Clients have several opportunities to provide feedback and insight to help the Federal Communications Commission (FCC) shape policy and inform upcoming congressional reports. JSI encourages clients to file comments in proceedings relevant to their business and share company-specific perspectives.

Rural Health Care Program

The FCC is proposing new rules and seeks comment on changes to the Telecommunications (Telecom) Program, a component of the Rural Health Care (RHC) Program. The Telecom Program ensures that rural health care providers do not pay more than their urban counterparts for telecommunications services by subsidizing the difference between rural and urban rates.

The FCC seeks comment on how to improve the accuracy of support provided by the Telecom Program and decrease administrative burdens. Clients that provide services to rural healthcare providers and receive support from the Telecom Program are encouraged to submit comments in response to the FCC’s proposals and inquiries. Although not yet published in the Federal Register, comments will be due 30 days after the FCC order is published.

Accessibility of Communications Technologies

The FCC also invites comment on issues relating to communications accessibility and plans to use such comments to inform its biennial report to Congress, which is required by the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA). The CVAA requires telecommunications, interconnected voice over Internet protocol (VoIP), and advanced communications service providers and equipment manufacturers to make their services and equipment available to and useable by people with disabilities. The CVAA also requires Internet browsers on mobile phones to be accessible to and usable by people who are visually impaired.

The FCC seeks comment on current levels of compliance with the CVAA, products or services that are not accessible, and the extent to which providers and manufacturers ensure the usability of their offerings through accessible manuals, bills, and product support. The FCC also seeks comment on developments in the accessibility of new communications technologies such as 5G, high-definition (HD) voice, the Internet of Things, and Bluetooth.

In light of the COVID-19 pandemic, the FCC is especially interested in whether equipment necessary to work, study, and obtain healthcare remotely is accessible to people with disabilities. The deadline for filing comments in this proceeding is April 4, 2022.

The Future of USF

JSI recently filed comments in response to the FCC’s Notice of Inquiry on the future of the Universal Service Fund (USF). JSI encouraged the FCC to adopt a policy framework that secures the future of needed federal high-cost universal service. JSI also encouraged the FCC to recognize and report to Congress the historic importance of the federal high-cost universal service programs. JSI emphasized that the programs provide crucial support to rural local exchange carriers who provide broadband services to rural customers in furtherance of the FCC’s goal to ensure all Americans have access to quality broadband. JSI also recommended the FCC adopt robust standards for universal service and further universal service in high-cost areas of the nation by:

  • Coordinating the use of grant funds with existing high-cost universal service support;
  • Reinforcing the importance of the Eligible Telecommunications Carrier designation for providers seeking universal service;
  • Requiring trained auditors to conduct reviews for waste, fraud, and abuse in high-cost programs;
  • Revisiting the distribution of the remaining Rural Development Opportunity Fund budget to better address deployment needs in rural areas;
  • Ensuring levels of universal service support to construct and maintain rural networks; and
  • Engaging in meaningful universal service contribution reform in 2022.

In response to its inquiry, the FCC received 75 comments. Of particular interest to the rural providers JSI serves, many commenters discussed funding USF with Congressional appropriations instead of contribution charges, reforming high-cost USF, and maintaining USF for operating expenditures. JSI plans to file reply comments addressing these issues and encourages clients to file company-specific comments in which they can provide their own perspectives on proposals made by commenters.

JSI’s seasoned advocacy experts are ready to provide strategic advice and assist in drafting company-specific comments. Reply comments are due on March 17, 2022, so we ask that clients interested in JSI’s help contact us no later than March 10, 2022.

If you would like JSI’s help with writing comments or are otherwise interested in discussing any of the topics raised in this e-Lert, just click below, and one of our FCC experts will contact you.