The Federal Communications Commission (FCC or Commission) has released a Public Notice seeking comment on potential reforms to the Universal Service Administrative Company (USAC), the private not-for-profit corporation that administers the Universal Service Fund (USF) programs. This is the first wide-ranging review of USAC’s operations in many years and signals a broad interest by the Commission in strengthening efficiency, accountability, and transparency across the organization.

The Commission is casting a broad net as it seeks comments on USAC operations and governance with the goal of strengthening internal processes, improving management structure, and ensuring the Commission’s oversight framework reflects current best practices for accountability and transparency. Stakeholders have been asked to weigh in on:

Current State and Operations — How USF administration can be made more efficient, what process improvements are most needed, and what barriers exist to meaningful reform;

Internal Management — Whether existing USAC processes create undue delays for program participants and whether clearer deadlines or “shot clocks” for USAC action would improve responsiveness;

Audits and Fund Recovery — Whether audit and recovery processes should be streamlined and made uniform across USF programs, and whether statistical sampling and extrapolation methodologies should be codified program-wide;

Annual Audit and MOU — What changes, if any, should be made to USAC’s annual independent audit, and whether the FCC-USAC Memorandum of Understanding should be updated — including whether it should require USAC to submit a proposed annual budget; and

Board Composition and Conflicts of Interest — Whether the USAC Board’s size, stakeholder representation, nomination and removal processes should be modified, and how the FCC should strengthen conflict-of-interest rules for Board members.

Comments are due May 15, 2026.

JSI strongly encourages providers to participate directly in this proceeding. Comprehensive reviews of USAC’s operations are exceedingly rare and your feedback could shape how USF programs are administered for the foreseeable future.

Carriers that have experienced firsthand frustrations with USAC processes are in a uniquely powerful position to inform these reforms, and individual provider voices carry significant weight with the Commission. If your company has encountered challenges such as unexplained delays in funding disbursements, burdensome or inconsistent audit processes, difficulties resolving red light status, challenges navigating USAC’s appeals and recovery procedures, lack of responsiveness from USAC program staff, or administrative processes that seem disconnected from the operational realities of smaller providers, this is the proceeding to share actionable recommendations for improvement.

JSI is ready to assist in preparing and submitting comments that clearly and effectively present your experiences and recommendations. If you are ready to participate in these comment proceedings, please contact Celia Lewis or Brett Hallagan.

The Federal Communications Commission’s (FCC or Commission) Wireline Competition Bureau (Bureau) has updated the Performance Measures Module (PMM) to streamline how carriers certify when they have no network performance testing data to report for a given quarter. Previously, carriers without test results were required to email both the Bureau and USAC by the quarterly certification deadline. Starting with the April 15, 2026 certification deadline, that email process is being eliminated in favor of new in-system certification options.

New Certification Process

The PMM now includes three specific certification options for carriers with no data to report. Carriers can select the appropriate reason from the following:

• No active subscribers during the quarter for the speed tier
• The carrier had active subscribers but obtained the sample during the quarter and did not have time to set up testing; or
• The carrier had subscribers but did not perform network testing.

Carriers must use these new system certifications rather than sending email notifications. The upcoming quarterly certification deadlines are April 15, 2026 (Q1 2026 results), July 15, 2026 (Q2 2026 results), October 15, 2026 (Q3 2026 results), and January 15, 2027 (Q4 2026 results).

Given the significant penalties associated with missed certifications, JSI encourages clients to familiarize themselves with the new certification options well before the April 15 deadline. For questions about the new certification process or assistance with PMM compliance, please contact Lans Chase or Brett Hallagan.

JSI would like to remind all Advanced Communications Service providers that their annual certification regarding covered equipment and services is due by March 31, 2026. “Advanced Communications Service” is defined as a high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality voice, data, graphics, and video telecommunications using any technology with connection speeds of at least 200 kbps in either direction.

The FCC requires all providers to certify whether they have purchased, rented, leased, or otherwise obtained any covered equipment or services from the Covered List since August 14, 2018. This annual reporting requirement helps the FCC track the presence of equipment from manufacturers on the Covered List within U.S. communications networks.

Importantly, if you have previously certified that you do not have any covered communications equipment or services, you do not need to file a certification this year unless you have subsequently added covered equipment since your last certification. If your company possesses covered equipment or services, you’ll need to provide additional information including equipment location, type, costs, replacement plans, and justification for the acquisition. Your 2026 Annual Report should reflect information current as of December 31, 2025.

If you need assistance with this filing or have questions about your reporting obligations, please contact Lans Chase.

The Universal Service Administrative Company (USAC) has announced that beginning August 2026, it will require the use of SAM.gov banking information to process all Universal Service Fund (USF) disbursements. This change completes the transition to the Unique Entity Identifier (UEI) system announced in April 2022. This is required for all service providers, including both those who receive direct USF payments and NECA pool participants, though USAC will continue to honor NECA selections and send payments to NECA on their behalf. JSI encourages all providers to take immediate action to ensure uninterrupted reimbursements.

All providers who invoice USAC and receive USF disbursements must register at SAM.gov to obtain a UEI and add their bank account information to their SAM.gov profile. The registration process typically takes four to six weeks to complete, so providers should begin this process immediately. Once SAM.gov confirms the UEI is active, providers can then log into E-File and add the UEI to their FCC Form 498.

SAM.gov requires annual renewal of registrations. Providers must complete the renewal process one year from their initial registration date and each subsequent year thereafter, or risk USF payment processing delays.

If you need assistance understanding these requirements or would like JSI to assist with your registration, please contact Lans Chase.

The Federal Communications Commission (FCC or Commission) has released a Notice of Proposed Rulemaking (NPRM) that would introduce substantial new operational requirements for all carriers participating in the Lifeline program. While the proposal addresses numerous program aspects, three specific changes could create significant compliance burdens and costs for providers, particularly smaller carriers with limited Lifeline subscriber counts.

Universal Broadband Usage Tracking

The most significant proposed change would require all Lifeline providers to track and document broadband usage for every Lifeline subscriber, regardless of service plan or billing arrangement. Currently, carriers that assess and collect monthly fees from subscribers are exempt from usage tracking and non-usage de-enrollment requirements. The proposal would eliminate this exemption, requiring carriers to monitor broadband usage, submit proof of subscriber usage with reimbursement claims, and maintain detailed documentation of tracking methods.

For many providers, implementing broadband usage tracking systems represents a substantial new compliance cost that could exceed the revenue generated from serving a limited number of Lifeline customers. Most carriers typically serve tens to hundreds of Lifeline subscribers rather than thousands, making the administrative infrastructure required for comprehensive usage monitoring particularly burdensome relative to program participation benefits. Additionally, providers may not currently have systems in place to track broadband usage and would need to invest in new monitoring capabilities, modify billing systems, and dedicate staff resources to ongoing compliance documentation.

Secondary Verification Requirements

The Commission also proposes enhanced consumer protection measures requiring secondary verification of all enrollment and transfer requests. Providers would need to obtain affirmative confirmation through text or email responses from subscribers for each transaction, submit consent evidence to USAC, and potentially comply with transfer restrictions limiting provider changes to once per month. While intended to prevent unauthorized enrollments, these requirements would add additional administrative steps to already efficient processes. For providers with limited administrative staff, the additional verification and documentation requirements for each Lifeline transaction could represent a meaningful increase in operational workload and expenses.

Minimum Service Standards Changes

The proposal would reform minimum service standards by addressing the mobile broadband data capacity formula that has required annual waivers since 2019. The Commission seeks comment on whether standards should remain static, be tied to marketplace data, or use alternative calculation methods. Changes to minimum standards could affect network capacity requirements and potentially impact the ability of some providers to offer no-cost Lifeline services in certain service areas where higher speeds may not be economically viable.

Why Your Input Matters

The Lifeline rules adopted over the past decade were prompted by documented fraud patterns associated with high-volume wireless reseller enrollment models and third-party agent activity. Expanding usage tracking requirements to all providers, including facilities-based carriers with established customer relationships and limited Lifeline participation, represents a significant regulatory expansion that may not be appropriately targeted to demonstrated program integrity risks. Comments from providers explaining the operational realities and costs of implementing these requirements, particularly for smaller carriers, would provide the Commission with essential information as it considers whether these rules achieve program integrity goals without creating disproportionate burdens.

JSI Needs Your Input

To effectively represent provider concerns in this proceeding, JSI needs to understand the practical impacts these proposed requirements would have on your operations. We are specifically interested in learning:

• Do you currently track broadband usage for Lifeline subscribers? If so, what systems do you use and what are the associated costs?
• If you don’t currently track broadband usage, what would it cost to implement the necessary monitoring systems and processes?
• How many Lifeline subscribers do you currently serve, and what is your approximate monthly Lifeline reimbursement?
• What administrative resources would secondary verification requirements demand from your staff

JSI suggest providers file comments in this proceeding to highlight the disproportionate burden these requirements create and to advocate for more targeted approaches that address legitimate program integrity concerns without creating unnecessary regulatory costs. Your operational data and specific examples would strengthen these arguments and help demonstrate the real-world impacts of the proposed rules.

If you are interested in participating in this proceeding or have questions about how these proposed reforms might affect your Lifeline operations, please contact Celia Lewis, Dounia Chikhoune, or Brett Hallagan.

The Federal Communications Commission (FCC or Commission) has released a Notice of Proposed Rulemaking (NPRM) that would fundamentally reshape how telecommunications carriers recover costs for voice services. In 2011, the FCC began transitioning terminating switched access charges to bill-and-keep, where carriers recover network costs directly from subscribers rather than from other carriers. The 2011 reforms left many access charges in place, including originating switched access charges, certain terminating charges, dedicated transport charges, 8YY charges, and SS7 signaling charges. The Commission proposes in this NPRM to complete the transition of all remaining intercarrier access charges to a bill-and-keep framework, eliminate price regulation of end-user telephone charges, and accelerate the industry’s shift to all-IP networks.

Transition to Bill-and-Keep Access Charges

Under the proposed rules, all remaining interstate and intrastate access charges would transition to bill-and-keep over 24 months through three annual reductions: 33% at the first annual tariff filing following the effective date, an additional 33% at the second filing, and a final 34% at the third filing, bringing all charges to zero. This schedule would apply uniformly to both price cap and rate-of-return carriers. As an immediate first step, all remaining uncapped intrastate originating access charges would be capped effective 30 days after final rules are published in the Federal Register.

During this same two-year transition period, the FCC would eliminate all remaining tariff requirements for interstate and international interexchange services. The notice also addresses a critical implementation question: defining the network edge—the point where financial responsibility for transporting traffic shifts between carriers under bill-and-keep. The FCC asks whether each state should designate a single point of interconnection during the transition period, with carriers financially responsible for transporting traffic to that point including any necessary TDM-to-IP conversion costs.

Deregulation of Telephone Access Charges

To enable carriers to recover costs from end users, the FCC would eliminate ex ante pricing regulation and mandatory tariffing requirements for all end-user Telephone Access Charges, including the Subscriber Line Charge, Access Recovery Charge, Presubscribed Interexchange Carrier Charge, Line Port Charge, and Special Access Surcharge. Carriers could begin detariffing these charges with the first annual access tariff filing following the effective date and must complete detariffing no later than the second annual filing. Once detariffed, carriers could set rates based on market conditions subject to just and reasonable rate requirements.

CAF ICC Phase-Out and Universal Service Adjustments

The NPRM proposes a phase out of CAF ICC support for rate-of-return carriers over two years following the completion of the transition to bill-and-keep. Under the proposed rules, carriers would receive 66% of their baseline support amount in the first year after transition, 33% in the second year, and zero beginning in the third year.

For universal service contributions, the FCC proposes adopting a 25% interstate safe harbor for local voice service revenue. For CAF BLS calculations, carriers would use fixed SLC amounts of $6.50 monthly for residential and single-line business lines and $9.20 monthly for multi-line business lines.

Next Steps

This proceeding represents the most comprehensive reform of intercarrier compensation and access charge regulations in over a decade and will fundamentally affect how telecommunications providers recover costs and structure their services. The FCC is seeking comments on whether the 24-month transition period provides sufficient time for carriers to adapt, whether the CAF ICC phase-out appropriately balances stability with the transition to bill-and-keep, how the network edge should be defined during and after the transition to all-IP networks, whether additional funding mechanisms are needed to support rate-of-return carriers’ IP transition, and what impacts the elimination of price regulation for end-user charges might have on cost recovery and consumer rates.

JSI strongly encourages participation in this proceeding through individual comments or coordinated industry filings. Comments will be due 60 days after Federal Register publication, with reply comments due 90 days after publication. Federal Register publication has not yet occurred. For assistance in analyzing these proposals, developing comment strategies, or preparing filings, please contact Brett Hallagan or John Kuykendall.

The Federal Communications Commission (FCC or Commission) has implemented new annual recertification requirements for the Robocall Mitigation Database (RMD), with the first mandatory recertification deadline of March 1, 2026, now approaching. All voice service providers with current RMD filings must complete their annual recertification during the filing window that opens February 1, 2026.

New Annual Requirements

All providers with current RMD filings must now certify annually that their submitted information remains true and correct. This annual recertification will be required every March 1st going forward. Providers must verify the accuracy of all information including robocall mitigation programs, STIR/SHAKEN implementation certifications, and contact information. Additionally, all FCC Registration Number (FRN) holders must update their CORES information within 10 business days of any changes.

The FCC has established significant penalties for RMD violations, including a $10,000 base forfeiture for false or inaccurate information and a $1,000 base forfeiture for failure to update information within required timeframes. The planned $100 application fee is not yet effective for this recertification cycle.

Providers should ensure this March 1, 2026, recertification deadline is added to their JSI TrackNow portal. For assistance with RMD recertification requirements, please contact Bridget Alexander White or Brett Hallagan.

The Federal Communications Commission (FCC or Commission) has announced that new Robocall Mitigation Database (RMD) requirements will take effect February 5, 2026, establishing a $10,000 base forfeiture for each violation involving false or inaccurate RMD information and a $1,000 base forfeiture for failure to update information within required timeframes. Both penalties are assessed on a continuing violation basis until cured, meaning providers face daily penalties until deficient information is corrected.

Additional Provisions with Delayed Effective Dates

Additional RMD rules have been adopted but will not take effect until their announcement in a subsequent Federal Register publication. These include CORES update requirements, annual RMD recertification, and the addition of an application processing fee when created or updated RMD registrations.

Recommended Actions

Given the significant increase in penalty amounts, JSI recommends that providers conduct a thorough review of their current RMD filings to ensure accuracy and completeness before the February 5, 2026, effective date. This proactive approach can help avoid costly violations and ensure continued compliance with evolving robocall mitigation requirements.

For assistance with understanding these new penalty provisions or ensuring RMD compliance, please contact Bridget Alexander or Brett Hallagan.

Tax Updates

• Illinois confirmed new municipal SMTT rates effective July 1, 2026. Combined rates: 8.65% state, Up to 6.00% local (outside Chicago). Providers needed to validate municipal coding, sourcing, and billing configs during April–May to prepare.
• San Francisco, CA – MTS rate increases from 15.8% to 16.02%, effective 4/1/2026.
• CA, Sales and Use Tax – rate increase for Q226 for 7 cities/districts.
  PUBLICATION 388, TAX INFORMATION BULLETIN
• Ohio eliminated several long standing exemptions, resulting in broader sales tax application to telecommunications and related digital services, including: Certain telecommunications services, Digital communications products, Data transmission and processing services historically treated as informational or ancillary.

Assurance

• CCH update – Reconfiguration of the Plano, Texas Local 911 Fee
• CCH update – Reconfiguration of the Maine Universal Service Fund
• CCH update – Reconfiguration of the Utah Universal Service Fund
  • Rising VoIP and bundled‑services scrutiny being identified and reviewed; January  1, 2026 expansions to digital and communications tax bases began showing billing and audit impact in April, especially for:
  • VoIP
  • UCaaS
• Bundled voice + software offerings
• Preparation for mid‑year state and municipal tax changes
• Security and disaster‑response obligations – CPUC in Imperial, Santa Barbara, Santa Cruz, Mendocino, Sonoma, Ventura, and Humboldt California Counties
• The FCC expanded DIRS and MDRI reporting in response to Super Typhoon Sinlaku; Providers were required to submit network‑status and outage reports throughout April

Talk to one of our experts for more details to confirm you are not missing these crucial agency updates

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Federal Oversight and Initiatives

Despite the Q2 dip to 37.0%, industry pressure on: expanding the contribution base (e.g., broadband) or restructuring USF methodology continues in Congress and at the FCC.

499 A filings were due April 1, 2026, using 2025 revenue data.
April and May 2026 USF invoices are based on these newly updated filings.

• The FCC announced the agenda for its April 30, 2026 Open Commission Meeting, highlighting several major regulatory actions.
• FCC Announces Tentative Agenda for April Open Commission Meeting
  April 2026 FCC releases show strong emphasis on:

• Robocall enforcement and KYC controls
• Satellite broadband and spectrum modernization
• National security in telecom infrastructure
• Disaster response accountability
• Cybersecurity certification
• The FCC signaled additional reporting and disclosure requirements tied to domestic Section 214 authorizations.
  • Section 214 compliance often overlaps with:
  • Transaction reviews
  • Certifications
  • Ongoing reporting requirements
  • Failures can trigger:
    • Fines
    • License revocations
    • Increased regulatory fees
• Wireless Telecommunications Bureau – Lower C‑Band Rulemaking – Published: April 15–16, 2026 – https://www.federalregister.gov/documents/2026/04/15/2026-07269/wireless-telecommunications-bureau-refreshes-record-on-lower-c-band-petitions-for-reconsideration
• News Release – April 20, 2026 – https://www.fcc.gov/document/fcc-issues-initial-determination-robocall-order-against-sk-teleco
• News Release – April 20, 2026 – https://www.fcc.gov/document/domestic-section-214-authorization-granted-logix

FCC Upcoming Events

• April 30, 2026 – April 2026 Open Commission Meeting
• May 14, 2026 – Cybersecurity Workshop for Broadcasters
• May 15, 2026 – Cybersecurity Workshop for Telecommunications Carriers
• May 20, 2026 – May 2026 Open Commission Meeting

Industry Recap

• South Carolina USF – 3.74% contribution factor; Applies to wireline, wireless, and VoIP, In effect since January 1, 2026, continues through April–May.
• Missouri, Madison County Subscriber Fee E911 – Added and due effective April 1, 2026
• Alaska, City of Palmer adopted changes to its sales tax ordinances; Effective April 1, 2026 the City of Palmer’s sales tax rate will increase from 3% to 4%.

Uncover more with a JSI i360 911 rules and rates database solutions subscription – learn more about this here – i360 – JSI.

JSI offers transactional tax managed services, including tax audit support. We’re the human hands behind the technology that drives your business to success. 

President Trump has signed an Executive Order (Order) establishing federal AI policy that directly conditions Broadband Equity Access and Deployment (BEAD) program funding on state artificial intelligence regulations. States with AI laws deemed “onerous” by the federal government may lose access to BEAD non-deployment funds, with implementation guidance required from the Commerce Department by March 11, 2026. The Order positions AI innovation as dependent on high-speed broadband networks, bringing telecommunications infrastructure within the scope of federal AI policy enforcement.

BEAD Funding Restrictions

The Executive Order requires the Secretary of Commerce to issue a Policy Notice establishing conditions for continued BEAD program eligibility by March 11, 2026. States identified as having conflicting AI laws may become ineligible for BEAD non-deployment funds “to the maximum extent allowed by federal law.” The Policy Notice directive is to demonstrate how state AI regulation threatens BEAD-funded deployments, AI applications that rely on high-speed networks, and the program’s universal connectivity mission.

The Order also directs the Federal Communications Commission (FCC) to consider adopting federal AI reporting and disclosure standards that would preempt conflicting state requirements, potentially affecting AI tools used by telecommunications providers for network management and operations. Additionally, all federal agencies must assess discretionary grant programs and consider conditioning funding on states avoiding conflicting AI laws.

The Commerce Department’s March 2026 evaluation will provide clearer guidance on which state laws are considered problematic. JSI will continue monitoring developments as AI policy and BEAD program requirements converge. For assistance with BEAD program compliance or questions about how these developments might affect your operations, please contact Amanda Molina or Brett Hallagan.