LawFlash

Comment Deadlines Set for USF Contribution Rulemaking

June 07, 2012

The FCC’s proposal to modify the Universal Service Fund contribution and recovery methodology has been published in the Federal Register on June 7, 2012. Accordingly, comments on the proposal must be filed by July 9, 2012 and reply comments are due by August 6, 2012

The FCC requests comments in four primary areas: (1) who should contribute, (2) how contributions should be assessed, (3) methods to improve administration of the system; and (4) whether and how contributors should recover USF contributions from their customers. 

The FCC seeks to broaden the USF contribution base.  It asks whether VPN, MPLS, text messaging, one-way VoIP and broadband Internet access services revenues should be included in the base of assessable revenues. The FCC also seeks to broaden the base by changing the treatment of international revenues. 

The FCC is also considering a new assessment methodology based on connections, numbers, or a hybrid approach of numbers and connections. For each of these approaches, it seeks data and comment on the relevant definitions, such as “connection” and “assessable number.” They also seek comment on possible changes to the current system to provide clarity and make it flexible enough to accommodate future technological changes. 

With respect to recovery of USF contributions, the FCC seeks comment on new requirements for customer billing information, with the aim of harmonizing carrier recovery and reducing customer confusion. The rulemaking also seeks comment on whether recovery of USF contributions from customers should be prohibited. 

Please do not hesitate to contact us if you would like more information about how the FCC proposals may impact your company or would like to file comments on the FCC's rulemaking.

Tamar E. Finn 
tamar.finn@bingham.com
202.373.6117

Douglas D. Orvis II 
douglas.orvis@bingham.com
202.373.6041

This article was originally published by Bingham McCutchen LLP.