Changes Coming to 2018 Form 481 Reporting Requirements for High-Cost ETCs

USAC recently opened its filing system for FCC Form 481, which is due Monday, July 2, 2018, for all eligible telecommunications carriers (ETCs). USAC also released updated filing instructions, upload templates, and a draft PDF of Form 481, which contains several changes as outlined below. These documents are all in draft form until Paperwork Reduction Act (PRA) approval is obtained. Companies can begin to input data, but they will not be able to certify the filing until the PRA approvals are received.

Although the FCC eliminated several items from this year’s Form 481, one new reporting requirement has been added for a subset of ETCs. RLECs receiving CAF-BLS support that do not have HUBB reporting requirements (Legacy carriers with greater than 80% 10/1 deployment) must report new broadband deployment on Form 481. These carriers must report any new broadband locations deployed since May 26, 2016, broken down by speed tier: 1) at least 10/1 Mbps, but less than 25/3 Mbps; and 2) 25/3 Mbps or higher. In conversations JSI had with FCC staff last year, we confirmed that it was acceptable for RLECs that are already 100% deployed for 10/1 and/or 25/3 to report “zero” for the respective categories for each annual filing.

Reporting requirements eliminated in an Order the FCC released last July no longer appear on the Form 481 for ETCs that receive both high-cost and low-income support:

  1. network outage information for voice;
  2. unfulfilled service requests for voice and broadband;
  3. number of complaints per 1,000 subscribers for voice and broadband services;
  4. voice and broadband service rates; and
  5. the requirement for ETCs to certify compliance with service quality standards.

According to the instructions, this year’s filing also eliminates the need for ETCs to file duplicate copies of Form 481 with the FCC, states, U.S. territories, and/or Tribal governments. The FCC centralized filing of Form 481 so that the FCC and states will have access to the information through an online portal. USAC has not issued any further information confirming that this feature will be activated in time for this year’s filing. JSI will continue to monitor and update clients as developments occur. JSI also reminds ETCs that some state PSCs have their own rules that require ETCs to file certain information contained in the Form 481.

If you have questions regarding these changes or need assistance with the 2018 Form 481 filing, please contact Cassandra Heyne in JSI’s Maryland office at 301-459-7590 or Lans Chase in JSI’s Georgia office at 770-569-2105.