Data Recording Starts April 1

About 16 months after the rules were first adopted, last week the Office of Management and Budget (OMB) approved the FCC’s Rural Call Completion Recordkeeping and Reporting Requirements. Rural call completion problems have troubled the industry, and especially rural consumers who cannot be reached by landline, for years without significant improvement in the matter. The FCC has issued several enforcement actions, and now the new recordkeeping and reporting requirements are moving forward—it remains to be seen if any positive impact on the problem will be achieved.

Entities that must comply with the recordkeeping and reporting requirements (FCC Form 480) are called “covered providers.” Covered providers are long-distance voice service providers that make the initial call path decision and have more than 100,000 domestic retail subscriber lines (including all business, residential, and mobile subscriber lines). Covered providers include local exchange carriers (LECs), interexchange carriers (IXCs), commercial mobile radio services (CMRS), and voice over IP (VoIP) providers; however because of the 100,000 line reporting threshold, very few RLECs will qualify as a covered provider. The first Form 480 will be due August 1, 2015, and cover data collected for the months of April, May, and June. Additionally, long-distance voice providers that do not make the initial call path decision, but have more than 100,000 domestic retail subscribers, will need to file a letter by April 1 explaining why they are not subject to the recordkeeping and reporting requirements.

Already, the FCC has concluded some enforcement actions against covered providers, and we expect to see additional enforcement actions by the FCC this year. As part of its Consent Decree, Verizon is required to hold a workshop on rural call completion problems in April. For more information about the status of rural call completion problems, the recordkeeping and reporting requirements, and ongoing advocacy efforts at the FCC and on the Hill, contact Cassandra Heyne and John Kuykendall in the Maryland office at 301-459-7590. JSI can assist with ex parte visits and communications to lawmakers on this serious call completion problem in rural America.

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