Upcoming Deadline Reminders: Service Accessibility Compliance, LD Rate Averaging

JSI reminds clients of two upcoming deadlines: service accessibility compliance certifications (April 2) and FCC Section 254(g) interexchange rate integration and rate averaging certification (May 1). Details of both are below.

Service Accessibility Compliance Certification
All telecom providers, providers of advanced communications services (VoIP, electronic messaging, and interoperable video conferencing) and mobile phones with web browsers, have until April 2, 2018, to submit their certifications for calendar year 2017 to the FCC concerning accessibility of services to the disabled. The filing must be completed via the FCC’s Recordkeeping and Compliance Certification and Contact Information Registry. Specifically, providers are to certify operating procedures have been established to:

  • Document efforts to consult with individuals with disabilitiesu037e
  • Document the accessibility features of products and servicesu037e and
  • Record information about the compatibility of such products and services with peripheral devices or specialized customer premise equipment commonly used by individuals with disabilities to achieve access.

Certifications and contact information must be submitted for your company and for each affiliate that provides telecom services. If previously submitted contact information remains current, the 2018 submission need only include the new compliance certification. We remind clients that any updates to contact information must be made in the online registry within 30 days of the change.

FCC Section 254(g) Interexchange Rate Integration and Rate Averaging Certification
Each non-dominant provider of detariffed interstate interexchange service must certify by May 1, 2018, that it provides service in compliance with the geographic rate average and rate integration obligations pursuant to section 254(g) of the Communications Act. Geographic rate averaging prohibits a company from charging different rates for calls of similar geographic scope. Providers must certify annually that pricing policies are not discriminatory among rural and high cost areas and that rates charged in each state are no higher than rates charged to any other state.

Clients who need assistance with either of these filings should contact Kim Waldvogel in the Maryland office at 301-459-7590.