Filing the FCC Form 499-A. What s New For March 8, 2016

Transcription

1 Filing the FCC Form 499-A What s New For 2016 March 8, 2016

2 Welcome Housekeeping Audio is available through your computer s speakers The audience will remain on mute Enter questions at any time using the Questions box There is a large audience signed in today. We will answer as many questions as possible! If we can t answer today, we will publish an answer (and send to you via ) within a week Feedback polls throughout the webinar A recording will be available after the event

3 Welcome Today s Presenters Donna Lauer Senior Financial Analyst Mona Castleton Manager of Financial Operations Amy Kavelman Senior Telecom Industry Analyst

4 Filing the FCC Form 499-A What s New For 2016 March 8, 2016

5 Welcome Agenda What s New for the 2016 FCC Form 499-A Lessons Learned from Audits in 2015 E-File Helpful Hints

6 Welcome FCC Form 499-A The Annual Telecommunications Reporting Worksheet All telecommunications providers (including de minimis carriers) are required to submit FCC Form 499-A, which reports historical revenue data from 2015, by Friday, April 1, 2016.

7 Welcome 2016 FCC Form 499-A Did You Know? The FCC Form 499-A is used by the FCC for purposes other than Universal Service. LNP, NANPA, TRS, and FCC regulatory fee contributions DC Agent for Service of Process Statistical measurements of types of companies Regulatory contact information Jurisdictional (state and territory) information

8 Filing the FCC Form 499-A What s New in 2016

9 2016 FCC Form 499-A Notable Changes New For 2016 Layout of the information The content of the FCC instructions have been modified in order to make the instructions more user friendly. DC Agent Service of Process Change Filers are now required to submit updates to their registration information, including their DC Agent for Service of Process, to only the Universal Service Administrative Company (USAC), the Universal Service administrator (page 12). Traffic Studies Filing Change Removed the requirement for filers to send a copy of their traffic studies to the Commission. Filers must now only submit one copy to USAC at the address provided in the instructions.

10 New For FCC Form 499-A All companies that have access to the Internet must file the FCC Form 499-A/Q using E-File FCC announcements DA and Doc Online filing resources are available on USAC s website Online Filing Webinar (view in the Online Learning Library) Online User Guide (visit the Contributor Forms page)

11 Filing the FCC Form 499-A Lessons Learned: Audits from 2015

12 Lessons Learned Lessons Learned = Items Flagged in Recent Audits USAC audits a certain number of filers each year to ensure compliance Audit findings show areas that may be confusing to filers You can learn from the errors found on these audits

13 Lessons Learned General Requirements Filers must maintain documentation for 5 years. This includes documentation on how a filer determines jurisdiction for revenue. If a filer can determine the exact amount of revenue billed for interstate and international services, it should enter those amounts in columns D and E, respectively. Total revenue entered in column A includes revenue billed for intrastate service even though intrastate is not broken out on the FCC Form 499-A. In other words, A does not necessarily equal D + E. Good faith estimates must be based on information that is current for the filing period. Information supporting good-faith estimates must be made available to either the FCC or the administrator (USAC) upon request.

14 Lessons Learned Gross Revenue, Not Net Revenue The instructions to the 2016 FCC Form 499-A specify that filers are to fill out the form with gross revenue figures. Filers cannot subtract costs and filling in the form with net revenue Using net revenue is incorrect Gross revenue consists of total revenue billed to customers during the filing period with no allowances for uncollectibles, settlements, or out-of-period adjustments (Instructions on p. 9) Uncollectibles are subtracted out on lines 421 and 422

15 Lessons Learned Private Line Service Revenue Private line revenue includes dedicated circuits, private switching arrangements, digital subscriber lines, predefined transmission paths to end users, or frame relay and similar services where the customer is provided a dedicated amount of capacity Revenue from providing local private line services should be reported on line 406. Revenue from providing long distance private line services should be reported on Line 415. For international private line circuits, the filer should report the US portion to the theoretical midpoint on line 415 and the rest on line 418. Revenue from providing local private line and special access service to other contributors for resale should be reported on Line 305. Revenue from selling long distance private line/special access service to other contributors for resale should be reported on Line 312.

16 Ordinary Long Distance Service Revenue Lessons Learned Ordinary long distance provided to end users (except for interconnected VoIP) including toll service that uses Internet Protocol but that is not provided as interconnected VoIP should be reported on Line Flat monthly charges for long distance plans billed to customers, such as account maintenance charges, PICC pass-through charges and monthly minimums should be reported on Line All toll charges that are not specifically included on other lines go on Traffic originating in a foreign point, received in the US, and terminated in a foreign point is to be reported on either 311 or 414. Ordinary long distance provided to contributing resellers should be reported on Line 311.

17 Quick Poll Please take a moment to provide your feedback about USAC Customer Operations (2 questions about calling us)

18 Common Identifiers of Affiliated Companies Lessons Learned All affiliates must report the same common identifier on line All affiliates must report the same Employer Identification Number (EIN) on line If there are no affiliates, the box on line MUST be checked

19 Lessons Learned Mobile Services Along with monthly activation charges, revenue related to promotional sales, deferred device activation fees, rewards redemption, device activation fees, and charges for changing an end-user s mobile number should be reported on Line 409 of the form. Mobile overage, message charges, and roaming charges that are billed separately are reported on line 410. Mobile outcollect (long distance service revenue from roaming partners) is reported on Line 309.

20 Lessons Learned Toll Services Prepaid Calling Card Revenue must be reported on Line 411 at the face value of the card with no deductions for discounts provided to distributors.

21 Lessons Learned Other Revenue (line 418) Line 418 shows non-assessable revenue. Non-telecom revenue such as late payment fees and charges for detailed billing Information services and non-interconnected VoIP Voice mail, call moderation, call transcription Directory service, wiring, insurance, pole attachments Customer premise equipment (CPE) Sale or lease of dark fiber or bare transponder service without associated telecom services Telecommunications in a foreign country or between two foreign companies where the traffic does not transit the U.S.

22 Quick Poll Please take a moment to provide your feedback about USAC Customer Operations (3 questions about ing us)

23 Lessons Learned Federal and State Universal Service Contributions Amounts billed to end-users for federal Universal Service should be designated as either interstate or international revenue on line 403 in columns D or E, as appropriate. Amounts billed to end-users for state Universal Service should be included only in column A of line 403. Universal Service support revenue received by your company from USAC or a state agency is to be reported on line 308.

24 USF Surcharges on Invoices (line 403) Lessons Learned Filers should report intrastate revenue on line 403 in column A only if payments to state universal service programs were recovered by pass-through charges itemized on customer bills. We do not expect to see all of your revenue reported on line 403 and no revenue anywhere else on the form.

25 Lessons Learned Allocating Bundled Rates The FCC adopted two safe harbor methods for allocating revenue from bundled services. Report revenue based on unbundled prices, with no discount allocated to telecom services Treat all bundled service as telecom services Any other method Evaluated on a case-by-case basis Will not automatically be considered reasonable

26 Lessons Learned What is a Reseller? If one of your customers incorporates your wholesale services into an offering that is at least in part assessable telecom services and can be reasonably expected to contribute to federal Universal Service support, then your customer is a reseller. Revenue from resellers who contribute directly to USAC go in Block 3 (Carrier s Carrier Revenue Information) Revenue from resellers who are de minimis and thus do not contribute directly to USAC go in Block 4 (End-User Revenue)

27 Lessons Learned What is a Reseller? (continued) A filer must demonstrate that it has a reasonable expectation that its customer contributes to Universal Service support mechanisms by obtaining the following information from each reseller (safe harbor procedures) or providing other reliable proof: filer ID 2. Legal name 3. Legal address 4. Name of a contact person 5. Phone number of the contact person 6. Annual certification by the reseller regarding its reseller status

28 Lessons Learned What is a Reseller? (continued) An annual certificate: 1. Specifies year and services the filer is purchasing for resale 2. Is consistent with the following language: I certify under penalty of perjury that the company is purchasing service(s) for resale, at least in part, and that the company is incorporating the purchased services into its own offerings which are, at least in part, assessable U.S telecommunications or interconnected Voice over internet Protocol services. I also certify under penalty of perjury that the company either directly contributes or has a reasonable expectation that another entity in the downstream chain of resellers directly contributes to the federal universal service support mechanisms on the assessable portion of revenue from offerings that incorporate the purchased services. (see 2016 Instructions to the FCC Form 499-A, pp )

29 Lessons Learned What is a Reseller? (continued) Reasonable Expectation Standard Filers may rely on certificates that specify any of the following: 1. Entity-level certification; 2. Account-level certification; 3. Service-specific certification; or 4. Exception-specific certification

30 Quick Poll Please take a moment to provide your feedback about notices from USAC (2 questions about your preferences)

31 Agent for Service of Process is Required Lessons Learned An Agent for Service of Process, also known as a DC Agent, is a requirement of the FCC. All common carriers and providers of interconnected and non-interconnected VoIP must provide an address in Washington, DC to which the FCC can serve notices, process, orders, and decisions. A filer may also provide information on an alternate Agent at a location outside of DC. This is not required, but is allowed.

32 Lessons Learned Using the Ten Percent Rule If a private line circuit carries more than 10% interstate traffic, then all of the revenue from the circuit is considered interstate. In cases where a flat-rated unbundled network access element is ordered from a federal tariff, it should be classified as interstate, and if it is from a state tariff, it should be classified as intrastate. Filers that use ASRs in circuit ordering often receive information from the customer on the expected percent of interstate traffic for the circuit. 47 C.F.R (a) is the specific federal regulation that references the ten percent rule.

33 Lessons Learned Reseller Revenue on Line 511 Revenue from resellers that do not contribute to universal service support mechanisms (primarily de minimis filers) are included on Line 420 but may be excluded from a filer s TRS, NANPA, LNP, and FCC interstate telephone service provider regulatory fee contribution bases when reported on Line 511. You must have the 499 Filer ID for each reseller whose revenue you report here.

34 Questions? Lessons Learned from the 2015 Audits

35 Quick Poll Please take a moment to provide your feedback about USAC s training and outreach (2 questions about our website and tools)

36 Filing the FCC Form 499-A E-File Helpful Hints

37 Password Reset E-File: Helpful Hints Click the Forgot Password link on the E-File Sign In page

38 Password Reset E-File: Helpful Hints Enter your first name, last name, and user ID (your address) and click the Validate button

39 Password Reset E-File: Helpful Hints Fill in your filer ID and User Role (Officer or Preparer) and click Validate and Reset Password

40 E-File: Helpful Hints Password Reset CONFIDENTIAL - TEMPORARY PASSWORD RESET Your Name, The password for your Universal Service Administrative Company (USAC) online account "Your.Name@companydomain.ext" has been reset to the following: B7RVo#s8a1A! If you copy/paste this temporary password, be sure NOT TO COPY AN EXTRA SPACE. This will not allow you to access your account. Upon logging in, you will be prompted to provide a new password of your own choosing. You must keep this information confidential. This temporary password will expire in 72 hours. If this password has expired, click "Forgot Password" to reset the password. For E-File support, contact USAC at (888) For information about or assistance with about the RHC Program, contact the RHC Help Desk at (800) or rhcadmin@usac.org Note: If you believe you have received this in error, please notify USAC immediately at (888) or CustomerSupport@usac.org. Additionally, reset your password immediately using this Forgot Password link , Universal Service Administrative Company, All Rights Reserved.

41 Password Reset E-File: Helpful Hints

42 E-File: Helpful Hints Add New Officer If no former officer is available, add a new officer by selecting the link, Add FCC Form 499 Company Officer

43 E-File: Helpful Hints Add New Officer (continued) E-File will show you the current officer or officers names. If one of those officers are still active, they will be able to add any new officers or preparers. Wile Coyote

44 E-File: Helpful Hints Add New Officer (continued) If you have no active officers, you must have: The former officer s address The exact amount (dollars and cents) of the latest 499-A certified by the former officer Click the button that says All Company Officers listed above have left the company

45 E-File: Helpful Hints Add New Officer (continued) Enter the officer s name, job title, and phone number Enter the verification information

46 E-File: Helpful Hints Add New Officer (continued) If the verification information is entered incorrectly, your request will be manually reviewed and you may need to provide more information before your request is approved

47 E-File: Helpful Hints Temporary Reactivation If your account has been deactivated, this screen will appear when you enter your address and Filer ID Click Yes to request that it be temporarily reactivated

48 Temporary Reactivation (continued) E-File: Helpful Hints Fill out the Temporary Entitlements form and click Submit

49 Temporary Reactivation (continued) E-File: Helpful Hints If your request is successful, you will receive this screen Otherwise, you will receive an error message telling you what must be fixed.

50 E-File: Helpful Hints Error Messages If you get an error message, don t panic Most errors can be cleared by deleting your cache, history, and browsing data, then closing and reopening your browser Search in your browser s help screen to find out how to do that in the browser you use

51 Questions? What s New in the 2016 FCC Form 499-A

52 Filing the FCC Form 499-A Thank You!

53 FCC Form 499-A: What s New in 2016 Thank You! Thank you for joining us at today s webinar Short survey following this event Written answers to questions will be available within a week Sign up for the 498/499 Spotlight Quarterly Newsletter Go to usac.org and click subscribe in the upper-right corner For assistance with FCC Form 499-A: Call USAC s special FCC Form 499-A hotline at (866) ; the hotline will be available until April 5, Submit an to Form499@usac.org Visit our newly redesigned website: