Telecom Regulatory Reporting

Transcription

1 Telecom Regulatory Reporting The material appearing in this presentation is for informational purposes only and is not legal or accounting advice. Communication of this information is not intended to create, and receipt does not constitute, a legal relationship, including, but not limited to, an accountantclient relationship. Although these materials may have been prepared by professionals, they should not be used as a substitute for professional services. If legal, accounting, or other professional advice is required, the services of a professional should be sought. 2

2 Moss Adams Firm established in 1913 Serving telecom clients since 1957 The 11th largest accounting and consulting firm in the U.S. 1,800 staff and partners Organized by industry & service specialists Telecom personnel in Seattle, Spokane, Stockton, Kansas City and Portland offices 3 Course Outline FCC s Order on USF/ICC Reform New Reporting Requirements CPNI & Red Flags NECA Reporting (EC 1050) Line Counts 499 Reporting FCC Form 497 Truth-In-Billing USAC Audits Highlights of Other Reporting Forms 4

3 Housekeeping Class schedule Tuesday 8 4 / Wednesday 8 12 CPE forms Evaluation forms Regular breaks Facilities Restrooms Lunch Introductions 5

4 Summary of USF & ICC Reform Order & FNPRM CAF & ICC Reform Order & FNPRM Connect America Fund (CAF) and Intercarrier Compensation (ICC) Reform Order and FNPRM Approved October 27, 2011 Released November 18, 2011 Order primarily addresses interim ICC and USF reform Proposed effective dates beginning in 2012 FNPRM primarily addresses long term ICC and USF reform 7

5 CAF & ICC Reform Order & FNPRM Follow on Orders to clarify, review or reconsider certain issues Regression Order April 2012 Adopted calculation of cost limitations for HCLS Access Rate Clarification Order May 2012 Clarified the process for transitioning intrastate access rates Intrastate rate elements may be increased to accomplish revenue goal Intrastate rate elements must be raised to Interstate levels by July 1, CAF & ICC Reform Order & FNPRM Follow on Orders (cont.) 3 rd Order on Reconsideration May 2012 Reporting Requirements & Deadlines Document Retention Reporting End User Rates USF for Carriers in Alaska Revenue Baseline 9

6 CAF & ICC Reform Order & FNPRM Follow on Orders (cont.) 5 th Order on Reconsideration November 2012 Financial Reporting Requirements Waiver Standards 6 th Order on Reconsideration February 2013 Modifies calculation of limitations on costs for HCLS Dismisses several Applications for Review on other issues Establishes a progress reporting deadline of 11/18/13 for the WCB 10 CAF & ICC Reform Order & FNPRM Budget Up to $4.5B each year $1.8B for Price Cap carriers $500M Mobility Fund $100M Remote Areas Fund $2.0B for Rate of Return carriers Funding in a given year could be more or less Contribution will not exceed $4.5B + expenses 11

7 USF Reform Public Interest Obligations 4 Mbps downstream/1 Mbps upstream No 5 year requirement at 6/1.5 Mbps 100 millisecond latency, suitable for real time applications Deploy broadband upon receipt of a reasonable request for service, within a reasonable amount of time Annual reporting to the PUC and USAC Construction charges may be assessed pursuant to state requirements Additional requirements to be identified in FNPRM No further action at this point in time 12 USF Reform Limitations on CapEx and OpEx Implemented no later than 7/1/2012 Additional comment as part of FNPRM Regression analysis using publicly available cost, geographic and demographic data Comparison of costs to similarly situated companies Annual publication of capped costs that will be used in place of actual costs that exceed the cap Focused initially on HCLS, but FNPRM directs similar benchmarks for ICLS No action at this point in time 13

8 USF Reform Limitations on CapEx and OpEx Regression Order Implemented 2 separate regression based limitations CapEx Investments, reserve and depreciation OpEx All other expenses Phase in of limitations 25% in 2012 limited to 10% of total support 50% in % in 2014 and beyond Redistribution of support from limited carriers Calculation of 2 NACPLs (Capped & Uncapped) Annual updates performed by WCB 14 USF Reform Limitations on CapEx and OpEx 6 th Order on Reconsideration Combined CapEx and OpEx limitations 2013 simple addition of actual costs and limitations» Reduced # of impacted carriers from 159 to revised regression calculation 2013 impacts limited to 15% of total support Did not change any independent variables Provides WCB flexibility to change the regression annually or leave it constant for a period of time 15

9 USF Reform Corporate Operations Expense Cap on ICLS Effective 1/1/2012 Minor updates to the formula Loops 6,000 Loops monthly per loop expense = greater of $ ( * working loops) $63,000/working loops 6,000 Loops 17,887 monthly per loop expense = $ (117,990/working loops) Loops 17,887 monthly per loop expense = $9.56 Adjusted by GDP-CPI, beginning 1/1/ USF Reform Artificially Low Voice Rates 3 step phase in beginning 7/1/2012 7/1/2012 6/30/2013 = $ /1/2013 6/30/2014 = $14.00 Thereafter, determined by WCB annual survey Latest national average = $15.62 Includes state SLC, state USF fees and mandatory EAS Dollar for dollar reduction in HCLS Requires annual submission of rates and fees to USAC 17

10 USF Reform Safety Net Additive grandfathered or phased out Eligibility as a result of 14% increase in TPIS Support grandfathered for the remainder of eligibility period No new support for costs incurred after 2009 Eligibility as a result of loss of access lines Support phased out over 2 years 50% of calculated support in 2012 Support eliminated in USF Reform Eliminate LSS as a separate support mechanism effective 7/1/2012 Limited ongoing recovery through ICC recovery mechanism Support frozen at 2011 support levels for 1/1/2012 6/30/2012 Subject to true up based on actual 2011 operating costs 19

11 USF Reform Adjusted HCLS Cap for 2012 Elimination of HCLS for Price Cap carriers requires that the overall size of the fund be reduced Includes Rate of Return study areas affiliated with Price Cap carriers NECA required to submit revised cap within 30 days 20 USF Reform Study Area Waivers Eliminate 1% change in USF guideline New standards for approval State PUC approval Public interest Streamlined Process Public Notice with 30 day comment and 45 day reply comments Absent action by the WCB, waiver deemed granted 60 days after reply comments 21

12 USF Reform Revisions to Parent Trap Rule If actual costs would generate lesser support, LEC will receive the lesser Does not apply to price cap carriers and their rate of return affiliates (frozen support) Effective 1/1/ USF Reform Cap per line support at $250 a month Effective 7/1/2012 Applies to both ETCs and CETCs Applies to all High Cost Support, excluding CAF ICC 3 year phase in of cap 7/1/2012 6/30/2013 = $250/line + 2/3 of difference 7/1/2013 6/30/2014 = $250/line + 1/3 of difference 7/1/2014 = No more than $250/line Carriers may file a petition for waiver or adjustment 9 of 26 limited carriers have filed for a waiver 23

13 USF Reform Unsubsidized Competition Eliminates support where unsubsidized competitor(s) offer voice and broadband to 100% of the study area Incumbent support phased out over 3 years Support frozen at the lesser of 2010 support or $3,000/line Support reduced by 33% each year FNPRM seeks comment on process for determining support in study areas with less than 100% overlap Ongoing comment process 24 USF Reform Waivers Waiver process to seek relief from some or all USF reforms FCC does not expect to grant waivers routinely Subject to a total company earnings review Carrier must demonstrate that reduction in existing support would put voice & broadband service at risk Consideration given if reform would cause a provider to default on existing loans or become insolvent 25

14 Interstate Rate of Return Prescription Represcription to be addressed in the FNPRM Order waives certain procedural requirements to streamline the process Primarily related to the filing of paper copies and service Notice and comment process to be used No further action at this point in time 26 ICC Reform Rate of Return Carriers Transition terminating switched access to bill and keep Cap all interstate switched access rates Effective 12/29/11 Originating and terminating» End Office Access Service» Tandem Switched Transport Access Service» Dedicated Transport Access» Other interstate switched access rate elements Carrier Common Line, as applicable Information Surcharge 27

15 ICC Reform Rate of Return Carriers Transition terminating switched access to bill and keep Cap intrastate switched access rates Effective 12/29/11 Terminating only» End Office Access Service» Tandem Switched Transport Access Service Includes reciprocal compensation No adjustment required/allowed if intrastate is already lower than interstate 28 ICC Reform Rate of Return Carriers Transition terminating switched access and reciprocal compensation to bill and keep Step 1 (July 1, 2012) 50% transition to interstate May maintain intrastate switched access rate structure; or Apply interstate rate structure for intrastate rates» Immediately migrate to interstate rates» Apply a transitional rate equal to 50% of the difference Step 2 (July 1, 2013) 100% transition to interstate 29

16 ICC Reform Rate of Return Carriers Transition terminating switched access and reciprocal compensation to bill and keep Step 3 (July 1, 2014) 1/3 of difference between interstate and $0.005 Step 4 (July 1, 2015) 2/3 of difference between interstate and $0.005 Step 5 (July 1, 2016) $ ICC Reform Rate of Return Carriers Transition terminating switched access and reciprocal compensation to bill and keep Step 6 (July 1, 2017) 1/3 of difference to $ Step 7 (July 1, 2018) 2/3 of difference to $ Step 8 (July 1, 2019) terminating switched end office access $ Step 9 (July 1, 2020) bill and keep Tariff filings to remove charges for Terminating End Office Access Charges 31

17 ICC Reform Rate of Return Carriers Other Issues Reforms do not automatically replace existing contracts or interconnection agreements Left to change of law, renegotiation and termination clauses in agreements Originating Access left to FNPRM, beyond cap Transport (originating and terminating) left to FNPRM, beyond cap Other rate elements left to FNPRM, beyond cap 32 ICC Reform Rate of Return Carriers Eligible Recovery Rate of Return Baseline 2011 Interstate Switched Access Revenue Requirement* Intrastate Switched Access Revenues Net Reciprocal Compensation Revenues - 5% annual reduction o Recovered from 3 sources Intercarrier Compensation Revenues Access Recovery Charge (ARC) Connect America Fund (CAF) * Revenue requirement submitted to NECA for 2011 tariff filing 33

18 ICC Reform Rate of Return Carriers Access Recovery Charge (ARC) Residential & SLB = $0.50/year for up to 6 years for a max of $3.00 MLB = $1.00/year for up to 6 years for a max of $6.00 SLC + ARC may not exceed $12.20 Local Rate + SLC + EAS + Surcharges + ARC $30.00 Residential, no benchmark for SLB & MLB ARC is not mandatory, but will be imputed for CAF Carriers that forego recovery in 1 year may not recover in future years ARC may not be assessed on Lifeline customers ARC may be determined at the holding company level 34

19 FCC Reform Order Reporting Requirements New 5-Year Service Quality Improvement Plan (a)(1), (a) Due July 1, 2013 Proposed Improvements or Upgrades Improvement of service quality, coverage, capacity Projected start & completion date Amount of investment Geographic areas Population served Wire center or census block level Separately broken out for voice and broadband 36

20 New 5-Year Service Quality Improvement Plan (a)(1), (a) Include new broadband obligations Take reasonable steps to offer broadband Provide broadband upon reasonable request Criteria to determine reasonable request» Line Extension Tariff» Aid to Construction Requests for broadband service are met within a reasonable time Carrier must define what is reasonable 37 Progress Report on Service Quality Improvement Plan (a)(1) Due July 1, 2014 and annually thereafter Maps detailing progress USF received Details of how support improved service quality, coverage, capacity Explanation of unfulfilled improvement targets Wire center or census block level Separately broken out for voice and broadband 38

21 Progress Report on Service Quality Improvement Plan (a)(1) Additional filing requirements (f)(1)(i), (ii) Due July 1, 2014 and annually thereafter A letter certifying that: Reasonable steps are being taken to provide broadband service at actual speeds of at least 4 Mbps downstream/1 Mbps upstream Latency is suitable for real-time applications, including VoIP Usage capacity that is reasonably comparable to those in urban areas Requests for such service are met within a reasonable time 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 39 Outage Reporting (a)(2) Due July 1, 2013 Detailed outage information for outages of at least 30 minutes; and At least 10% of the end users in the designated service area was affected; or A 911 special facility was affected Order requires outages to be separately reported for voice and broadband, however, FCC is not seeking PRA approval for broadband outage reporting at this time DA , footnote 46 40

22 Outage Reporting (a)(2) Report must include: Date and time the outage began Date and time the outage ended Brief description of the outage and resolution of the outage Particular services affected Geographic areas affected Steps taken to prevent a similar situation in the future Number of customers affected 41 Unfulfilled Service Requests (a)(3) Due July 1, 2013 and annually thereafter Voice Service Number of requests for voice service from potential customers that were unfulfilled Details of how the ETC attempted to provide service Broadband Service Number of requests for broadband service from potential customers that were unfulfilled Details of how the ETC attempted to provide service 42

23 Complaints Received (a)(4) Due July 1, 2013 and annually thereafter Voice Service Number of voice service complaints received per 1,000 connections Fixed Voice Telephony Service Mobile Voice Telephone Service Broadband Service Number of broadband service complaints received per 1,000 connections Fixed Broadband Service Mobile Broadband Service 43 Certification of Compliance with Service Quality Standards and Consumer Protection Rules (a)(5) Due July 1, 2013 and annually thereafter Separate certifications must be filed for both voice and broadband service 44

24 Certification of Ability to Function in Emergency Situations (a)(6) Due July 1, 2013 and annually thereafter Must certify ETC: Has reasonable amount of back-up power to function without an external power source Is able to reroute traffic around damaged facilities Is capable of managing traffic spikes caused by emergency situations Separate certifications must be filed for both voice and broadband service 45 Price Offerings (a)(7) Due July 1, 2013 and annually thereafter Pending OMB approval ETC s price offerings Voice Broadband - to include capacity range Format to be specified by the Wireline Competition Bureau 46

25 Additional Voice Rate Data (h) Due July 1, 2013 and annually thereafter Report rates for residential local service that are below local urban rate floor Residential local service rate State subscriber line charges State universal service fees Mandatory extended area service charges Report number of lines below local urban rate floor Report lines and rates in effect as of June 1 47 Additional Voice Rate Data (h) Due January 2 of each year Pending OMB approval Mid-year update Optional - to report increases to residential local rates or applicable state fees Mandatory - if residential local rates or applicable fees decrease after June 1 sampling date causing residential rate to fall below local urban rate floor Report rates and fees in effect as of December 1 48

26 Local Urban Rate Floor July 1, 2012 June 30, 2013 Local Urban Rate Floor = $10 July 1, 2013 June 30, 2014 Local Urban Rate Floor = $14 July 1, 2014 and thereafter Local Urban Rate Floor to be announced annually by Wireline Competition Bureau 49 Ownership Information (a)(8) Due July 1, 2013 and annually thereafter Pending OMB approval Report to include: Holding company Operating company Affiliates Branding ( dba or brand designation) Report relevant universal service identifiers for each such entity by Study Area Codes 50

27 Tribal Reporting (a)(9) Due July 1, 2013 and annually thereafter Pending OMB approval ETCs Serving Tribal Lands Information demonstrating that discussions with Tribal governments included (at a minimum): Needs assessment and deployment planning with a focus on Tribal community anchor institutions Feasibility and sustainability planning Marketing services in a culturally sensitive manner 51 Tribal Reporting (a)(9) Information demonstrating compliance with: Right-of-way processes Land use permitting requirements Facility siting rules Environmental review processes Cultural preservation review processes Tribal business and licensing requirements Certificate of Public Convenience and Necessity Tribal business license Master license Other related forms of Tribal government licensure 52

28 Additional Certifications (a)(10) Due July 1, 2013 and annually thereafter Pending OMB approval A letter certifying that the company s rate for voice services is no more than two standard deviations above the applicable national average urban rate for voice service The national average urban rate to be specified by the Wireline Competition Bureau and Wireless Telecommunications Bureau and released in a public notice 53 Network Performance Tests (a)(11) Pending OMB approval The results of network performance tests pursuant to the methodology and in the format determined by the Wireline Competition Bureau, Wireless Telecommunications Bureau, and Office of Engineering and Technology FCC DA clarifies ETCs are not required to file network performance results with the 2013 annual report 54

29 Financial Reporting (f)(2) Annual Report of the Company s Financial Condition and Operations Privately Held Rate of Return Carriers ONLY Pending OMB approval WCB to publish filing deadline 55 Financial Reporting (f)(2) Fifth Order on Reconsideration (FCC ), released 11/26/12 Carriers receiving RUS loans Submit 2011 RUS Operating Report Non-RUS borrowers that are audited Option 1 file audited 2011 financial statement Option 2 provide 2011 financial information in a form consistent with the RUS Operating Report Carriers that are not audited Option 1 file 2011 financial statement reviewed by a CPA Option 2 provide 2011 financial information in a form consistent with the RUS Operating Report Include officer certification that carrier is not audited in the ordinary course of business and reported data are accurate 56

30 Filing Deadlines (j) Annual reporting information must be filed no later than July 1 of each year in order to receive support for the following calendar year Reports filed after the July 1 deadline Filed no later than October 1 = support for the 2 nd, 3 rd, and 4 th quarters of the subsequent year Filed no later than January 1 = support for the 3 rd and 4 th quarters of the subsequent year Filed no later than April 1 = support for the 4 th quarter of the subsequent year 57 Certification of High-Cost Support Due October 1 receive support in succeeding year Certification in letter format Clearly referencing WC Docket No Filed with Office of the Secretary of the FCC and the Administrator of the high-cost fund 58

31 Certification of High-Cost Support Carriers Subject to State Jurisdiction State regulatory authority must file an annual certification identifying which carriers in the state are eligible to receive federal support Certify that all federal high-cost support provided to carriers within the state was used in the preceding calendar year and will be used in the coming calendar year only for the provision, maintenance, and upgrading of facilities and services for which the support is intended 59 Certification of High-Cost Support Carriers Not Subject to State Jurisdiction Carriers must file an a sworn affidavit executed by a corporate officer Certify that all federal high-cost support received was used in the preceding calendar year and will be used in the coming calendar year only for the provision, maintenance, and upgrading of facilities and services for which the support is intended 60

32 Certification of High-Cost Support Filing Deadlines Certifications Filed After October 1 Deadline Certifications filed on or before January 1 - receive support in the 2 nd, 3 rd, & 4 th quarters of that year Certifications filed on or before April 1 receive support in the 3 rd & 4 th quarters of that year Certifications filed on or before July 1 receive support in the 4 th quarter of that year Certifications filed after July 1 no support received in that year 61

33 FCC Study Area Boundary FCC Study Area Boundary FCC Report and Order, DA adopted & released November 6, 2012 Adopted data specifications for collecting study area boundaries FCC to issue Public Notice announcing deadline for submission Data will be used in: Quantile regression analyses to generate capex and opex limitations Determining whether unsubsidized competitors offer service within an ROR s study area 63

34 FCC Study Area Boundary Data submitted via web interface Data can be submitted by ILECS or state commissions ILECs must review and verify accuracy of data Company officer must certify Changes to study area boundaries must be submitted by March 15 of each year All ILECs must recertify study area boundary data every two years 64 Shapefile Data Specifications Must be submitted in esri shapefile format Each shapefile must represent a single study area Shapefile templates are available at Shapefile must: Contain one closed, non-overlapping polygon for each exchange in the study area that represents the area served from that exchange 65

35 Shapefile Data Specifications Shapefile must: Have associated with each exchange polygon the following identifying feature attributes: Operating Company Number Company name Exchange name Acquired exchange if applicable CLLI code(s) associated with exchange Study Area Code State FRN 66 Shapefile Data Specifications Shapefile must: Have an assigned projection with accompanying.prj file Use unprojected (geographic) WGS84 geographic coordinate system Have a minimum horizontal accuracy of +/- 40 feet or less, conforming to 1:24K national mapping standards Be submitted as a WinZip archive with a name containing the company name and study area code (e.g., CompanyName_ zip) 67

36 Cover Page Information Information to be submitted with shapefile(s): Contact person name Contact person address Contact person phone number Contact person address Date created/revised Methodology process steps to create the data Certifying official name Certifying official address Certifying official phone number Certifying official address 68

37 FCC Form 499 FCC Form 499 All telecommunications carriers providing telecommunications services, including interconnected VoIP providers, within the United States must file a 499 Very few exceptions/exemptions from filing 499A & 499Q available on USAC s website: 70

38 Form 499A Uses Calculate contributions to USF Based on interstate and international end user revenues 10% or more interstate traffic is interstate Telecommunications Relay Services (TRS) North American Numbering Plan (NANPA) Administration 71 Form 499A Uses Long-Term Number Portability (LNPA) Interstate Telecommunications Service Providers (ITSP) Regulatory Fee FCC Form 159-W assessment Satisfy obligation under Section 413 of the Act to designate a DC agent and FCC registration 72

39 Form 499Q Uses Forecast quarterly USF contributions Based on projected gross-billed end-user interstate and international revenues. Watch projected revenues so they end up matching Form 499-A end user interstate and international revenues. Non de minimis filers only 73 Form 499 Filing 499 is filed with USAC 5 times a year Form 499Qs due by: February 1st (4Q actual/2q projections) May 1st (1Q actual/3q projections) August 1st (2Q actual/4q projections) November 1st (3Q actual/1q projections) Form 499A is due by April 1 USAC s mailing address is on the form 74

40 Form 499 Revisions 499s must be revised if revenue data changes Form 499A revisions: Decreased contributions - filed by March 31st of the year following the original filing Additional contributions - accepted anytime. Form 499Qs 45 calendar days from original filing date 75 De Minimis Carriers Worksheet in 499 instructions estimates contribution less than $10,000. Watch instructions for changed contribution factor for de minimis test. Do not file 499Q Contribute to: NANPA LNPA TRS 76

41 De Minimis Carriers Carriers near $10K contribution should file a 499Q All carriers must file a 499A If 499A results in de minimis status, USAC will refund contribution Carriers that do not file a 499Q and go over $10K must pay contribution plus unadjusted contribution 77 A and Q Differences Form 499A reports actual annual revenues Form 499-Q reports actual quarterly and projected quarterly interstate and international end user revenue Quarterly revenues should equal annual revenues 78

42 Reporting Gross Revenue Report gross revenue from all sources. Gross revenues consist of total revenues billed to customers with no allowance for uncollectable, settlements, or out-of-period adjustments. Gross billed revenues maybe distinct from booked revenues. Deposits are not revenue. NECA pool companies report actual gross billed revenues not settlements. Surcharge treated as revenues included in revenue categories to which the surcharge applies Revenues on the customers bills to recover federal or state universal service support goes on line A Inputs Block 1 (lines ) Contributor Information Line 101, Filer 499 ID Line 102, Legal name of filer Line 103, IRS employer identification number Line 104, Name file is doing business as 80

43 FCC Form 499 Line 105, Telecommunications activities Select up to 5 boxes that apply (number in order of importance) Competitive Access Provider (CAP)/CLEC Cellular/PCS/SMR (wireless telephony included by resale) Interexchange Carrier (IXC) Coaxial Cable Incumbent LEC 81 FCC Form 499 Line 105, Telecommunications activities Interconnected VoIP Non-Interconnected VoIP Local Reseller Operator Service Provider (OSP) Paging & Messaging Payphone Service Provider Prepaid Card Private Service Provider 82

44 FCC Form 499 Line 105, Telecommunications activities Satellite Service Provider Shared-Tenant Service Provider/Building LEC Specialized Mobile (SMR) (dispatch) Audio Bridging Provider/ Teleconferencing Service Provider Toll Reseller Wireless Data Other Local (requires description) Other Mobile (requires description) Other Toll (requires description) 83 FCC Form 499 Interconnected VoIP 47 CFR Section 9.3 defines it as a service that: Enables real-time, two way voice communications Requires a broadband connection from user s location Requires Internet protocol-compatible CPE Permits users to receive calls that originate on the Public Switched Telephone Network (PSTN) and to terminate calls to the PSTN Vonage is; Skype isn t. When in doubt call USAC. Interconnected VoIP Non-Interconnected VoIP Difference from above is real-time that originates from or terminates not two way 84

45 FCC Form 499 Line 106.1, Holding company name Just added any entity that directly or indirectly owns or controls affiliated filers. Own means 10% equity interest Line 106.2, Holding company IRS employer identification number Line 107, FCC Registration Number (FRN) Line 108, Management company Line 109, Complete mailing address of reporting entity corporate headquarters 85 FCC Form 499 Line 110, Complete business address for customer inquiries and complaints Line 111, Telephone number for customer complaints and inquiries Toll-free number if available Line 112, Trade names used in the past 3 years in providing telecommunications known by customers 86

46 FCC Form 499 Block 2-A (lines ) Regulatory Contact Line 201, Filer 499 ID (repeat of Line 101) Line 202, Legal name of filer (repeat of Line 102) Line 203, Person who completed worksheet Line 204, Telephone number of this person Line 205, Fax number of this person 87 FCC Form 499 Line 206, of this person Required if available not for public release Line 207, Corporate office, attention name and mailing address for Telecommunications Reporting Worksheets Check if same name as Line 203 Check if same address as Line

47 FCC Form 499 Line 208, Billing address and billing contact person (bills for contribution will be sent to this address unless you attach a written request for alternative billing arrangements) Check if same name as Line Line 208.1, address where ITSP Regulatory Fee issues can be addressed 89 FCC Form 499 Block 2-B (lines ) Agent for Service of Process Line 209, D.C. Agent for Service of Process Line 210, Telephone number of D.C. agent Line 211, Fax number of D.C. agent Line 212, of D.C. agent Line 213, Complete business address of D.C. agent 90

48 FCC Form 499 Line 214, Local/alternate Agent for Service of Process (optional) Line 215, Telephone number of local/alternate agent Line 216, Fax number of local/alternate agent Line 217, of local/alternate agent Line 218, Complete business address of local/alternate agent 91 FCC Form 499 Block 2-C (lines ) FCC Registration & Contact Line 219, Filer 499 ID (repeat of Line 101) Line 220, Legal name of filer (repeat of Line 102) Line 221, Chief Executive Officer (or highest ranking company officer) 92

49 FCC Form 499 Line 222, Business address of individual named on Line 221 Check if same as Line 109 Line 223, Second ranking company officer, such as Chairman Line 224, Business address of individual on Line 223 Check if same as Line 109 Line 225, Third ranking company officer, such as President or Secretary (don t list same names as those on Lines 221 or 223) 93 FCC Form 499 Line 226, Business address of individual on Line 225 Check if same as Line 109 Line 227, Jurisdictions you provide service in the past 15 months and jurisdictions service is likely to be provided in next 12 months Line 228, Year and month filer first provided or expects to provide telecommunications in the U.S. Check if prior to 1/1/1999, otherwise provide year and month. 94

50 FCC Form 499 Block 3 (lines ) Carrier s Carrier Revenue What is a Carrier s carrier? Revenues from services provided for resale to other carriers that are contributors to FUSF Revenues from carriers billed for using your facilities Bill their own customers Report its revenues on their 499 in Block 4 Calendar year revenues Non-contributors must be treated as end user 95 FCC Form 499 Other requirements for Block 3 Latest update: lines 304,306, 307,308, and 309 excluded in this annual process. Lines 303, 305, must: Retain Filer ID and contact information for the associated carriers Verify each carrier is a direct contributor to FUSF for that calendar year Print and keep information on FCC website to validate reseller contributor status Have documented procedures 96

51 FCC Form 499 Other requirements for Block 3 Other requirements for Block 3 Verify that customer is purchasing service for resale as telecommunications Annual certification under penalty of perjury using text from instructions Keep records to support verification Non-compliance to these requirements may require additional universal service assessments if carrier reclassified as end user. 97 FCC Form 499 Line 301, Filer 499 ID (repeat of Line 101) Line 302, Legal name of filer (repeat of Line 102) Fixed Local Service Line 303.1, Provided as unbundled network elements (UNEs) Line 303.2, Provided under tariffs or other arrangements Use interconnected VoIP safe harbor 98

52 FCC Form 499 Fixed Local Service Monthly service Local calling Connection charges Vertical features Other local exchange service» Subscriber Line Charge (SLC or EUCL)» Primary Interexchange Carrier Charge (PICC) charges to IXCs Local directory assistance LNP surcharges (considered interstate revenues) 99 FCC Form 499 Per-minute charges for originating or terminating calls Include originating or terminating VoIP-PSTN traffic Line 304.1, Provided under state or federal access tariff Carrier Access Switched Billing (CABs) NECA EC-1050 switched earned interstate revenues reported on Line 14 or AS1000 Line 17 Line 304.2, Provided as UNE or under other arrangements Reciprocal compensation (do not deduct compensation paid to wireless carrier) 100

53 FCC Form 499 Local private line and special access service Line 305.1, Provided to other contributors for resale as telecommunications Carrier Special Access Billing (CABs) billed to carrier s not end users NECA EC-1050 SP earned interstate carrier revenues reported on Line 22 A) or AS1000 Line 20 A) for carriers not ISP Line 305.2, Local private line special access service provided to other contributors for resale as interconnected VoIP 101 FCC Form 499 Line 306, Payphone compensation from toll carriers Compensation from Atlantax Systems National Payphone Clearinghouse Billing Concepts Use ratio of interstate toll billings to intrastate toll or access revenues to split out estimated interstate compensation for a good faith estimate of interstate revenues. 102

54 FCC Form 499 Line 307, Other local telecommunications service revenues. Include collocation revenues pursuant to 47 U.S.C. 251 (c) (6) Line 308, Universal service support revenues received from federal or state sources. Exclude NECA settlements. Interstate universal service support includes High Cost Loop (on NECA Disbursement Notification or USAC Correspondence) Safety Net Additive (on NECA Disbursement Notification or USAC Correspondence) 103 FCC Form 499 Interstate universal service support includes: (cont.) Safety Valve Support (NECA Disbursement Notification or USAC Correspondence) CAF Support (EC-3060-L Page 1 of 3 or AS3060-L Page 1 of 6 or EC1205). CAF is state and interstate Interstate Common Line Support (EC-3060-L Page 1 of 3 or AS3060-L Page 1 of 6 or EC1205) Lifeline and Link Up Charges (Form 497). All reported as interstate revenues on this line Exclude charges or credits for subsidized services to schools, libraries, and rural health care providers. These are end user revenues. Intrastate universal service support and/or lifeline support 104

55 FCC Form 499 Mobile services (including wireless telephone, paging & messaging, and other mobile services) Line 309, Monthly, activation, and message charges except toll services Use safe harbor percentage or submitted traffic study for all line 309 Toll services Line 310, Operator and toll calls with alternative billing arrangements Credit card Collect International call-back 105 FCC Form 499 Line 311, Ordinary long distance Direct dialed MTS Customer toll-free service calls Associated monthly account maintenance PICC pass-through Other switched services not reported above 106

56 FCC Form 499 Line 312, Long distance private line services Line 313, Satellite services Line 314, All other long distance services Line 315, Total revenues provided for resale (Lines ) The total of the 300 lines are line 115 for the Form 499-Q 107 FCC Form 499 Many companies use payable accounts to record NECA reported revenues, instead of revenue accounts Payable to NECA pool You will need to separate the settlements from what is reported if this is booked to the same account Need to know what the support dollars are buried in settlements-can use EC3060 or AS

57 FCC Form 499 Block 4A (lines ) End User & Non- Telecom Revenue End users are customers that use the services provided by your company. ISP is considered end user for any transmission carrying internet Non-telecom revenues are other than U.S. telecommunications revenues Voice mail Inside wire revenues Published directory revenues Internet revenues Dark Fiber 109 FCC Form 499 Non-telecom revenues (cont.) Billing and collection revenues Late payment charges Pole rental Returned check charges Phones and accessories Line 401, Filer 499 ID (repeat of Line 101) Line 402, Legal name of filer (repeat of Line 102) 110

58 FCC Form 499 Line 403, Surcharges or other amounts on bills identified as recovering state or federal universal service contributions For NECA companies revenue on EC-1050, Line 3.C).2. or AS1000, Line 5 B) For all other companies this could be the revenue collected from the end users called USF charges. There are rules to follow if you do this Do not apply safe harbor percentages State universal service program payments recovered by passthrough charges itemized on customer bills ISPs that bill USF Cost Recovery report on this line unless it is labeled Federal Cost Recovery then it goes with revenues assessed on 111 FCC Form 499 Fixed Local Services for Lines thru Monthly service Local calling Connection charges Vertical features (custom calling features) Other local exchange service except for subscriber line and PICC charges Local directory assistance LNP surcharges (considered interstate revenues) 112

59 FCC Form 499 Fixed local services - Traditional circuit switched Line 404.1, Provided at a flat rate including interstate toll service local portion Line 404.2, Provided at a flat rate including interstate toll service toll portion Lines & bundled local service with interstate toll as part of that monthly rate Line 404.3, Monthly local services provided without interstate toll included 113 FCC Form 499 Fixed local services - Interconnected VoIP Line 404.4, Offered in conjunction with a broadband connection Line 404.5, Offered independent of a broadband connection Use interconnected VoIP safe harbor with lines and If you do not use safe harbor for bundled interstate or international toll calling then determine appropriate portion of revenues 114

60 FCC Form 499 Line 405, Tariffed subscriber lines charges, Access Recovery Charges, and PICC charges levied by a local exchange carrier to an end user CLECs that do not have a tariff or price list for these revenues, not reselling such tariffed charges, or do not separately state charges; report nothing NECA EC-1050 SLC revenue on Line 6 or AS1000 Line 8 NECA EC-1050 PIC revenues reported on Line 14 or AS1000 Line 17 or state PIC revenues if you have a Tariff» These Lines also include switched revenues NECA EC-1050 Line Port Charges for ISDN & DS1 revenues on Line 3.C).3 or AS1000 Line 5 C) NECA EC-1050 ARC lines 15 thru 17 or lines 18 thru 20 for AS FCC Form 499 Line 406, Local private line, DSL, & special access service, includes the transmission portion of wireline broadband internet access provided on a common carrier basis (Title II) billed to end user or ISP Common carriers are ILECs and CLECs whether you provide DSL or other transmission under tariff or price list NECA EC-1050 DSL end user and ISP revenues reported on Line 22 B) or AS1000 Line 20 B Ethernet & Multi-Protocol Label Switching go on this line Due diligence to assure special access is or is not interstate Line 407, Payphone coin revenue (local and LD, do not reduce by commissions) Line 408, Other local telecommunications service revenues 116

61 FCC Form 499 Mobile services (including wireless telephony, prepaid wireless, paging & messaging, and other mobile services) Line 409, Monthly, activation charges, and service order charges Line 410, Message charges including roaming, local directory assistance, and air time charges for toll calls Exclude separately stated toll charges 117 FCC Form 499 Revenues on lines 409 and 410 must have a submitted traffic study or use safe harbor. A different traffic study can be used for each of these lines Work with USAC to see if traffic study is acceptable. Safe harbor currently = 37.1% 118

62 FCC Form 499 Toll services (outside of local exchange calling areas) Line 411, Prepaid calling card (card sales to end users, distributors, and/or retail establishments) Report at face value of cards Prepaid card revenues recognized when end user purchases card Includes prepaid service where customer uses the service provider s switching platform and personal identification number Line 412, International calls that both originate and terminate in foreign points 119 FCC Form 499 Line 413, Operator and toll calls with alternative billing arrangements other than revenues reported on Line 412 Credit card Collect International call back Long distance directory assistance Include calls placed from coin, coinless, prison telephones 120

63 FCC Form 499 Line 414.1, All, other than interconnected VoIP, including, but not limited to itemized toll on wireline and wireless bills No safe harbor or traffic studies Line 414.2, All interconnected VoIP long distance, including, but not limited to, itemized toll Use safe harbor 121 FCC Form 499 Lines and include toll calls placed for a fee, flat monthly charges, and monthly minimums. Report toll bundles and split bundles based on minutes behind bundles.» Intrastate» Interstate» International Toll bundles packaged with basic service goes on lines

64 FCC Form 499 Line 415, Long distance private line services for services extending beyond basic service area, frame relay using dedicated services Line 416, Satellite services Line 417, All other long distance services like toll teleconferencing, frame relay using the toll network Lines , are Line 116 on Form 499- Q 123 FCC Form 499 Line 418, Revenues other than U.S. telecommunications revenues, including: Information services Inside wiring maintenance and installation Billing and collection Customer premises equipment (cell phones) Published directory Pole attachment Late payment charges Returned check charges Voice Mail 124

65 FCC Form 499 Dark fiber not part of a UNE or telecommunications service Internet access Cable TV program transmission Foreign carrier operations Non-telecommunications revenues Non-Common Carrier wireline broadband internet access and cable modem service (provided cable modem service is being provided by an entity already filing an FCC Form 499-A). Price cap carriers (Title 1) offering DSL under contract 125 FCC Form 499 Line 418.1, Bundled with circuit switched local exchange service Line 418.2, Bundled with interconnected VoIP local exchange service Line 418.3, Other revenues not bundled Line 418.4, Non-interconnected VoIP revenues not included in any other category Line 418 is Line 117 on Form 499-Q 126

66 FCC Form 499 Bundle Safe Harbors Two safe harbor methods for allocating bundle packages with telecommunications and CPE/enhanced services:» Report revenues based on all unbundled service offering prices & no discount allocated to telecommunications» Treat all bundled revenues as telecommunications revenues and nothing reported in line FCC Form 499 Source of Revenues for Class B carriers using USOA Basic area revenues on line 404 = Account 5001 Miscellaneous revenues for the incidental revenues on lines 403, 404, 406, 408 & 418 = Account 5200 Local network service revenues and local private line = Account 5000 End user special access line 406 = Account 5084 Tariffed SLC & PIC on line 405 = Account 5081 & 5082 These can be the same Part 32 account numbers for some 300 lines 128

67 FCC Form 499 Source of Revenues for Class B carriers using USOA Monthly mobile and message charges on lines 409 or 410 = Accounts 5000 and/or 5004 Toll services on lines 411 thru 417 = Account 5100 Directory revenues = Account 5200 Uncollectible revenues on lines 421 & 422 = Accounts 5300 and/or 5301 Payphone coin revenues on line 407 = Accounts 5280 and/or 7990 These can be the same Part 32 account numbers for some 300 lines 129 FCC Form 499 Companies use varying sub-accounts for further breakdown for Form 499 reporting by carrier or end user NECA companies can use payable accounts to record revenues reported to NECA and revenue accounts to record NECA settlements Ensures that NECA settlements are not reported to USAC 130

68 FCC Form 499 Block 4B (lines ) Total Revenue & Uncollectible Line 419, Gross billed revenues from all sources including reseller and non-telecom Lines 303 thru 314 plus Lines 403 through 418 Line 419 is line 118 on the Form 499-Q Line 420, Gross universal service contribution base amounts Lines 403 thru 411, Lines 413 thru FCC Form 499 Line 421, Uncollectible revenue/bad debt expense associated with gross billed revenue amounts shown on Line 419 Line 422, Uncollectible revenue/bad debt expense associated with universal service contribution base amounts shown on Line 420 Lines 421 and 422 include collected written off uncollectible and write-off recoveries Line 423, Net universal service contribution base revenues Line 420 minus Line 422 Line 423 are lines 119 & 120 of the Form 499-Q 132

69 FCC Form 499 Block 5 (lines ) Additional Revenue Breakouts Line 501, Filer 499 ID (repeat of Line 101) Line 502, Legal name of filer (repeat of Line 102) Lines 503 thru 510, Percent of revenues by each region of the country for Block 3, Carrier s Carrier and Block 4, End-User Telecom Customer billing addresses may be used to calculate or estimate» Line 510 must add to 100% 133 FCC Form 499 Line 511, Include revenue from resellers that do not contribute to Universal Service support mechanisms reported in Block 4-B, Line 420. Keep records of each customer with revenues reported on Line 511 Line 512, Gross TRS contribution base amounts (lines 403 thru 417 plus less line 511) Line 513, Uncollectible revenue associated with TRS base amounts on line 512 Line 514, Net TRS Contribution base revenues (line 512 less line 513) 134

70 FCC Form 499 Block 6 (lines Certification) Line 601, Filer 499 ID (repeat of Line 101) Line 602, Legal name of filer (repeat of Line 102) Line 603, Mark the box for Universal Service, TRS, NANPA, LNPA Administration if entity is exempt from contributing to those funds Line 604, Indicate whether the exempt entity is state or local government entity or Internal Revenue Code (I.R.C.) 501 Tax Exempt 135 FCC Form 499 Line 605, Certify that revenue data is privileged and confidential and that public disclosure would likely cause substantial harm to the competitive position of the company Those that certify will have to support this position in the case of a Freedom of Information Act request Line 606, Signature of officer Line 607, Printed name of officer Electronic signature is the equivalent to a handwritten signature. Line 608, Position with reporting entity Line 609, Business telephone number of officer 136

71 FCC Form 499 Line 610, of officer (required if available) If a general address, officer may not be able to go online and certify Line 611, Date filed Line 612, Check applicable box Original April 1st filing New filer registration Revised filing with updated registration Revised filing with updated revenue data 137 FCC Form 499 Common Errors/Omissions If you do not provide the information requested on every line, the Commission may consider you in violation of Commission rules Make sure there is an officer signature in ink on mailed form Enter 0 on the lines that you did not have revenues Do not report negative revenues 138

72 FCC Form 499 Report whole dollars Recover USF contributions in excess of amounts permitted Revise the Form 499 when out-of-period adjustments affect a reported amount by more than 10% Do not report NECA settlement revenues Uncollectibles need to tie back to year end Trial Balance 139 FCC Form 499 Do not send check with the Form 499 Line 403 column (d) / Line 423 column (d) should = average of the last four quarters contribution factors Revise Form 499-A if changes are made to contributor identification, DC agent, FCC registration information, error in revenue, and/or you are no longer in business or start a new entity within one week Use circuit self-certification when Access Service Order is not used for end user. Have them certify it does not have 10% interstate traffic or carries internet 140

73 FCC Form 499 Traffic Studies & Safe Harbor Traffic studies and safe harbors apply when there is a need to split revenues between state and interstate services Include Filer ID, Name, Holding Company (if applicable) at the top of each page Use same methodology for Form 499-A that was used in Form 499-Q Line 309, 409 & 410 mobile services Lines 303.2, 404.4, & interconnected VoIP 141 FCC Form 499 Safe harbor percentages vary by service; currently: 37.1% for cellular & broadband PCS revenues 12% for paging revenue 1% for analog SMR dispatch revenues 64.9% for interconnected VoIP telecommunications revenues 142

74 FCC Form 499 Reporting carrier makes an election to use a traffic study or safe harbor with each filing 499A must include revenues as reported in 499Qs Traffic study, if used, must be submitted with each 499Q No support is required at the time of filing Sent to FCC and USAC Subject to FCC OIG audit» Maintain all supporting documentation & data 143 FCC Form 499 Traffic study documentation Explanation of sampling and estimation methods used Explanation of why the study is an unbiased estimate of the interstate and international (if applicable) traffic Wireless traffic studies should include all types of minutes used to provision the wireless plan 144

75 FCC Form 499 Traffic study data Minutes of use can come from multiple sources Underlying carrier for resale Customer calling records Switch data Minutes of use should be actual, not just a representative period Summarize by month and quarter Traffic study data can also be used as a good faith estimate for local bundled service 145 FCC Form 499 Late Payment Fees Interest is the > of: $100 or; Prime Rate (on delinquent date) + 3.5% from the date filing was due Administrative charges for collection and/or penalties permitted by law Additional 6% annual interest on debt remaining 90 days after delinquent Fees based on date a payment was received * Report and Order FCC FCC Rcd

76 FCC Form 499 Record Retention FCC currently requires that all records be retained 5 years including those of consultants working on your behalf De Minimis Worksheet Form 499 and supporting work papers See USAC Audit section Traffic Studies 147 FCC Form 499 Federal Universal Service Charge (FUSC) FUSC is paid for by all telecommunications companies that provide interstate and international telecommunications services Except de minimis carriers FUSC is assessed on all interstate and international end user revenues 148

77 FCC Form 499 FUSC can, not must, be passed on to customers The FCC does not dictate the manner in which carriers may recover their universal services costs from interstate or international subscribers. Title 47 CFR, Part 54, Section FUSC must be a separate billed line-item Flat amount or a percentage Not assessed on Lifeline or Link Up participants for subsidized services Must not exceed the current contribution factor Not assessed on exempt military 149 FCC Form 499 Variances for wireless carriers Commercial Mobile Radio Services (CMRS) providers may recover universal service contributions through rates charged for all services Contribution factor * traffic study interstate factor * total telecommunications revenue on Lines 409 & 410 Contribution factor * safe harbor * total telecommunications revenue on Lines 409 & 410 FCC DA Monthly contributions due to USAC by the 15th. 150

78 FCC Form 499 USAC submits quarterly filings to the FCC that project support requirements for: High Cost Support Low Income Support Rural Healthcare Schools & Libraries USAC also submits estimates of interstate and international projected revenues based on 499Qs FCC calculates quarterly contribution factor 151 FCC Form 499 Customer notification of FUSC increases FCC rules do not specify that 30 day advance notice is required for non-dominant carriers 47 CFR, Part does require some form of advance customer notification Written notification Personal contact Advertising in newspapers of general circulation 152

79 References =full Late Payment Penalties DSL as Interstate Wireless Cost Recovery Clarification Current USF Contribution Factor To subscribe to the FCC s Daily Digest FCC Contacts Fred Theobald (202)

80 NECA Monthly Reporting Revenue Distribution Agreement Form EC-1050-I or AS1000-I Cost companies (CC) Average Schedule companies have different reporting requirements (AS) Data must be updated and corrected for up to 24 months. Tie EC 2060-L or AS 2060-L to General Ledger or billing records. Maintain backup data to verify accuracy. 155

81 EC-1050-I or AS1000-I Inputs Line 1A, Interstate Access Minutes (include VoIP) Source: CABS minutes by jurisdiction for originating and terminating, excludes transiting minutes Line 1B, Intrastate Terminating Local Switching Minutes (exclude VoIP) Line 1C, Intrastate Terminating Local Switching Minutes (VoIP only) 156 EC-1050-I or AS1000-I Inputs Line 2A, Access lines in service for CC and Settlement Access Lines for AS A) 1) Residential include employee concession A) 2) single-line business Line 2B), Access lines in service for CC and Settlement Access Lines for AS Multi-line business Source: Billing Journal (Units by type refer to NECA s Access Line Count Guide) 157

82 EC-1050-I or AS1000-I Inputs Line 3, Common Line Earned Revenues for CC or Line 5, Other CL Charges for AS C)1) Special Access Surcharge for CC or A) for AS. Source: CABS facility access service bill. C)2) Federal Universal Service Charge for CC or B) for AS Source: End User Billing & Carriers that do not contribute C)3) Line Port Charges: ISDN Lines, DS1 Channel Service if customer channelizes DS1 for CC or C) for AS Source: End User Billing 158 EC-1050-I or AS1000-I Inputs Line 4, Other Common Line (CL) Charges Realized Uncollectible Revenue for CC or line 6 for AS Source: End User Billing for write-offs or recovery Line 5, Other CL Net Earned Revenue for CC or line 7 for AS Source: Line 3 C) Line 4 for CC or Line 5 + Line 11 Line 6 for AS Line 6, End User (EU) Earned Revenue for CC or Line 8 for AS Source: End user billing includes recurring and partial month billing A) Residential & single-line business B) Multi-line business 159

83 EC-1050-I or AS1000-I Inputs Line 7, EU Net Realized Uncollectible Revenue for Cost Company (CC) or Line 9 for Average Schedule (AS) Source: End User Billing and write-offs or recoveries Line 8, EU Earned Revenue for CC or line 10 for AS Source : Line 6 Line 7 for CC or Line 8-Line 9 for AS 160 EC-1050-I or AS1000-I Inputs Line 9, CL Expenses & Other Taxes (A + B) A) CL EOT Amount Source: Cost Study Part 69 Expense Summary Total EOT assigned to CL Acct EOT B) Universal Service Contribution Reimbursement will match EC 1050 line 3 C) 2 This is line 12 for AS and it matches AS1000 line 5 B). 161

84 EC-1050-I or AS1000-I Inputs Line 10, CL Average Net Investment Source: Cost Study Part 69 Revenue Requirement Summary Rate Base assigned to Common Line Line 11, CL Income from AFUDC Source: Cost Study Part 69 Revenue Requirement Summary AFUDC assigned to Common Line 162 EC-1050-I or AS1000-I Inputs Line 12, CL Income Adjustment for FIT Source: Cost Study Part 69 Revenue Requirement Summary FIT Adds/Deducts assigned to Common Line Line 13, CL FIT Tax Credit Source: Cost Study Part 69 Income Tax Analysis 163

85 EC-1050-I or AS1000-I Inputs Line 14, Switched Access (SW) Earned Revenue for CC or Line 17 for AS Sources: CABS Connecting company statements Revenue sharing statements End User Billing for PICs Billing, Name, and Address (BNA) 164 EC-1050-I or AS1000-I Inputs Line 15 for CC or line 18 for AS, ARC residential line revenue excludes lifeline Line 16 for CC or line 19 for AS, ARC single- line business revenue Line 17 for CC or line 20 for AS, ARC multi- line business revenue This applies to those Companies in Tariff 5 to recover the Access Recovery Charge (ARC). Source is end user billing, includes recurring and partial month charges 165

86 EC-1050-I or AS1000-I Inputs Intrastate Terminating Access Line 18 A) for CC and line 21 A) for AS Billed intrastate terminating switched access end office and transport. Includes direct trunks If CCL originating 800 minutes are billed at terminating rate Companies in state pool, the amount of contribution (negative or positive) associated with terminating intrastate switched traffic Excludes VoIP 166 EC-1050-I or AS1000-I Inputs Reciprocal Compensation and State Terminating Access Support Rebalancing Funds Line 18 B) for CC and line 21 B) for AS Net revenues from interconnection agreements Reciprocal compensation revenue from CMRS and CLEC carriers, net of reciprocal compensation expense paid to these carriers Intrastate terminating access revenue from a state fund designed to offset changes in rates and revenues associated with intrastate access billed to interexchange carriers 167

87 EC-1050-I or AS1000-I Inputs Intrastate VoIP Terminating Revenue Line 18 C) for CC and line 21 C) for AS Revenues based on intrastate terminating VoIP minutes rated at the lower of the intrastate and interstate rate Line 19, SW Net Realized Uncollectible for CC or Line 22 for AS Sources: Work papers showing you attempted to collect Bankruptcy work papers End User Billing for ARC & PIC write-offs and recoveries 168 EC-1050-I or AS1000-I Inputs Line 20, SW Net Earned Revenue for CC or Line 23 for AS Are the totals from entered data Line 21, SW Expenses & Other Taxes for CC, effective July 1, 2012, pre-populated with data due to FCC mandated traffic sensitive switched access freeze, reduced by 5% each year 169

88 EC-1050-I or AS1000-I Inputs Switched Intrastate Terminating Access & Reciprocal Compensation Revenue Requirement Line 22 for CC and line 24 for AS Frozen baseline intrastate revenue requirement from the CAF/ICC data collection, pre-populated with data, reduced by 5% each year 170 EC-1050-I or AS1000-I Inputs Line 23, SW Average Net Investment, Line 24, SW Income From AFUDC, Line 25, SW Income Adjustment for FIT, and Line 26, SW FIT Tax Credit pre-populated with data due to FCC mandated traffic sensitive switched access freeze, reduced by 5% each year 171

89 EC-1050-I or AS1000-I Inputs Special Access (SP) Earned Revenue (excludes DSL & Fixed Rate Option Line 27A) for CC and Line 25A) for AS Source: End User Billing for end user special access CABS facility access service bill Includes DSL Access Service Connection Charges, ATM- CRS Port, and Ethernet Port Charges Remember Internet Service Provider is considered the Company s end user 172 EC-1050-I or AS1000-I Inputs Line 27 for CC or Line 25 for AS B)1) DSL Earned Rev-Data Only-monthly charges B)2) DSL Earned Rev-Voice Data-monthly charges & WPP Term monthly charge Source: ISP invoice that includes DSL line charges, DSL WPP Term Plans. C) 1) DSL Line Counts-Data Only C) 2) DSL Line Counts-Voice-Data Source: ISP invoice. Remember discounts starting at 500 lines for C) 1 & C 2) combined D) SP Fixed Rate Option (FRO) Rev 173

90 EC-1050-I or AS1000-I Inputs Line 28, SP Net Realized Uncollectible Revenue for CC or Line 26 for AS Sources: Work papers showing you attempted to collect Bankruptcy work papers End User billing for write-offs and recoveries Line 29, SP Net Earned Revenue for CC or Line 27 for AS Source: Line 27 Line 28 for CC or Line 25-Line 26 for AS 174 EC-1050-I or AS1000-I Inputs Line 30, SP Expenses & Other Taxes Source: Cost Study Part 69 Revenue Requirement Summary EOT assigned to Special Access Line 31, SP Average Net Investment Source: Cost Study Part 69 Revenue Requirement Summary Rate Base assigned to Special Access 175

91 EC-1050-I or AS1000-I Inputs Line 32, SP Income from AFUDC Source: Cost Study Part 69 Revenue Requirement Summary AFUDC assigned to Special Access Line 33, SP Income Adjustment for FIT Source: Cost Study Part 69 Revenue Requirement Summary Income Adds/Deducts assigned to Special Access Line 34, SP FIT Tax Credit Source: Cost Study Part 69 Income Tax Analysis 176 EC-1050-I or AS1000-I Inputs TS SW Other- Line 35 for CC or Line 32 for AS Covers reported incremental amounts for surcharges/fees through CAF data request collection Telecommunications Relay Surcharge Federal Regulatory Fees North American Numbering Plan Administration 177

92 USAC Line Counts USAC Line Counts Forecast Line Counts Due around February 20th to NECA Purposes Collect study area data to set rates from July 1 to June 30 USAC uses data to compute ICLS 179

93 USAC Line Counts Report historical and projected lines for three successive September 30th Prior Year Current Year Following Year Reported in Customer Premises Terminations (CPTs) A line termination at a customers premises EUCL charged Reference NECA Loop Count Guide

94 USAC Line Counts Types of lines to be reported Residential Customer Premises Terminations (CPTs) Include employee concession lines Exclude Centrex ISDN Lifeline Lifeline CPTs 182 USAC Line Counts Types of lines to be reported (cont.) Single Line Business CPTs Exclude Integrated Services Digital Network (ISDN) Service Multi-line Business CPTs Exclude Payphone Lines Centrex ISDN arrangements DS1 channel service arrangements Official company lines 183

95 USAC Line Counts Centrex CPTs Residence Dormitory Centrex business CPTs Total Payphone Lines Payphone Lines assessed FUSC Basic Rate Interface ISDN Primary Rate Interface ISDN 5 access lines per arrangement, report by number of arrangements 184 USAC Line Counts DS1 Channel Lines 5 access lines per arrangement, report by number of arrangements Special access surcharge channels reported in Special Access Surcharge Channels section EC-1050-I, Line 3.C)1) for Cost Company or AS1000-I, Line 5 A) for Average Schedule $ / 25 = Voice Grade Equivalents Unbundled Network Element Loops (Average Schedule Companies only) Source for all line counts is the End User Billing Report 185

96 USAC Line Counts Interstate Common Line Support (ICLS) Line Count Data (FCC Form 507) Line counts used to calculate per line USF support All rate-of-return carriers not affiliated with a price cap company must file 12/31 line counts by July 31st along with the 507 certification form Quarterly data is voluntary as of January 1, 2012 Disaggregation rules deleted. Submit totals for each item reported 1.3 loop count data only submitted for USF HCL data submissions 186 USAC Line Counts Types of lines to be reported Total Residential Customer Premises Terminations (CPTs), including: Centrex ISDN Employee concession lines Lifeline Total Single Line Business CPTs, including ISDN BRI 187

97 USAC Line Counts Types of lines to be reported Total Multi-line Business CPTs, including: Payphone lines ISDN» 5 lines for each PRI arrangement Centrex DS1 Channel Arrangements (5 lines if customer channelizes) Excludes official company lines 188

98 Customer Proprietary Network Information (CPNI) & Red Flags CPNI

99 CPNI 47 U.S.C. 222 Basic Rule of CPNI: Telecommunications carriers cannot use, disclose, or permit access to individually-identifiable information obtained from customers without customer consent, unless an exception applies Carriers collect sensitive personal information including to whom, where, and when their customers call 191 Carriers Subject to CPNI rules Local exchange carriers (ILECs & CLECs) Interexchange carriers Wireless providers (like T-Mobile or Verizon Wireless) Interconnected VoIP providers Paging providers Resellers Prepaid telecommunications Calling card providers 192

100 What is CPNI? Account Information Account number Telephone number Services purchased Custom calling features Bundled plans Long distance PIC Account balance All info available to the carrier only through the carrier-customer relationship 193 What is CPNI? Call Detail Information Information pertaining to the transmission of calls Number called outbound calls Number from which call was placed inbound calls Time of call Location of the called or calling number Duration of call Frequency of calls 194

101 What is Not CPNI? Subscriber list information = directory information Billing name and address (BNA) Information from public sources (e.g., post office, Google) Information not obtained from the customer through the customer/carrier relationship 195 Safeguarding CPNI Take reasonable measures to discover and protect against unauthorized access Authenticate customer prior to disclosing CPNI Customer-initiated telephone call Online account access In-store visit require valid photo ID Authenticate without the use of readily available biographical information SS#, mother s maiden name, home address, DOB 196

102 Safeguarding CPNI Notification of Account Changes Immediate notification required: Password is created or changed Back-up question is created or changed Online account is created or changed Address of record Notification can be carrier-originated voic or text message to telephone number of record or mailed to address of record Notification must not reveal the changed information Not required at service initiation 197 Safeguarding CPNI Carriers must guard against pretexting, which is Pretending to be a customer to gain proprietary information Techniques used to obtain unauthorized access to customer information Protect database from hackers and other unauthorized access FCC outlines a General Duty to protect Burden of proof will fall on the carrier Maintain documentation of procedures 198

103 CPNI Breaches Carrier determines that a person without or exceeding authorization has intentionally: Gained access to CPNI Used CPNI Disclosed CPNI Notify United States Secret Service & Federal Bureau of Investigation Within 7 days of determination of breach Notify FCC at CPNI Breaches Customer notification after consulting named agencies After full 7 business days have passed after law enforcement notification Notify customers after consultation with relevant agencies Records of breaches must be maintained for 2 years minimum Dates of discovery and notification Detailed description of CPNI breach Circumstance of breach 200

104 Personnel Policies Acknowledgement of policies by all staff with access to CPNI CPNI training Annual meeting to go over CPNI or have every employee read policy annually. FCC does not have a preference. New employees must read and acknowledge policy Employee discipline procedures CPNI Compliance Officer responsibilities Supervision and review of CPNI releases Staff training & counseling Implement locks and shredders 201 Annual Certification to FCC Officer must affirmatively state personal knowledge of operating procedures Provide written statement on how operating procedures ensure compliance Affirmatively state whether any actions with data brokers or unauthorized release of CPNI took place Must be filed with the FCC each year by March 1 Officer must sign compliance certificate File by web application, Electronic Comment Filing System, or filing paper copies 202

105 CPNI Consent Options 1. No consent required Carrier and affiliate marketing of communications services using a total services approach Permitted to share among affiliates that provide service Carriers may market products and services within each of these categories as follows: Local voice and all related services and Customer-Provided Equipment (CPE) Long distance and all related services and CPE Wireless and all related services and CPE DSL and all related services and CPE Wireless broadband and all related services and CPE 203 CPNI Consent Options 2. Opt-out Affiliate marketing of communications services Specific requirements of what must be included in electronic or written method Notices provided every 2 years in writing or electronic 30 day minimum waiting period No cost to customer Deemed to have consent if customer fails to object within waiting period 204

106 CPNI Consent Options 3. Opt-in Affiliate or 3rd party marketing Specific requirements of what must be included Customer affirmatively expresses consent in oral (remember burden of proof) written, or electronic method for at least one year Valid until customer revokes or limits such approval or denial 205 Non-CPNI Based Marketing Newsletter or mass mailings Mailing to addresses of non-subscribers Up sell in the processing of taking service order Sales efforts from a customer inquiry if customer agrees Generalized promotions to all customers 206

107 FCC Enforcement Action Failure to comply with CPNI rules, including annual certification may include monetary forfeitures of up to $150,000 for each violation or each day of a continuing violation, up to a maximum of $1,500,000 False statements to the FCC may result by fine or imprisonment 207

108 Red Flags Red Flag Rules In effect since January 1, Not enforced until December 31, Federal Trade Commission adopted final rules for Section 114 of the Fair & Accurate Credit Transactions Act of 2003, also known as Red Flag Rules. Designed to prevent identity theft and apply to all Financial Institutions and Creditors with covered accounts. 209

109 Financial Institution Definition A state or national bank A state or federal savings and loan association A mutual savings bank A state or federal credit union Any other person that directly or indirectly holds a transaction account belonging to a customer such as utility companies and telecommunications companies 210 Creditor Definition A company that regularly bills customers after services are provided Any person who regularly arranges or extends, renews, or continues credit Any assignee of an original creditor who participates in the decision to extend, renew, or continue credit 211

110 Covered Account Definition A continuing relationship to obtain a service A consumer account designed to permit multiple payments or transactions, Any other account for which there is a reasonably foreseeable risk from identity theft There may be foreseeable risk of identity theft in connection with accounts accessed remotely through Internet or by telephone 212 New Law On Creditors Effective December 18, 2010, covers creditors who regularly meet one of 3 criteria: Obtain or use consumer reports in connection with credit transaction Furnish information to consumer reporting agencies in connection with credit transaction Advance funds to or on behalf of someone incidental to a service provided by the creditor to that person 213

111 Red Flag Requirements Identify relevant red flags and incorporate them into the Program Detect red flags that are part of the Program Respond appropriately to any red flags that are detected Ensure the Program is updated at least annually to address changing risks Describe how to prevent and spot identity theft in day-to-day operations 214 Administering the Program Obtain approval of the initial Program by the Board of Directors, senior management, or appropriate senior- level employee State who will implement and administer and review how staff is complying Train appropriate staff Address how you monitor contractors compliance if you outsource or subcontract parts of operations. Make sure they have a copy of your policy 215

112 Red Flags Program Program must include four basic elements Include reasonable policies and procedures to identify the red flags of identity theft in day-to-day operations Detect relevant red flags. For example; have a procedure to detect fake, forged, or altered IDs Spell out appropriate action Ensure the Program is updated at least annually to address changing risks 216 Appropriate Responses to Red Flags Monitor accounts for evidence of identity theft Contact customer Change passwords Change way to access covered account Close and reopen account with new account number Refuse to open account 217

113 Suspicious Personal Identifying Information SSN does not match birth date (use Social Security Administration s (SSA) issuance tables) SSN is for deceased person or is not issued (use SSA Death Master File) Address does not match credit report Person cannot provide passwords or common forms of identification Person cannot answer a challenge question when you try to authenticate 218 Safeguards Limit employee access to CPNI, social security numbers, credit card numbers, and other personal information Lock paper records and limit who can access Electronically limit and monitor employee access to electronic customer information and database Securely dispose of data you no longer need For new accounts use a credit reporting company or Social Security Number Death Master File 219

114 Penalties FTC can seek monetary penalties ($3,500 maximum civil penalty per violation) Injunctive relief to comply and failure to comply results in further penalties 220

115 FCC FORM 497 FCC Form 497 & FCC Order Changes Lifeline & Linkup Worksheet ETC s non-tribal support will equal $9.25 per month and Link Up support ended April 2012 No More Tiers 1-3 ETC s tribal support up to an additional $25 for tribal land residents ($34.25 maximum) and Link Up covers 100% of the customary charges up to $100 Toll Limitation Service incremental cost study support is capped at the lesser of $2 per lifeline subscriber or actual cost. Nothing paid after January 1,

116 FCC Form 497 & FCC Order Changes Submit Form 497 by the 8 th each month Paid monthly Lifeline service covers dial tone and the subscriber line charge-not data Offer toll restriction at no charge No deposit for lifeline service unless customer does not take toll restriction when they have toll 223 FCC Form 497 & FCC Order Changes Certifications Publicize the availability of Lifeline & Linkup services ( for non-tribal). Designed to reach those eligible for support but not a current lifeline customer Pass through support to customer Received all regulatory approvals necessary Data is true, accurate, and complete USAC s authority to request supporting information Effective April 1, 2012 must be signed by officer 224

117 FCC Form 497 & FCC Order Changes Effective June 1, confirm an applicant s eligibility using one of three methods annually thereafter: Access state or federal social services databases Rely on an agency or administrator (Xerox/Solix) If no access to a database then review documentation and determine eligibility. Keep accurate records on income or qualifying program. Do not retain any consumer documentation De-enroll those that fail to demonstrate eligibility, has more than one lifeline service, does not re-certify annually, fails to use wireless service for 60 days 225 FCC Form 497 Lifeline Basic Service should include: Single Party Service Voice Grade access to the PSTN DTMF or functional equivalent (touch tone) Access to Emergency services Operator services Toll services Directory Assistance Free TLS Lifeline not assessed FUSC, Access Recovery Charge (ARC), & LNP End User charges 226

118 FCC Form 497 Additional Thoughts Advertising must reach eligible customers that are not on the telephone network Maintain supporting documentation, including advertisements, for 3 years All rates and charges must be documented on bill and supported by a tariff or price list The program enforces the one-per-household rule. One landline or one wireless phone but not both at each principal place of residence (fine up to $16,000 for each violation up to $112,500 for single continuing violation) 227 FCC Form 497 Common Audit Findings Failure to provide clear and simple customer bills for lifeline credits so subscriber is unaware of lifeline credits Carrier did not use the correct customer eligibility criteria Failure to submit Form 555 certification by January 1 Re-certification on all its consumers continuing eligibility 228

119 FCC Form 497 Failure to use updated annual verification/certification letter Claiming toll limitation not based on incremental cost study Penalties? Monetary forfeitures of up to $150,000 for each violation or each day of a continuing violation up to a maximum of $1,500,000 False statements or misrepresentations may be punishable by fine or imprisonment 229

120 Truth In Billing Truth-In-Billing Establishes standards for telecommunications bills Applies to all telecommunications common carriers except (a)(2) & (c ) shall not apply to CMRS unless the FCC determines otherwise. Does not preempt state truth-in-billing requirements 231

121 Basic Principles Who is asking the customer to pay for service? What services are customers being asked to pay for? Where can the customer call to get more information about the charges on their bill? 232 Goals Reduce slamming, cramming & other fraud Slamming - changing service or providers without permission Typically an unauthorized PIC change Cramming placing unauthorized, misleading, or deceptive charges on a bill Aid customers in understanding bills Make informed choices on telecommunications services 233

122 Potential Examples of Cramming Charges explained in general terms Service fee / service charge / other fees /etc. Monthly charges without a clear explanation of the service provided Monthly fee / minimum monthly usage fee Charges for an authorized service, but the customer was misled about its cost 234 Bill Requirements Bills must be clearly organized and comply with the following requirements Service provider name associated with each charge Where multiple carriers appear on the same bill, charges must be separated by provider (CMRS exempt) Provide clear and conspicuous notification of any change in service provider Notice that would be apparent to a reasonable customer A new service provider is any provider that did not bill for services on the previous bill 235

123 Descriptions of Billed Charges Brief, clear, non-misleading, plain language description of services Customers must be able to accurately assess Billed services are the same as ordered & received Costs for services conform to their understanding of the price charged Clarity of what is included in bundle 236 Deniable & Non-Deniable Charges Bill must distinguish charges for which nonpayment will result in disconnection of basic local service Carriers may also use other methods of informing customers that they may contest charges prior to payment CMRS is exempt from this section 237

124 Disclosure of Inquiry Contacts Bill must contain clear and conspicuous disclosure of information necessary to inquire about or contest charges on the bill Must include a telephone number May be the number of a billing agent with sufficient information to answer questions & resolve disputes Carriers must make business address available upon customer request 238

125 USAC Audits USAC Audits USAC audits under the direction of the FCC s Office of Inspector General Purpose is twofold Assess compliance w/ FCC Rules Address requirements of the Improper Payment Information Act Waste, fraud, and abuse 240

126 USAC Audits Program was modified beginning in 2011 There are now 2 programs Payment Quality Assurance Program (PQA) Not an audit Beneficiary & Contributor Audit Program Very similar to program from USAC Audits Payment Quality Assurance Program Covers all 4 programs High Cost Low Income Rural Health Care Schools & Libraries Focuses on an individual monthly payment i.e. July HCLS payment 242

127 USAC Audits Payment Quality Assurance Program Measures accuracy of payments Evaluates eligibility or recipients of payments High level testing of information from recipients Scope of procedures are limited in order to: Keep costs down & minimize requirements on beneficiaries Reduce process time Capitalize on documents that USAC already has No on-site visit Not an audit 243 USAC Audits Payment Quality Assurance Program 5 Step Process USAC selects beneficiaries for PQA USAC contacts beneficiaries Request payment documentation Confirm eligibility USAC reviews beneficiary information USAC concludes on the payment USAC submits annual assessment results to FCC 244

128 USAC Audits Payment Quality Assurance Program Typical Documentation Requests Trial Balance corresponding to latest HCLS filing Cost Study work papers associated with latest HCLS filing Loop Count support from internal system Safety Net eligibility worksheet NECA Allocator supporting CL Revenue Requirement SLC Revenue support Trial Balance NECA 24 Month Latest View FCC Form 509 Calculation of CL Revenue Requirement 245 USAC Audits Beneficiary & Contributor Audit Program Formal audit program to evaluate compliance w/ rules Covers all four programs and contributors Audit type and scope based on risk and size of payments Performance audits Agreed upon procedures audits 246

129 USAC Audits Beneficiary & Contributor Audit Program Audits to be spread throughout the year Smooth workload Improve efficiencies Control costs Reduce burden on beneficiaries Maintain pool of trained auditors Reasonable cost in relation to program payment and beneficiary being audited 247 USAC Audits Beneficiary & Contributor Audit Program Benefits (according to USAC) Improved scheduling Company/staff time requirements considered Flexibility to adjust on-site dates USAC engagement lead on each audit Additional USAC visibility More manageable number of audits More planning by auditors Review & use of materials before on-site visit 248

130 USAC Audits Contributor Audits Its all about the 499 and supporting documentation Did you report the revenues in the appropriate block and on the right line? GL not TB detail Do you have documentation to support the revenues reported? Line/customer counts Billing detail Contributor certification Etc. 249 USAC Audits Record Retention FCC Order on Retention (FCC 07-15) adopted on August 29, 2007 Retain records related to disbursements for 5 years from date of disbursement Up to 7 years from record creation Order does not supplant Part 32 rules on CPRs Applies to all agents of the recipient NECA Consultants Auditors Etc. 250

131 USAC Audits Record Retention FCC Order on Retention (FCC 07-15) Records must be made available to: FCC OIG USAC Auditors hired by OIG & USAC Data Supporting & Tying to Filings Line counts Customer records Continuing Property Records Maintenance contracts Any other relevant documentation or records 251

132 Highlights of other reporting forms USAC Schools and Libraries E-Rate Program Program reimburses telecommunications, Internet access, and internal connections providers for discounts on eligible services provided to schools and libraries. USAC ensures that these discounts are passed on to program participants. funded by the interstate and international end user revenues reported on your Company s Form 499. What is your role as the service provider? 253

133 Important E-Rate Documents Form 471 from USAC, Receipt Acknowledgment Letter (RAL) to applicant & service provider Request Item 21 Attachment from applicant covers eligible services. details what rates and charges were submitted Form 486 Notification Letter from USAC. Do not provide discounts without the Form 486 Find out if school or library wants credits on bill or Billed Entity Applicant Reimbursement (BEAR method) 254 Important E-Rate Documents File Annual Certification Form 473 filed by service provider Certify compliance Relates to that funding year Certify invoice will be based on previously submitted bills Certify you keep support for 5 years Needed to get paid 255

134 How to get paid by USAC for E-Rate Invoice USAC Form 474 Service Provider Invoice (SPI) if you give bill credits or Form 472 Billed Entity Applicant Reimbursement (BEAR) for services paid by applicant Received no later than 120 days after last date of service or After date on the Form 486, whichever is later 256 Local Number Portability (LNP) FCC mandated service provider portability Allows end users to switch providers while retaining same number at same location in local area To date this is the only one type of LNP mandated Follow service provider porting intervals and porting standards All carriers, excluding paging carriers are required to port numbers 257

135 Local Number Portability (LNP) The customer can send & receive calls while being transferred 911 may not know location during process New carrier starts process Carriers may assess fees to recover costs A carrier cannot refuse a valid porting request to port if porting charge not paid if customer owes a bill or termination fee 258 Local Number Portability (LNP) Wireless handsets are often incompatible Carrier that wins customer will port from former carrier Interconnection agreement not required Cannot delay or obstruct porting process Not obligated to port disconnected number 259

136 FCC Form 477 Who Must File? Facilities Based Broadband Services Providers Wired or Fixed Wireless Local Exchange Telephone Service Providers Interconnected VOIP Service Providers Facilities Based Commercial Mobile Radio Service Providers offering mobile telephony service When to File? March 1st 12/31 of prior year data September 1st 6/30 of current year data 260 FCC Form 477 Collects information about broadband connections to end user locations Data must be provided at a granular level Report Broadband Service Connections at the Census Tract Level Census tracts are geographic areas within a county Connections must be reported by technology and upload and download speeds Data may be entered manually or a data file uploaded 261

137 FCC Form 477 Common Violations Failing to file on time Failing to have an official certify and not including the officials required contact information What are the penalties? Monetary forfeitures of up to $150,000 for each violation or each day of a continuing violation up to a maximum of $1,500,000 False statements or misrepresentations may be punishable by fine or imprisonment There is no exemption for small companies 262 Federal Rural Health Care Program Program reimburses telecommunications and Internet service providers for services provided to rural health care providers. USAC works with service providers to ensure discounts are passed on to program participants Where can you find more? 263

138 Important Documents for Rural Health Care Funding Commitment Letter Validate SPIN No USAC support without letter Has start & end dates, monthly support HCP Support Schedule (HSS) to determine final credit approved Provide credit next bill cycle or Send check to billed entity based on Billing Account Number 264 How to get paid Invoice USAC monthly using USAC s template. Sign & certify accuracy Get Invoice Status Report for accepted & rejected invoice items Both parties can decide on one lump check at end of funding year USAC not invoiced until HCP gets credit 265

139 Questions? Thank You! 266