Filing FCC Form 481
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.
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.
The FCC Form 481, online user guide, filing templates, and form instructions are currently available on the High Cost Program Forms and Filing Deadlines page. Use the E-File system to file the form online.
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).
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 2016, which is the most recent full calendar year data available.
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.
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.
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.
Filing and Certifications
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.
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.
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.
State designated ETCs that receive Lifeline Program support must comply with 47 CFR Section 54.422(a) (State Designated).
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.
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).
Yes, the Program Year 2020 filing of FCC Form 481 reports data from the 2018 calendar year.
The response should be specific to the SAC being reported upon in the respective FCC Form 481.
The question in section 220 seeks to identify as to whether an outage affected more than just the SAC being reported upon.
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.
The order would only be an unfulfilled order only if the service is offered within the SAC being reported upon.
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).
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.”
The term “complaints” is used to refer to any formal complaints filed with state regulatory commissions or the FCC.
CFR Section 54.313(a)(5) states, “Certification that it is complying with applicable service quality standards and consumer protection rules.”
You may enter up to 1000 characters on Line 910.
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).”
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).
The explanation is optional but can be provided if the carrier wants to elaborate on its compliance.
The most recent published survey was released on December 20, 2018. Public Notice (DA 18-1280 ) 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 $51.61 (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.
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.
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.
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.
Carriers should provide total net income. When providing the RUS form, carriers should enter this number on Line 31.
PDF format is sufficient. No other format is required.
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.
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.
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.
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.
ETCs that will not have audited financials by July 1, 2017, should seek a waiver of the filing deadline.
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.
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.
Carriers should indicate the amount declared.
“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.
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.
To the extent patronage capital credits are deemed comparable to dividends paid for a -Corp, they should be reported on Line 3034.
The Rules do not require that the company report ILEC-only financials, thus consolidated numbers would be sufficient.
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.