: Carriers should indicate the amount declared.
A82: "Newly deployed" means both (1) those who never had access to any broadband, and (2) those who had access to lower speeds but now have gained access to 10/1 speeds during the year.
A83: Carriers that are not borrowers from RUS have the option of either uploading a copy of their audited financial statement or entering their financials directly to the form (Line 3019). For carriers choosing the former option, they should submit their audit (including audit opinion issued by the independent certified public accountant that performed the company's financial statement audit) and a management letter. For carriers choosing the latter option, they should enter their financial statements directly in to the form and upload a management letter to line 3021. Those carriers must produce their audit financial statements, audit opinion, and related work papers upon request of the FCC, USAC, or the relevant state commission, relevant authority in a U.S. Territory, or Tribal government, as appropriate.
A84: To the extent patronage capital credits are deemed comparable to dividends paid for a -Corp, they should be reported on Line 3034.
A85: The Rules do not require that the company report ILEC-only financials, thus consolidated numbers would be sufficient.