Deadline Approaches to End Resale of Lifeline
JSI again reminds clients that effective August 15, 2016, eligible telecommunications carriers (ETCs) that sell Lifeline-discounted services to resellers will no longer be eligible for Lifeline support for those customers. Going forward, ETCs will only receive reimbursement for Lifeline service provided directly to subscribers. The FCC’s Lifeline Order seeks to reduce the risk of reimbursement from the fund by two ETCs, in this case, both the wholesale provider and the reseller. With this decision, the FCC has also effectively eliminated the ability of non-ETC resale providers from providing Lifeline service.
Furthermore, if your company resells Lifeline service, your company must submit the appropriate FCC and state notices and discontinuance filings. For the FCC filing, impacted ETCs should have already provided notice to the resellers and submitted a Section 214 Discontinuance Application to the FCC to discontinue its resale of Lifeline service in order to meet the August 15 deadline. If your company resells Lifeline service and has not made this filing, please contact us immediately if you would like our assistance.
In addition, ETCs are no longer obligated to provide Lifeline-discounted service at resale under Section 251 (c)(4) of the Telecommunications Act. This duty to resell service at a discount is only required of ILECs that have given up their rural exemption, but JSI notes that some rural ILECs also may have entered into resale agreements with carriers offering service at the full tariffed rate. As a result, any ILEC with agreements that include provisions to resell local service, and more specifically Lifeline, should amend these agreements by the August 15 deadline. The FCC did make provisions, if necessary, for an ILEC to file a waiver to request additional time, for good cause shown, if it is unable to amend agreements by the deadline.
If you have any questions or you would like JSI’s assistance with this Lifeline change, please contact Lans Chase in JSI’s Georgia office at 770-569-2105, Lisa McLaughlin in our Texas office at 512-338-0473, or Olivia Hill in Maryland at 301-459-7590.
International Traffic and Revenue Reporting Due July 31
JSI clients are reminded that their International Traffic and Revenue Reporting data as of December 31, 2015, is due on July 31, 2016. All reports must be made in the online system at Section 43.62 Online Filing System.
This reporting deadline applies to your company if:
- It holds a Section 214 international authorization, or
- It is a VoIP provider that provided international VoIP service connected to the PSTN in 2015.
The online filing will provide for the streamlined reporting of pure resellers with international revenue under $5 million for the reporting period, and will eliminate the need to separately file a letter certifying you are under that threshold.
The following information will be required for the online filing:
- FRN and FRN Password of your long distance entity
- 499 Filer ID of long distance entity
- Applicable International Section 214 authorization number(s).
If you have any questions or need assistance, please contact Kim Waldvogel in JSI’s Maryland office at 301-459-7590.