On September 28, 2015, JSI filed joint comments with NTCA–The Rural Broadband Association and WTA – Advocates for Rural Broadband in support of the Wireless ETC Petitioners Petition for Reconsideration regarding the FCC’s Lifeline Reform Order. The joint comments agree with the Wireless ETC Petitioners’ and Total Call Mobile, Inc.’s assertions that the FCC’s proposed Snapshot Rule would force ETCs to “incur costs and provide service without reimbursement.”

JSI, NTCA and WTA pointed out that RLECs typically bill all of their customers on a monthly basis, including Lifeline customers. In addition to potentially not being reimbursed monthly for “each qualifying low-income consumer served,” the proposed Snapshot Rule would require companies that bill their Lifeline customers on a monthly basis to either undergo costly billing system changes or implement a labor-intensive manual process which would increase the risk of errors and unduly complicate reporting and audits procedures.

Moreover, these changes will be necessary to accommodate what appears to be an interim measure, as the FCC has begun a proceeding for more permanent changes to the provider reimbursement process.

Thus, NTCA, WTA, and JSI requested that billing carriers be given the option of taking a snapshot of the number of subscribers as of their carrier-specific billing dates.