JSI Files Comments Urging USAC Process Reforms to Benefit Communications Providers

JSI has filed comments with the Federal Communications Commission (FCC or Commission) in response to a Public Notice seeking input on reforms to the Universal Service Administrative Company (USAC) — the entity that administers the Universal Service Fund (USF) programs on the FCC’s behalf.

JSI grounded its comments in what our clients have experienced firsthand navigating USAC processes and in the challenges we have witnessed working alongside providers through audits, filings, appeals, and compliance matters over many years. We are proud to advocate for these reforms, as the inefficiencies and unpredictability in the current system create real burdens for providers — and any new framework must be built with providers’ interests at its center. We welcome you to review our filed comments in ECFS.

How JSI Advocated for Providers

JSI’s comments centered on a core theme: many of the compliance challenges providers are facing stem not from a lack of rules, but from misalignment between FCC policy, USAC’s administrative implementation, and the operational realities providers navigate on the ground. JSI urged the Commission and USAC to address this friction through several targeted reforms.

On rulemaking implementation, JSI highlighted how delays between FCC policy adoption and USAC’s system and process updates expose providers to compliance risk through no fault of their own. JSI recommended more structured FCC-to-USAC implementation guidance and clearer transition timelines.

On audit administration, JSI proposed formal “shot clock” timelines for each stage of USAC’s audit processes, along with a tiered escalation pathway for stalled matters. JSI also called for greater coordination to prevent overlapping, duplicative audits of the same providers and data periods, which burdens smaller providers with limited staff and compliance resources.

On recovery practices, JSI urged the Commission to apply materiality thresholds before initiating formal recovery proceedings, and to require greater transparency in USAC’s use of statistical sampling and extrapolation to calculate recovery amounts, which can produce demands that far exceed the actual scope of a compliance deficiency.

Finally, JSI recommended that the Commission and USAC establish a feedback-driven continuous improvement framework using trends from audits, appeals, and stakeholder inquiries to proactively improve guidance, training materials, and filing systems, rather than relying solely on enforcement to address recurring issues.

Your Voice Matters in These Processes

The FCC considers the record developed through the comment process, which means the perspectives of service providers are necessary and essential to quality reform. Comments submitted by carriers carry significant weight and help the Commission understand the real-world impact of administrative inefficiencies on the providers these programs serve.

Participating in FCC comment cycles is one of the most direct ways providers can shape the rules and processes that govern their operations. JSI regularly monitors open proceedings and can help you identify opportunities to make your voice heard. If you are interested in participating in current or future comment proceedings, please contact Brett Hallagan.