Upcoming 2023 Regulatory Compliance Deadlines

As we begin the new year, clients should prepare for several upcoming filing and compliance deadlines in the weeks ahead.

These deadlines include the annual Hearing Aid Compatibility Certification (FCC Form 855), the annual Lifeline Eligible Telecommunications Carrier Certification (FCC Form 555), the semi-annual Carrier Identification Code (CIC) Entity Access and Usage reports, the annual High Cost Universal Broadband (HUBB) filing, the semi-annual Broadband Data Collection (BDC) filing/FCC Form 477, the annual Customer Proprietary Network Information (CPNI) Certification, and the semi-annual Cable Copyright Statement of Account.

Further, carriers receiving universal service funds with buildout obligations are reminded of their upcoming quarterly broadband testing requirement. Clients should also pay special attention to changes concerning FCC Form 477 and the related BDC filing.

The details for these deadlines are as follows:

January 31 – FCC Form 855: Wireless service providers must complete the annual Hearing Aid Compatibility Certification (FCC Form 855), certifying their compliance with the FCC’s wireless hearing aid compatibility requirements during the reporting period from January 1 through December 31, 2022. The form is currently available for completion and submission. The filing window closes on January 31, 2023, at 12:00 am (EST).

January 31 – FCC Form 555: The annual Lifeline Eligible Telecommunications Carrier Certification (FCC Form 555) is due on January 31, 2023, and it must be filed and certified online through the Universal Service Administrative Company’s (USAC’s) E-File system. In addition, a copy of the certified form must be filed with FCC and relevant state commissions.

January 31 – CIC Entity Access and Usage Reports: The semi-annual CIC Entity Access and Usage Reports covering the period from July 1 through December 31, 2022, are due to the North American Numbering Plan Administration (NANPA) CIC Administrator by January 31, 2023.

March 1 – HUBB Filing: All rate-of-return carriers and recipients of federal high-cost funding must submit geo-located broadband information into USAC’s HUBB portal for locations made available in 2022. Carriers that did not deploy any locations in 2022 must still log into the HUBB and certify “no locations to upload.”

March 1 – BDC Filing and Form 477: In December 2022, the FCC issued an order to sunset specific requirements of FCC Form 477. Beginning with the March 1, 2023 BDC filing for data as of December 31, 2022, providers will no longer be required to submit broadband deployment data through Form 477. Instead, providers will report location-based broadband availability data through the BDC system.

Providers will continue to submit the subscription data required under Form 477; however, the BDC system, rather than the Form 477 filing platform, will be used to submit both the subscription data collected for Form 477 and the availability data collected for the BDC.
Providers must submit the following data using the BDC filing system:

• Fixed and mobile broadband and voice Form 477 subscription data;
• Fixed and mobile BDC broadband location-specific availability data; and
• BDC mobile voice availability data.

The Form 477 filing system will no longer be used to collect new Form 477 submissions and will remain open only for filers to make corrections to existing Form 477 filings for data as of June 30, 2022, and earlier.

March 1 – CPNI Certifications: All telecommunications carriers and Voice over Internet Protocol (VoIP) providers must file their annual CPNI certifications – confirming their compliance with the FCC’s rules protecting customer proprietary network information during the 2022 calendar year – by March 1, 2023.

March 1 – Cable Copyright Statements of Account: Cable/video providers must submit their Cable Copyright Statements of Account for the accounting period from July 1 through December 31, 2022, to the Library of Congress Copyright Office by March 1, 2023.

First Quarter of 2023 – FCC’s Performance Measures Testing: As part of the FCC’s performance measures testing framework, all CAF-BLS, A-CAM II, and CAF Phase II Auction recipients must conduct their first official broadband test in the first quarter of 2023. A-CAM I, Alaska Plan, and Rural Broadband Experiment recipients are also reminded of their obligation to conduct tests in the first quarter. While RDOF recipients will eventually have to conduct testing, the FCC has yet to establish the date by which they must begin pre-testing.

If you have any questions concerning any of the deadlines discussed above, then you can connect with a member of our team by simply clicking the “Connect with Us” button below or by calling 301-459-7590.

In addition, JSI can help your company to avoid missing these and other critical regulatory filing deadlines – and, in the process, avoid unnecessary government enforcement actions and fines – with TrackNow:

• TrackNow is a new, web-based regulatory reporting tracker solution that can provide your company with automated alerts for all of the relevant federal filings that are due throughout the calendar year. JSI can also customize its TrackNow system to include any state-specific reporting requirements or other deadlines that might be relevant to your company.

• With TrackNow, you can better position your company for success with all of its regulatory filings by increasing project visibility, internal and external collaboration, training, and overall accountability within your team. TrackNow also includes an initial set-up meeting and customization session, a 30-minute training session, an inventory of all filings due throughout the year, and regular updates to the system based on changes to the pertinent rules, guidance, and deadlines.

• JSI would be happy to customize a TrackNow package to ensure that it provides your company with the support that it needs – and provides your team with the peace of mind that it deserves. To learn more about TrackNow, simply click the button below to connect with our team today.