High Cost

Filing FCC Form 481

Filing and Certifications
Section 100
Section 200
Section 300
Section 400
Section 500
Section 900
Section 1000
Section 1200
Section 3005

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Q1: How do I file the FCC Form 481?

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.

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Q2: What is the filing deadline for the FCC Form 481?

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.

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Q3: Once I start filing, can I save and come back to finish the form later? If so, how?

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.

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Q4: Where are the FCC Form 481 templates, online user guide, FCC Form 481, and form instructions posted?

A4: The FCC Form 481, online user guide, filing templates, and form instructions are currently available on the High Cost Program Forms page. Use the E-File system to file the form online.

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Q5: There are several statements pointing to new reporting requirements for High Cost and Lifeline Program participants in the FCC Form 481. Can you please provide the rule, order, or Public Notice for each of these new reporting requirements?

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 the Rate-of-Return Order (FCC 16-33) and two Public Notices regarding rate comparability (DA 17-167 and DA 17-346).

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Q6: What does the term "program year" mean?

A6: Program year means the year that funding is received. This year's filing (due by July 1, 2019 ) is called Program Year 2020 because the information in the filing will be used for disbursements for 2020 . The data filed is from 2018 , which is the most recent full calendar year data available.

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Q7: What are the various user designations in E-File and what do they mean?

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:

  • 481 Officer: An officer of the company who may enter and certify data for the FCC Form 481,
  • 481 Agent: An individual outside your company who has the ability to enter data but not certify the FCC Form 481, and
  • 481 User: An individual within your company who has the ability to enter data but not certify the FCC Form 481.

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Q8: Are there any issues with browser compatibility that I should know about when filing?

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.

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Q9: What is the contact information for E-File and FCC Form 481-related questions?

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.

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Filing and Certifications

Q10: Where in CFR Section 54.313 or Section 54.422 does it indicate that a Company Officer must make the certification?

A10: On pages 35 and 36 of the FCC Form 481 Instructions, it is stated that a Company Officer must provide a signature attesting to the FCC Form 481 filing.

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Q11: If a revision to an FCC Form 481 were filed, would USAC consider ways to notify state commissions and the FCC of those revisions?

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.

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Q12: If you have an ETC who is a CLEC and does not receive HCL or Lifeline Program support are they required to file an annual FCC Form 481 report?

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.

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Q14: For Program Year 2020, is the reporting year, for purposes of answering questions on the form, considered to be 2018?

A14: That is correct. For the filing due on July 1, 2019, carriers should report data related to 2018 to assure certification for support to be received in Program Year 2020.

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Section 100

Q15: Are carriers required to submit progress plans on their five-year reports this year?

A15: No, the launch of the HUBB portal and the associated deployment location reporting requirements has eliminated the need to provide this information (formerly Section 100).

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Section 200

Q16: For outage reporting, should data be from the 2018 calendar year?

A16:Yes, the Program Year 2020 filing of FCC Form 481 reports data from the 2018 calendar year.

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Q17: For 220c2, should the response be the total number of customers in the SAC or company-wide?

A17: The response should be specific to the SAC being reported upon in the respective FCC Form 481.

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Section 300

Q19: On Line 320, if there were no unfilled service requests, do I need to upload an empty file in order for the line item to be considered complete?

A19: 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.

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Q20: Regarding broadband unfilled orders, if a customer calls and we do not offer service in their area at the time they call, is that considered an unfulfilled order?

A20: The order would only be an unfulfilled order only if the service is offered within the SAC being reported upon.

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Q21: For Line 320, for reporting unfulfilled broadband service requests, should we report counts of customers where their distance from our equipment makes it financially unreasonable to provide or build service to them?

A21: 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).

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Section 400

Q22: If we have no complaints to report, do we still need to populate a "0" in Line 420?

A22: 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."

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Q23: How do we define complaints (voice or broadband)?

A23: The term "complaints" is used to refer to any formal complaints filed with state regulatory commissions or the FCC.

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Section 500

 

 

Section 900

Q25: What is the character limit in Line 910?

A25: You may enter up to 1000 characters on Line 910.

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Q26: Are carriers expected to complete Tribal lands reporting in the FCC Form 481 filing?

A26: 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 Instructions 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)."

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Q27: Does the letter demonstrating coordination with the Tribal government need to be filed yearly?

A27: ETCs must continue to engage with Tribal governments and report on the steps they have taken to engage with Tribal governments each year (see Public Notice (DA 12-1165), para. 7).

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Section 1000

Q28: Is the explanation for how you meet the 2 standard deviation requirement (Line 1010) optional?

A28: The explanation is optional but can be provided if the carrier wants to elaborate on its compliance.

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Q29: Section 1000 asks for Voice Service Rate Comparability, to confirm that carriers do not charge more than two standard deviations above what the Wireline Competition Bureau claims is the national urban average service rate which it is supposed to be publishing annually. What is the current rate we should be comparing to?

A29: The most recent published survey was released on December 20, 2018 . Public Notice (DA-1280) 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 $51.6 1 (see paragraph 2). In addition, this Public Notice also released broadband rate comparability benchmarks to comply with 54.313(a)(12). The FCC released a Public Notice (DA 17-346) on April 11, 2017 setting the rate comparability benchmarks for carriers operating in Alaska.

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Q30: For Line 1000, if the sum of the basic rate, federal subscriber line charge (SLC), and state SLC exceed the reasonable comparability benchmark provided by the FCC (response = no), what else should a carrier do to address this?

A30: 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.

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Q31: Did the broadband pricing self-certification to be within a specified reasonable range get approved? Did the voice pricing requirements get approved?

A31: 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 17-167.

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Section 1200

Q32: Is the Lifeline Program section deemed compliant if terms and conditions are an upload, and the rate/minutes are provided via the web link? Is the use of both the upload and web link an acceptable way to satisfy the requirements?

A32: 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.

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Section 3005

Q36: If a company sells mid-year, the new owners will ultimately only have an audit review done on the financials for the portion of the year they owned the company and not the entire "fiscal year end." When it comes time to certify that the financials were audited, how should this be handled?

A36: 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.

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Q38: The Rule (CFR Section 54.313(f)(1)(ii)) tied to Line 3012 requires the, "Number, names, and addresses of community anchor institutions to which the ETC newly began providing access to broadband service in the preceding calendar year." There is a question of the term "newly began providing access." Does this include all anchor institutions to which the carrier has made broadband available, regardless of whether or not the institution subscribes to the service? Alternatively, is it just those institutions that are actually subscribing to the broadband service?

A38: 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.

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Q40: What should we do if our audited financials will not be available by the filing deadline, July 1, 2017?

A40: ETCs that will not have audited financials by July 1, 2017, should seek a waiver of the filing deadline.

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Q41: Line 3012 – Community Anchor Institutions. What should be done if we do not have any new anchor institutions in the previous calendar year?

A41: 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.

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Q42: Line 3030: Is Telephone Plant in Service (TPIS) before depreciation, etc. or is that net plant? If a company is providing the RUS form on the balance sheet, would they provide the amount on Line 18 or Line 23?

A42: 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.

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Q44: Line 3012: What does "newly deployed" mean?

A44: "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.

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Q45: What documents must privately held rate-of-return carriers that are not RUS borrowers but are audited in the ordinary course of business provide (Lines 3018-3021)?

A45: 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.

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Q46: For Line 3034 (Dividends), should cooperatives report patronage capital credits which they deem comparable to dividends paid for a C-Corp?

A46: To the extent patronage capital credits are deemed comparable to dividends paid for a -Corp, they should be reported on Line 3034.

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Q47: For all financial reporting lines (3027-3034), should we report ILEC only numbers or will total company numbers be OK?

A47: The Rules do not require that the company report ILEC-only financials, thus consolidated numbers would be sufficient.

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Q48: Do you have a specific definition for Anchor Institutions?

A48: According to footnote 37 of FCC 11-161, the term community anchor institutions includes schools, libraries, medical and healthcare providers, community colleges and other institutions of higher education, and other community support organizations and entities.

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