One of the FCC’s new Lifeline reforms, the “Snapshot rule,” takes effect for all eligible telecommunications carriers (ETCs) on August 15, 2016 (see JSI’s April 21 e-Lert). All ETCs must take a “snapshot” of the number of eligible Lifeline subscribers they have as of September 1 and use this count on FCC Form 497 for the August 2016 data-month.
The new rule implements a uniform snapshot date, the first day of the month, to report counts for the prior data-month in order to request reimbursement from USAC for providing Lifeline support. Previously, carriers could use their company’s normal billing date. The snapshot date is always the first day of the month, even if that day falls on a holiday or weekend. Subscribers who are enrolled and de-enrolled between snapshot dates are not included in the Form 497 for reimbursement.
Companies in default states, such as Texas, that receive a monthly list of eligible Lifeline subscribers from a state Lifeline administrator also are required to use the first day of the month snapshot date for filing the Form 497. Carriers are not required to provide a copy of the snapshot records with the Form 497, but should keep copies of the snapshot for audit purposes.
Mark Your Calendar
JSI will be hosting a webinar on key steps for implementing the Lifeline Modernization Order on Thursday, September 29 at 2 p.m. Eastern (1 Central). We will announce more details and registration soon, but for now put this date on your calendar.
If you have any questions or you would like JSI’s help with any of the new Lifeline changes, please contact Lans Chase in JSI’s Georgia office at 770-569-2105 or Lisa McLaughlin in our Texas office at 512-338-0473.
Source: JSI e-Lert