Save the Dates – JSI’s 2021 Financial Seminars

2021-11-02T13:11:07-04:00June 11, 2021|News|

We are excited to welcome everyone back to in-person trainings with our Financial Seminars this fall in Nashville! Begin making plans now for your key accounting and financial staff to attend these two seminars. Our one-day Part 32 & Part 64 Accounting Seminar will be Tuesday, September 28. Then we hope you’ll stay for our Separations & Access Seminar which runs Wednesday, September 29 – Friday, October 1. And as always, you’ll be eligible for CPE credits for both seminars.

Our Accounting Seminar provides a detailed review and explanation of the FCC’s Part 32 and Part 64 accounting principles and applications. Brian Sullivan and Ryan Denzel will once again discuss the FCC’s latest accounting procedures, including the “allowable” expenses for USF and NECA purposes, plus its increased regulatory scrutiny of the Part 64 allocation mechanisms.

The Separations & Access Seminar again will focus on how cost settlements, regulated and non-regulated allocations, jurisdictional categorizations, access procedures, and intercarrier compensation affect today’s broadband-centric network. Brian and Ryan will discuss the Universal Service funding mechanisms; data reporting and compliance; special access/BDS issues; using operational and financial data to manage for success; and federal and state grants and loans issues and opportunities.

Watch for More Information Soon!

Right now, block off September 28-October 1 on your calendar and look for a registration announcement in a few weeks. If you have any questions before registration opens, you can contact Leah Yoakum at 301-459-7590.

FCC Extends Study Boundary Area Recertification Deadline

2021-11-02T13:11:43-04:00May 19, 2021|e-Lerts|

Last week, the FCC announced that it would extend the deadline to file the biennial recertification of study area boundary data to June 30, 2021 (see JSI’s April 26, 2021, e-Lert for more information). ILECs and state commissions that submitted updated boundaries between December 31, 2020, and March 15, 2021, will not be required to recertify their data this year. All other ILECs and state commissions will be responsible for recertifying.

ILECs and state commissions should take these steps to complete the process:

  • Confirm your study area boundary by reviewing the study area boundary map (instructions for viewing the map can be found here). If the data is accurate, ILECs and state commissions can proceed with recertifying the data through the FCC’s portal. If the data is not correct, the ILEC or state commission will be required to file revised boundaries through the portal and inform FCC staff by sending an email to
  • ILEC Recertification: Once the study boundary area data has been confirmed as accurate, ILECs must sign into the FCC Portal and recertify their areas. Here is a tip sheet for completing the recertification electronically.
  • Certifying State Commission Recertification: Once a certifying state commission has reviewed and confirmed the boundary map is correct, the state commission must complete and sign the recertification notification.

If you would like any assistance with recertifying your study boundary area or have any questions, please reach out to Janee Devis at 301-459-7590.

EBBP Officially Launches Today; FCC Issues Warning to Providers

2021-11-02T13:11:58-04:00May 12, 2021|e-Lerts|

Yesterday, the FCC issued an Enforcement Advisory in advance of today’s launch of the Emergency Broadband Benefit Program (EBBP). The advisory reminds providers participating in the EBBP of their obligations to comply with the program’s rules. Providers must ensure that existing Lifeline customers give their informed affirmative consent to participate in the EBBP. Under the EBBP rules, customers can choose not to apply their emergency broadband benefit with their existing Lifeline provider without jeopardizing their Lifeline service.

The FCC has heard that some providers may be linking EBBP enrollment to implementation of technical changes necessary to retain the subscriber’s existing service or automatically enrolling subscribers that provide information needed for another purpose. The FCC warns that these practices may be deceptive and may undermine the integrity of the EBBP and can threaten to put subscribers at risk of losing their existing Lifeline service. The FCC emphasizes that providers must ensure that communications to consumers about the EBBP are clear, accurate, and not misleading as to the nature of the program, the program’s eligibility requirements, and the timing of the program and application process.

The advisory states that at a minimum, providers must make it clear that subscribers:

  1. may continue their existing Lifeline service without enrolling in the EBBP;
  2. may choose to take EBBP benefits from a service provider other than their existing Lifeline provider; and
  3. may transfer EBBP benefits to another provider at any time.

The advisory also highlights that “the provider must also retain documentation demonstrating that, having received such disclosures, the household provided affirmative consent to applying their Emergency Broadband Benefit to the service received from the EBB provider. Broadband providers may be required to provide such documentation to demonstrate compliance during an audit, validation, or investigation.”

Further Guidance on EBBP Questions
USAC has clarified a couple of key issues regarding the EBBP process that were causing confusion. First, many companies have asked how to handle partial monthly service under the EBBP. Although the EBBP Order seemed to indicate that using a uniform snapshot would not require a provider to claim a prorated amount when seeking reimbursement, USAC has now said that is not the case.  USAC states that:

“the EBB reimbursement cannot exceed the EBB discount that the provider actually passed through to the consumer for that month. So if the prorated price of the service is less than $50 for that month, then the provider must ensure it is not claiming reimbursement for more than the price of the service in that month.”

Secondly, while the rules are clear that providers cannot disconnect EBBP customers for non-payment, it was not clear if providers could downgrade a customer’s broadband service to a lower-priced plan for non-payment. USAC clarifies that:

“EBB Program rules do not prohibit a provider from downgrading a subscriber’s broadband service if the subscriber falls behind on their portion of the bill for the EBB-supported service. Providers downgrading a customer’s EBB-supported service due to non-payment are urged not to downgrade the EBB-supported service without the subscriber’s knowledge.”

If you have any questions about the EBBP, please contact Lans Chase at 770-569-2105 or John Kuykendall at 301-459-7590. If you would like JSI’s enrollment and customer notice templates, please contact Janee Devis at 301-459-7590.

Study Area Boundary Recertifications Due May 26

2021-11-02T13:13:33-04:00April 26, 2021|e-Lerts|

Every other year ILECs are required to recertify their study area boundaries and 2021 is a recertification year. This year’s deadline is Wednesday, May 26, 2021. The recertification attests that you have reviewed and determined that the shapefile for your study area is accurate and correct.

To complete the recertification, all you need to do is log in to the FCC Licensing and Databases site with your “FCC User” credentials and go to the study area boundary recertification link. JSI recommends following along step-by-step with this Study Area Boundary Recertification Tip Sheet for the best results. As a best practice, JSI also recommends taking a screenshot when you get to the final step, checking the “attest” box, because the site does not generate a confirmation email or page. Additional resources on the FCC’s study area boundary data collection and maintenance can be found at this site.

Previously, some state commissions, including Ohio, South Dakota, Vermont, Minnesota, Iowa, Kansas, North Dakota, Mississippi, and Nebraska, were initially responsible for submitting each ILEC’s study area boundary shapefile. Over the years, some of the state commissions have passed the responsibility of recertification to the individual ILECs. Each of these state commissions has since developed a different process for handling the submission of revised boundaries and the recertification process, so it is best to be aware of the process if you are in one of these states. JSI has a list of state commission information, and if you are unsure if your state commission recertified your boundaries, please contact us.

There is an annual deadline of March 15 for submitting updated shapefiles if you had study area boundary changes in the previous calendar year. If you had study area changes in 2020 and missed the deadline, JSI can work with you to get the updated shapefile submitted. In addition, ILECs that bought or sold study areas should check the FCC map to verify that the company name and holding company name are correctly listed. If the names are incorrect, it may require resubmitting a shapefile to the FCC.

For any questions about the study area boundary submission or recertification process, please contact Janee Devis in the Maryland office at 301-459-7590.

FCC Announces Robocall Mitigation Database

2021-11-02T13:13:50-04:00April 23, 2021|e-Lerts|

All service providers must submit information by June 30

The FCC has created a new Robocall Mitigation Database to enforce a requirement in the 2019 Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act (TRACED Act), which called for voice service providers to better police their networks against illegal and unwanted robocalls. All voice service providers must file certifications in the new database before June 30, 2021, providing detailed information regarding their implementation of the STIR/SHAKEN caller ID authentication framework and/or a robocall mitigation program.

When companies file their robocall mitigation program information with the FCC, each will certify that it has either completed STIR/SHAKEN implementation in its network, has partially implemented STIR/SHAKEN and is performing robocall mitigation, or that the company has not yet implemented STIR/SHAKEN and is performing robocall mitigation.

Carriers under the STIR/SHAKEN deadline extension until June 30,2023, must state the type of extension received and detail the robocall mitigation program its company has deployed. In addition, each company is required to provide a robocall mitigation contact.

Certifications, company identification information, and contact information must be submitted via the database portal on the Commission’s website at by June 30, 2021.

The FCC also set September 28, 2021, as the date in which intermediate providers and terminating voice service providers will be prohibited from accepting traffic from voice service providers not listed in the Robocall Mitigation Database.

For more information on the Robocall Mitigation Database, STIR/SHAKEN requirements, or anything robocall related, please contact Bridget Alexander White in JSI’s Maryland office at 301-459-7590.

Numbering & Porting Essentials Service

Clients interested in educating their staff on the cavalcade of numbering and porting requirements all service providers will face in 2021 should consider subscribing to JSI’s Numbering & Porting Essentials service. The subscription includes breaking news alerts, a free webinar and six web-based education sessions designed to keep companies informed about important numbering, porting and robocall mitigation decisions that will impact their internal operations and customers. Contact Bridget Alexander White for more details and to sign up.

FCC Announces Timeline to Participate in the Emergency Broadband Benefit Program

2021-11-02T13:15:10-04:00March 8, 2021|e-Lerts|

JSI’s March 16th Webinar Will Equip Participants for Implementation

In our March 1st e-Lert, we told you about the FCC’s Report and Order to establish the Emergency Broadband Benefit (EBB) program and its directive to the Wireline Bureau to release multiple Public Notices announcing timelines and other details. The first Public Notice was released late last week and contains two sets of timelines to submit information if your company decides to participate in the program – one for eligible telecommunications carriers (ETCs) and their affiliates that provide service within the same state (together known as Providers) to file an “election” with USAC and the other for non-ETCs to file an application with the FCC for approval to participate in the EBB program.

Most JSI clients fall under the category of Providers and can begin submitting their elections to participate in the program as soon as Thursday, March 11. We explain more about this process below. Entities that are not ETCs or do not have any affiliated ETCs within the state in which they provide service have a filing window that opens Monday, March 8 and closes Monday, March 22. These non-ETC entities will receive automatic program approval from the FCC if they meet certain criteria, including if they are affiliated with an ETC that serves in another state. If they don’t meet the criteria for automatic approval, they can file and receive approval under an expedited basis. If your company falls in this non-ETC category, please contact JSI as soon as possible if you would like to know more about this process or would like JSI’s assistance in filing an application with the FCC.

JSI encourages clients to diligently consider participating in the program and urges those that decide to move forward to be prepared to implement the program in a way that minimizes potential problems caused by the program’s limited duration. Our March 16 webinar will review how to participate in the program and how it will be administered, but also will provide recommendations to address issues that could arise for either your existing Lifeline subscribers or new customers that qualify under the additional criteria of the EBB program when the program ends.

Timeline for Providers
Under the Consolidated Appropriations Act, which established the program, Congress determined that existing ETCs don’t need to seek approval to participate in the EBB program, but only need to file an “election” with USAC. ETCs are entities that already are obligated to offer Lifeline services to qualified low-income individuals and include: ILECs, CLECs or wireless carriers that receive “frozen” support, Rural Broadband Experiment and CAF Phase II auction winners, and Rural Digital Opportunity Fund (RDOF) auction winners that have received ETC designation. In the Report and Order, the FCC ruled that affiliates of ETCs also qualify as Providers under the umbrella of the ETC if they provide service within the same state as the ETC.

The FCC announced the March 11 election application start date for Providers, but no deadline was provided. It is possible that one may be announced in a subsequent Public Notice, which will also provide the program’s start date. The program must begin no later than 60 days after the release of the Report and Order, which would be April 26. Given that the filing for Providers is an election open to all ETCs and in-state affiliates and is not a “first come, first served” application process, we urge clients not to rush to submit an election without thoroughly considering the pros and cons associated with implementing the program.

According to the Public Notice, Providers must submit a form to USAC, which USAC will make available “soon” on the link provided at the end of the notice (as of publishing of this e-Lert, the link was not yet available). Providers will then email that form to JSI will be available to assist companies with completing and submitting the form.

Expect to see requests for the following information required by the Report and Order on USAC’s form:

  • The states in which the provider plans to participate in the EBB program;
  • A statement that the provider was a “broadband provider” in each such state as of December 1, 2020;
  • A list of states where the provider is an existing ETC, if any;
  • A list of states where the provider received FCC approval, whether automatic or expedited, to participate, if any;
  • Whether the provider intends to distribute connected devices under the EBB program;
  • A description of the Internet service offerings for which the provider plans to seek reimbursement from the EBB program in each state;
  • Documentation demonstrating the standard rates for those services; and
  • Any other administrative information necessary for USAC to establish participating providers in the EBB program.

Additionally, participants in the EBB Program will need an FRN, SPIN and have registered with the System for Award Management (SAM) in order to receive reimbursement. While registering with SAM is not required at the time of election, the Report and Order “strongly recommends” that Providers start the registration process “immediately” because of the time it may take for the registration to become effective. You can register with the system at JSI is familiar with SAM and its cumbersome process so please let us know if you would like our assistance if you need to register. Providers that have already registered with SAM don’t need to reregister, but should check to see if its SAM registration needs to be renewed.

For more information about the EBB program or how JSI can assist your company in making the election with USAC or filing an application with the FCC, please contact Lans Chase at 770-569-2105 or John Kuykendall at 301-459-7590.

FCC Establishes the Emergency Broadband Benefit Program

2021-11-02T13:15:23-04:00March 1, 2021|e-Lerts|

JSI to Hold Webinar on March 16

The FCC late last week adopted a Report and Order to establish the Emergency Broadband Benefit (EBB) Program. The EBB program will provide eligible households with discounts off the cost of broadband service and certain connected devices for the duration of the emergency COVID-19 pandemic (see our Feb. 24th e-Lert). The Report and Order sets forth major aspects of the program, some of which are summarized below, and directs the Wireline Bureau to announce filing deadlines and other details in Public Notices – one of which is due within the next few days – that will provide the initial filing deadlines. The FCC will announce the EBB program’s start date, along with other key dates, this month or next.

JSI will hold a webinar on Tuesday, March 16th at 2 p.m. EDT to provide broadband providers with the information they’ll need to assess whether to participate in the program. We will review the pros and cons associated with being an EBB provider and go through the steps required to participate in the program and receive reimbursement. Registration for this webinar is $249 per company. You can sign up here.

The EBB program was established as part of the Consolidated Appropriations Act of 2021. Congress tasked the FCC to create the $3.2 billion program to provide qualifying low-income households with discounts on their broadband services and equipment. Participating broadband providers will receive reimbursement from the EBB for monthly discounts off the standard rates for an Internet service offering and associated equipment, up to $50.00 per month (up to $75.0 per month on Tribal lands). Providers that supply customers with a connected device will be eligible for a single reimbursement of up to $100.00 for the connected device, if the charge to the eligible household for that device is more than $10.00 but less than $50.00 (a participating provider may receive reimbursement for only one supported device per eligible household).

As for eligibility, the good news is that all eligible telecommunications carriers (ETCs) can elect to participate in the program for itself or any of its affiliates. This means that ILECs, CLECs and wireless carriers that receive “frozen” support, Rural Broadband Experiment and CAF Phase II auction winners, and any Rural Digital Opportunity Fund (RDOF) auction winners that have received ETC designation can participate or designate one or more of their respective affiliates as a participant. Further, ETCs are not required to participate in the program; it will be a voluntary election. Broadband providers that have no affiliated ETCs can also participate in the program under either an automatic or expedited approval process depending upon whether the provider meets certain criteria.

The program will utilize some of the existing mechanisms used by the FCC in its Lifeline program, such as the National Lifeline Eligibility Verifier (National Verifier) and National Lifeline Accountability Database (NLAD) and the Representative Accountability Database (RAD). But the FCC declined to impose Lifeline’s minimum service standards. Accordingly, participants in the EBB program will be able to offer discounts and receive reimbursements for any broadband services they offer, regardless of the speed.

One major issue with the program is that, at this point, it is only temporary and will end within the earlier of six months or until the program’s funds are exhausted. To ensure that households are informed that the benefit will terminate, the Order adopts procedures to notify all stakeholders of the forecasted end of the program, to disburse the remaining funds equally to providers, and to allow for a transition to ending the disbursement to households.

For more information about the EBB program or how JSI can assist your company in making the election, please contact Lans Chase at 770-569-2105 or John Kuykendall at 301-459-7590.

Save the Date – JSI’s 2021 Management Seminar

2021-11-02T13:18:23-04:00February 8, 2021|News|

We hope you and your key staff members will make plans to join us for our 2021 Virtual Management Seminar the afternoons of Wednesday, April 28 and Thursday, April 29. Instead of gathering in meeting rooms around the country, we will be gathering around our computer screens for important discussions on the financial and strategic initiatives critical to your company’s future, management principles to improve your operations, and technical advice to maximize your network and services.

Our experts have begun developing compelling and informative presentations on the following topics and more:

  • What we can expect from the FCC, especially future USF updates
  • Fallout from the RDOF auction & what to do now
  • Profiling your customers for more effective marketing
  • The lowdown on Low Earth Orbiting Satellites and 5G
  • Connecting to other carriers via IP trunks
  • The 411 on access billing and robocall mitigation
  • Knowing (and using) the value of your company

Keep Your Eyes Open for More Information Soon!

Right now, block off April 28th & 29th from 1 p.m. – 5 p.m. Eastern (12 p.m. – 4 p.m. Central) on your calendar and look for a registration announcement in a few weeks. If you have any questions before registration opens, you can contact Leah Yoakum at 301-459-7590.

FCC Delivers Holiday Gift of Reduced Broadband Testing Locations

2021-11-02T13:21:19-04:00December 23, 2020|e-Lerts|

In the days leading up to the Christmas holiday, and just over a week before some companies begin their year of broadband measurements pre-testing, the FCC released two items pertaining to broadband testing: a clarification order about end-of-term non-compliance and a waiver on its own motion to permit the 2021 pre-testing group to only pre-test 70% of their USAC-selected random location samples. Even with the release of these two items, nothing should prevent A-CAM I, Rural Broadband Experiment, and Alaska Plan companies from beginning their pre-testing in January. As a reminder, the Performance Measures Module in USAC’s E-File is now open to upload your subscriber data and produce your random location sample.

In the Clarification Order (released December 18), the FCC addresses questions regarding compliance calculations and end-of-term support recovery in order to give greater certainty to companies that have to do broadband testing as a condition of receiving high-cost USF support. The FCC clarified that if a company is not in compliance with the performance requirements at the end of the support term, “it is only then that a carrier may be subjected to final performance compliance withholdings.” Put another way, model-based funding recipients may get funding for 10 years even though their final buildout milestone is at the end of the sixth year. The performance testing must occur throughout the entire funding duration, but a company would only be subject to withholding at the end of that period if the performance measurements do not meet the speed and latency standards. Furthermore, if a company is not in compliance at the end of the support term, it is permitted an extra year to make adjustments and come into compliance. Finally, the clarification order noted that funded providers participating in multiple programs or subject to multiple speed tier tests will be rated in compliance or not in compliance for each program, state, and speed tier. For example, if a company gets A-CAM I and CAF II Auction 903 support, and it fails to meet the performance standards for the CAF II areas, it will not see any impact to the A-CAM I area. If a company has deployment milestones for 25/3 and 4/1 Mbps and fails the performance standards for the 25/3 tier, it will have support withheld based on the percentage of funding assigned to the 25/3 tier only—not the 4/1.

In the Order that the Wireline Competition Bureau granted on its own motion (released December 21), it acknowledged the additional hardships created by the COVID-19 pandemic that are preventing some companies from accessing testing equipment and installing it at customer locations. The Order noted that NTCA has reported challenges obtaining equipment due to supply-chain issues and difficulties accessing customer premises to install equipment. The FCC agreed that it was appropriate to at least modify the sample size but continue forward with the pre-testing year due to its importance in getting providers prepared for meeting their required performance standards. For the A-CAM I/RBE/Alaska Plan 2021 pre-testing group, the FCC will require carriers to pre-test and file results for at least 70% of their USAC-selected random location sample for each required speed tier. If the required testing size is 50 locations, the company must pre-test at least 35 of those 50 random locations. The Bureau had also waived some requirements for the CAF Phase II recipients who began pre-testing in 2020.

JSI reminds companies in the 2021 pre-testing group that USAC’s Performance Measures Module (PMM) is now open. Companies that begin pre-testing in 2021 should clean up their HUBB data and upload 2020 deployment data prior to going to the PMM. Once in the PMM, companies will generate their HUBB data and identify all active subscribers in each speed tier prior to generating the random samples. Then, companies can proceed with pre-testing of at least 70% of the random samples generated by the PMM.

If you have any questions about the performance measurement pre-testing requirements or process, please reach out to Valerie Wimer in the Maryland office at 301-459-7590.

FCC Opens Second 2020 E-Rate Funding Year Window

2021-04-05T14:59:51-04:00September 22, 2020|e-Lerts|

Other E-rate program waivers extended to year’s end

The FCC last week announced the opening of a second funding year 2020 filing window to allow schools to request additional E-rate funding specifically to address increased on-campus bandwidth needs. The second 2020 filing window will allow schools to purchase additional bandwidth to help with 1:1 student-to-device ratios in the classroom, live streaming to students at home, and it will expand the use of cloud-based educational tools and platforms. The second filing window opened on September 21 and will close on October 16, 2020.

During this expanded 2020 window, schools may only request E-rate discounts for additional on-campus Category One Internet access and/or data transmission services needed as a result of the COVID-19 pandemic. Because of the urgent need for these services, schools may submit FCC Form 471 during the second funding year 2020 application window requesting E-Rate discounts without initiating a new competitive bidding process for the requested services if: (1) the school or library has already submitted a Form 470 application for the services; (2) the school or library has received a Funding Commitment Decision Letter approving a funding year 2020 funding request for eligible Category One Internet access and/or data transmission services from that Form 470; and (3) it requests additional E-Rate discounts during the second application window to purchase additional bandwidth through the existing service provider or a new one.

For the second funding year 2020 window only, USAC will accept bids where the price per megabit is the same or less than the original contract. If the price per megabit is higher, USAC will limit the funding to the price per megabit in the original contract.

Gift Rule and 30-Day Extension Requests Extended
As well, the FCC has extended the waiver of the E-rate program gift rules through December 31, 2020:

  • During the extended waiver period, service providers can continue to offer, and E-rate program participants can continue to solicit or accept, broadband connections, Wi-Fi hotspots and other devices, networking gear, system upgrades, or other things of value that could help students, teachers, and patrons while schools and libraries prepare for extended remote learning and remain fully or partially closed as a direct result of COVID-19.
  • In addition, service providers may offer, and schools and libraries may solicit or accept, gifts of additional bandwidth through December 31 to meet the increased on-campus connectivity needs of schools and libraries in response to the pandemic without running afoul of the E-rate program rules.

The order also provides a 30-day extension, if program participants can provide an explanation of the need for the extension, for information requests issued between September 1 and December 31 related to the following:

  • Pending USAC appeals;
  • Invoices;
  • Pending FCC Form 500 requests, including service substitutions, Service Provider Identification Number (SPIN) changes, or funding request cancellation requests;
  • Audits, including BCAP and PQA audits; and
  • PIA requests.

If you have any questions about the second 2020 funding window or the extended waivers on the E-rate program rules, please contact Chresanthe Staurulakis at 301-459-7590 or Terri DeLong at 512-338-0473.

Go to Top