FCC Seeks Comment on the Future of USF

2021-12-20T12:37:45-05:00December 20, 2021|e-Lerts|

Clients Encouraged to Provide Input and/or File Company-Specific Comments

The FCC is inviting public comment on the future of federal Universal Service Fund (USF) programs. The FCC plans to use these comments for a report it must submit to Congress by August 12, 2022, on its options “for improving its effectiveness in achieving the universal service goals for broadband” as part of the broadband provisions in the Infrastructure Investment and Jobs Act (IIJA). Last week’s Notice of Inquiry (NOI) set deadlines of January 18, 2022, for comments and January 31, 2022, for reply comments.

JSI plans to file comments in response to the NOI, with particular focus on the High-Cost program (Legacy Rate-of-Return, A-CAM I and II, and reverse auction support including the Rural Digital Opportunities Fund (RDOF) Phase II support). We seek client input on the topics outlined below, as well as any others specified in the NOI. For example, the NOI seeks comments on how best to integrate USF with ReConnect and the new funding programs established by the IIJA. We would like to hear from clients with multiple funding sources whether streamlining and aligning reporting and other compliance requirements with these programs and USF could be beneficial or whether such alignment could add additional burdens and requirements to some funding mechanisms.

We also encourage clients to file company-specific comments in which they can provide the FCC with their own proposals for the future of USF. Given that the NOI seeks data on potential changes to all programs, clients should consider filing comments not only on potential changes to the High-Cost program, but also changes to other USF programs. For example, several clients have expressed frustration with the requirements imposed by Lifeline’s Representative Accountability Database (RAD) process. Others are concerned with overbuilding that takes place through the E-rate program. Because the NOI seeks comment on potential comprehensive reform to all of these programs, now is the time to raise any concerns along with viable alternatives. JSI’s seasoned advocacy experts are ready to provide strategic advice and assist in drafting company-specific comments. Due to the FCC’s tight deadlines for commenting in this proceeding, we ask that clients interested in JSI’s help contact us no later than January 7, 2022.

High-Cost USF
A major concern among our ILEC Rate-of-Return clients is the continuation of USF to support both the deployment and maintenance of fiber networks in rural America. The NOI highlights the billions of dollars that will be available in coming years to deploy broadband in unserved and underserved locations through the programs initiated by the IIJA. Here, the NOI seeks comment more broadly on what changes should be made to the High-Cost program considering the influx of newly authorized federal funding. The NOI asks for comment on the role the High-Cost program should have in the future given the evolving level of universal service, the type of data to collect from program recipients, and how to collect that data.

Next, the NOI discusses the newly authorized Broadband Equity, Access, and Deployment (BEAD) program to be run by the National Telecommunications & Information Administration that will allocate $42.45 billion to states for broadband infrastructure grants and asks the following questions:

  • Should the FCC modify the High-Cost program to further support ongoing operating and maintenance costs of recently constructed broadband facilities funded by BEAD to ensure that rates remain reasonably comparable?
  • Should the Commission coordinate with the BEAD program to ensure that newly constructed networks have ongoing support?
  • At what point would USF support be necessary, if at all?
  • How should the FCC approach next steps for the RDOF program or any successor program?
  • In light of the 100/20 Mbps service standard required in BEAD, should the FCC reconsider its service requirements for future High-Cost support?

The NOI also asks for input regarding the best way to allocate funding in the future, including the potential use of reverse auctions, and whether there are “other incentive-based, competitive methods for allocating funding that would be effective and efficient.”

Additionally, the NOI asks what other congressional action could help the FCC accomplish its universal service goals. Specifically, the NOI asks:

If the High-Cost program were to place additional emphasis on supporting operating costs in light of the influx of funding for capital expenditures, are the existing programs a sufficient vehicle to distribute that support? If not, are there statutory changes that would help the Commission shift additional support to operating and maintenance costs for deployed networks? Likewise, if the focus of the BEAD Program funding is on fixed broadband deployment, would congressional action be necessary to shift the focus of the High-Cost program, for example, to support mobile broadband? Should Congress provide additional authority regarding the use of auctions, or price models, to allocate funding for operating costs?

These questions certainly raise the possibility that the FCC will not maintain the status quo for High-Cost USF. Accordingly, it is up to each rural broadband provider – and us collectively – to engage in a robust advocacy effort to ensure that any changes made to the USF continue to allow for sufficient and predicable funding for the provision, maintenance, and expansion of fiber-based networks in the rural communities in which these companies serve.

Other Programs and Contribution Factor
For Lifeline, the NOI seeks comment on whether any changes in the program should be made to best coordinate it with the Affordable Connectivity Program (ACP), including any data that should be collected. Similar questions are raised regarding E-rate and Rural Health Care programs.

The NOI also observes the up and down nature of the quarterly USF contribution factor and seeks comment on ways to increase the stability of the factor. It also requests “general comment” as to the FCC’s USF priorities.

Please contact Guy Benson or John Kuykendall in our Maryland office at 301-459-7590 with any input you may have for JSI’s comments, if you would like assistance in filing individual comments, or if you have any questions about the NOI.

JSI’s 2021 Financial Seminars

2021-11-02T13:08:35-04:00July 15, 2021|Archived Events|

2021 Financial Seminars

JSI’s Part 32 & Part 64 Accounting Seminar provides a detailed review and explanation of the FCC’s Part 32 and Part 64 accounting principles and applications. JSI staff discuss specific issues of the FCC’s accounting procedures, including the “allowable” expenses for USF and NECA purposes, as well as increased regulatory scrutiny of the Part 64 allocation mechanisms. This seminar also covers the ongoing USAC and NECA audits and reviews. And new for 2021, we also covered how to account for broadband grants and COVID-19 relief efforts your company may have received.

Topics:

  • Part 32/64 Introduction
  • Part 64 and elements of the Cost Allocation Manual (CAM)
  • NECA & USAC audits
  • Rate base
  • Operating revenues
  • Expenses
  • Taxes
  • Accounting for FCC and other grants
  • Accounting issues related to the Federal PPP program
  • Changes to Part 32 Accounting to conform to GAAP accounting

Learning Objectives: At the end of the seminar, attendees are be able to:

  • Understand concepts and principles of the FCC Part 32 accounting rules
  • Determine sources and drivers of primary regulated revenue streams, including USF and NECA Settlements
  • Understand the hierarchy of Cost Allocations contained within Part 64 of the FCC’s rules
  • Compare and contrast valuation of transactions between affiliated entities and non-affiliated entities
  • List the primary areas of focus of USAC OIG and other audit processes

Attendees receive electronic copies of the seminar materials and JSI’s Accounting Manual for the Independent Telephone Company. The seminar includes lecture, group discussion, and sample accounting problems. Everyone is encouraged to participate.

This is a basic level course for accountants, bookkeepers, and auditors, as well as telco staff looking to gain a better understanding of telecommunications and FCC accounting requirements. Attendees are eligible for 8 hours of CPE credit (see below for more information).

CPE Information

CPE Credits & Information: This course offers 8 hours of Accounting CPE credit. For those interested in earning CPE credits, you will be required to respond to a series of engagement activities throughout the seminar sessions. The number of credits you receive will be based on the engagement activities you complete, as well as the amount of time spent in the meeting. The Accounting Seminar is considered an “Overview” program through NASBA classification. No prerequisites or advanced preparation is required for this course.

Delivery Method: All JSI seminars are “group-live” sessions as defined by NASBA.

CPE Sponsorship Information: JSI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Questions?

For questions or complaints about the seminar, registration, or program cancellation policies, please contact Leah Yoakum, Seminar Administrator, at 301-459-7590.

The FCC’s never-ending changes to the universal service and access charge regimes continue to add levels of complexity to the cost settlement system and significantly threaten your settlements and revenue streams. Understanding the allocation of costs and maximizing cost recovery, especially with the current pressures on your revenue streams, is critical to continued success. JSI’s Separations & Access Seminar focuses on responding to today’s broadband network and services, in addition to its usual assessment of cost settlements, regulated and non-regulated allocations, jurisdictional categorizations, access procedures, and intercarrier compensation. The 2021 seminar included the continued reform of Universal Service funding mechanisms; data reporting and compliance for A-CAM electors; special access/BDS issues; using operational and financial data to manage for success; and federal and state grants and loans issues and opportunities.

Topics:

  1. Separations concepts and principles
  2. Settlements and compensation
  3. Accounts affecting the separations process:
    • Part 32, USoA
    • Part 64
    • Regulated / non-regulated allocations
  4. NECA cost issues
  5. NECA & USAC audits
  6. A review of the cost study and cost allocation process, including the analysis of the telephone network, operating expenses and other inputs
  7. Broadband
    • Potential policy shifts
    • Current and proposed settlements
  8. Part 69 – Access Charges and the Recovery of Interstate Costs
  9. Federal Universal Service Funding
    • Overview of the categories
    • Current and proposed policy shifts
  10. Emerging trends and issues
  11. Projecting future revenue streams associated with Universal Service and FCC access charges

Learning objectives:
At the end of the seminar, attendees will be able to:

  • Understand how changes in FCC rules impact separations and settlements
  • Compare and contrast the FCC Part 36 Separations rules for various Part 32 Accounting groups
  • Understand the FCC’s High Cost Support Mechanisms, including A-CAM and Legacy programs and potential future changes
  • Identify the primary drivers of Federal High Cost Loop and other USF mechanisms
  • Define the steps involved in determining the Interstate Revenue Requirement
  • Analyze regulated revenue sources for purposes of budgeting and forecasting of future results

This is a basic level course for separations, settlement, and access personnel new to this area or company, or with responsibility for financial or operational issues. Other management, financial, and regulatory staff who rely on or make use of separations and access data will also benefit from this seminar. Attendees are eligible for 20 hours of CPE credit (see below for more information).

CPE Information

CPE Credits & Information: This course offers 20 hours of Specialized Knowledge CPE credit. For those interested in earning CPE credits, you will be required to respond to a series of engagement activities throughout the seminar sessions. The number of credits you receive will be based on the engagement activities you complete, as well as the amount of time spent in the meeting. The Accounting Seminar is considered an “Overview” program through NASBA classification. No prerequisites or advanced preparation is required for this course.

Delivery Method: All JSI seminars are “group-live” sessions as defined by NASBA.

CPE Sponsorship Information: JSI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org.

Questions?

For questions or complaints about the seminar, registration, or program cancellation policies, please contact Leah Yoakum, Seminar Administrator, at 301-459-7590.

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.

Recording Available for JSI’s 2021 Management Seminar

2021-11-02T13:13:26-04:00April 29, 2021|Archived Events, News|

Purchase the Management Seminar Recording

Did you miss the live seminar? Purchase the recording!

If you missed the live webcast of JSI’s Management Seminar, you didn’t miss out entirely. We recorded the live event and that recording is available for purchase for $695. You’ll receive all of the seminar presentation slides and the recordings from both days of the seminar. And there’s no limit on how many times you or your staff can view the recording online.

If you are interested in purchasing the recording, please email Leah Yoakum in our Maryland office or give her a call at 301-459-7590.

This last year further amplified the need for our industry to keep pushing forward to provide rural America with top-notch broadband. We’ve seen billions of dollars at both the state and federal level poured into connecting rural communities, but as we know, money alone won’t solve the problem. It became more important than ever for us to come together, even if it wasn’t feasible to meet in person, to discuss not only how to bring broadband to our customers, but to ensure that our companies are successful while doing it.

The theme of our 2021 Management Seminar was “Succeeding in a Broadband World.” Among the hot topics we discussed were:

  • Post-RDOF auction market assessments and strategies as unproven competitors creep ever closer;
  • Emerging broadband technologies including 5G, LEOS, and IP trunking and what your broadband network might look like in 2030;
  • Prospects of future USF funding, particularly what we expect from the 2024 review and the odds of an A-CAM III;
  • Profiling your customers for better marketing results;
  • Mitigating cybersecurity risks and fighting back against robocallers;
  • The future of access billing; and
  • Why the time might be right to calculate the value of your company and its assets.

Learning Objectives:
At the end of the seminar, you will be able to:

  • Prepare for future competitive, technological and compliance developments
  • Plan for the network of tomorrow 
  • Grow your revenue through new services and initiatives
  • Set up your company for success in the next 5 to 10 years
  • Meet requirements due to changes to federal telecom policies
  • Anticipate other initiatives that might be heading your way

Even though our Management Seminar venue was different in 2021, our goal remained the same – to showcase the financial, management, regulatory, and technical information you’ll need to remain successful in our evolving industry. Our seminar as always was led by some of the industry’s most respected experts, including JSI President Steve Meltzer; Vice Presidents John Kuykendall, Dave Lewis, Jamie Miller, Bhavini Sokhey, and Valerie Wimer; Director of Economics & Policy Douglas Meredith; Director of Network Engineering Milan Todorović; and Director of Engineering Operations Aaron Stroman, P.E.

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.

Webinar: Managing Your Universal Service Contributions on Form 499-A

2020-12-15T14:47:58-05:00December 15, 2020|Webinar Recordings|

With the 4Q 2020 federal Universal Service contribution level at 27.1% and increasing each quarter (it will be 31.8% 1Q 2021), it is important that you fully understand how to calculate your payment. Not only do you want to ensure you’re complying with the FCC’s rules, but you also want to be certain that your company is not paying more than is necessary when filing your Form 499-A.

JSI’s USF expert Brian Sullivan, along with Ryan Denzel and Dixie Lucabaugh, reviewed FCC Form 499-A requirements and major contribution sources to clarify your company’s obligations during a recent webinar. They discussed:

  • Competitive pricing implications of passing through USF contribution requirements to customers;
  • Cost recovery options and requirements;
  • Documents you need to gather and maintain; and
  • Lessons learned from recent USAC reviews and audits focused on USF contributions and Form 499-A.

Arm your regulatory, financial, and sales staff with strategies and options as they close out the 2020 books and begin the 2021 financial year. Future USF payments and true-ups are based on calendar year 2020 revenues so now is the time to take a close look at your contributions.

A recording of the webinar is available for $249. Contact Brenda Cordwell in the Maryland office at 240-556-1295 if you’d like to purchase the recording of this webinar.

JSI To File Comments in Telephone Access Charge Proceeding

2020-06-25T11:24:15-04:00June 25, 2020|e-Lerts|

Clients Encouraged to Provide Input

In April, the FCC released a Notice of Proposed Rulemaking (NPRM) proposing to eliminate the ability of telecom carriers to separately list “telephone access charges” on customers’ bills. These charges include: Subscriber Line Charge (SLC), Access Recovery Charge (ARC), Presubscribed Interexchange Carrier Charge, Line Port Charge, and Special Access Surcharge. Comments on the proposed changes are due July 6 and replies are due August 4. JSI will be filing comments in this proceeding and welcomes your input.

While the FCC currently mandates that these charges be listed on customer bills as part of its “ex ante” price regulation and tariffing to ensure that prices are just and reasonable, in the NPRM, the FCC proposes to eliminate this pricing regulation and require mandatory “detariffing” of these charges. The proposed changes would also modify the FCC’s “truth-in-billing” rules to explicitly prohibit all carriers from assessing any separate Telephone Access Charges on customers’ bills after those charges are deregulated and detariffed. According to the FCC, these charges are difficult to understand and the “opaque” way they are sometimes described on telephone bills “reduces consumers’ ability to compare the cost of different voice offerings.”

If the FCC proceeds as proposed in the NPRM, these changes could impact local rates if these Telephone Access Charges are moved into that rate, assuming state regulations allow for the local rates to change. Most notably, for purposes of calculating contributions to the Universal Service Fund (USF) and other federal programs, the NPRM proposes adopting a 25% “safe harbor” for local voice services provided by local exchange carriers, while allowing an option of submitting a traffic study to establish a different allocation. If this were enacted, every local exchange carrier, including CLECs and A-CAM carriers, would be required to contribute to USF based on a percentage of its local revenue regardless of whether or not the company currently assesses a SLC, ARC or other Telephone Access Charges. This percentage would also apply to contributions to other programs including the Interstate Telecommunications Relay Service Fund, Local Number Portability Administration, and North American Numbering Plan Administration.

In its comments, JSI will oppose this proposal. We welcome input from clients as to whether we should support eliminating these line item charges and if so, alternative ways for the FCC to assess its universal service contributions. Specifically, we would like to know the extent to which rural carriers are at a marketing disadvantage because they have to charge a SLC and ARC and assess the federal universal service charge for those line items while their VoIP competitors do not. If this is the case for your company and you would like these line items to be eliminated, we will need to consider alternative ways to ensure that the contributions to the universal service fund continue.

Please contact Brian Sullivan (301-459-7590), Ryan Denzel (651-452-2660) or Douglas Meredith (801-294-4576) with concerns or other suggestions that you may have regarding the FCC’s NPRM so that we can include those in our comments.

All ETCs Must File Reports Regarding Banned Equipment in Their Networks

2020-04-02T12:37:37-04:00February 27, 2020|e-Lerts|

Update: The FCC has delayed the deadline to May 22, 2020, because of the COVID-19 pandemic.

In a Public Notice released yesterday, the FCC initiated a one-time filing for all ILECs and other eligible telecommunications carriers (ETCs) to report the extent to which their networks contain or use potentially “prohibited” equipment or services. The equipment or services are those provided by Huawei Technologies Company or ZTE Corporation or their subsidiaries, parents or affiliates. The FCC banned carriers last fall from using universal service funds to pay for any equipment manufactured by the two Chinese firms citing national security interests.

The deadline for making the filing is April 22 May 22, 2020, and must be submitted using the FCC’s portal at www.fcc.gov/supplychain.

If your company uses equipment or services by either of these companies, you will need to identify the equipment and services, the costs associated with purchasing and/or installing the equipment and services, and the costs associated with removing and replacing the equipment and services. If your company does not have such equipment and services, you must still make the filing and report that fact to the FCC.

Companies that use JSI’s Continuing Property Records (CPR) services will be contacted by their CPR representatives to assist with this filing. If you are not a JSI CPR client but have this equipment and would like our assistance in making the filing, please contact Denise Whittington in our CPR department. Denise can assist in identifying the equipment, determining the cost estimations, and meeting the filing requirements. If your company does not have this equipment but you’d like help with the filing, please contact Cindy Neugebauer in our Texas office at 512-338-0473.

Changes Coming to USAC Program Web Portal Access Dec. 4

2019-11-14T12:13:33-05:00November 14, 2019|e-Lerts|

Service providers will see increased security steps and a single portal for most USF programs when signing into the Universal Service Administrative Company’s (USAC’s) website beginning December 4, 2019.

USAC is moving to a single online portal to access USF accounts for E-file, Lifeline, Rural Health Care, High Cost programs and E-rate. The E-rate forms, FCC Form 472 BEAR search, FCC Form 473, and FCC Form 474 will be available in the portal under one login. USAC also will add multifactor authentication (MFA) to the login process to tighten the site’s security. Next year in the spring, USAC will add the MFA process to the E-rate Productivity Center (EPC).

To prepare for this change, all USAC portal users should verify that the emails and passwords on all their current USF accounts are up to date and that each user has a unique login for each system which they access on USAC’s website. If your current login information is already up to date you are not required to do anything at this time. USAC will send your MFA login instructions on December 4, 2019.

If you would like assistance with this issue from one of JSI’s Lifeline team members, please contact Lans Chase in JSI’s Georgia office at 770-569-2105 or Lisa McLaughlin in JSI’s Texas office at 512-338-0473.

A-CAM II Offers Released with June 17 Decision Deadline (Delayed)

2019-06-06T15:48:17-04:00May 2, 2019|e-Lerts|

New 5-Year Buildout Obligations Announced for Carriers Remaining on Legacy  

Today, the FCC released the official Alternative Connect America Cost Model (A-CAM) II offer (v2.5.1) to rate-of-return carriers that are not already receiving model-based high-cost support. Carriers have until June 17, 2019 July 17, 2019, to indicate, on a state-by-state basis, if they choose to elect the model support. The A-CAM II 10-year term began January 1, 2019, despite the delay in releasing the offer. The FCC also released the new buildout obligations for companies that want to remain on Legacy high-cost support.

see our e-Lert: FCC Delays A-CAM II Election Deadline

A-CAM II Offers
Like the previous versions and the A-CAM I offer, v2.5.1 includes four reports. The first report (15.1) shows a list of state-level support for each eligible carrier, including the amount of annual support for 10 years and the total number of funded locations in each eligible census block. As a reminder, companies with multiple study areas are required to elect on a statewide basis. The second report (15.2) shows the specific broadband deployment obligations for each carrier, including “fully funded” and “capped” locations, the number of locations where 25/3 Mbps and 4/1 Mbps will be required, and the number of very high-cost locations subject to the reasonable request standard. The third report (15.3) shows the A-CAM II support amount, total eligible locations, fully funded, and capped locations by Tribal and non-Tribal component. Finally, the fourth report (15.4) lists the eligible census blocks.

The election letters must be submitted by June 17 July 17 to ConnectAmerica@fcc.gov. The letter must be signed by an officer of the company and confirm that the carrier elects support for the state(s) in which it serves, and the carrier must commit to satisfying the service obligations. JSI has a template letter for use in accepting the offer. Please contact us if you would like the template letter or if you’d like it customized for your company.

A-CAM II support will not be disbursed until after the FCC releases a Public Notice authorizing USAC to move forward with the disbursements. Carriers who elect A-CAM II must also exit the NECA common line pool before they can receive model-based support, and they are eligible to move their business data services (BDS) offerings to incentive regulation next year.

New 5-Year Plan
The FCC also released revised deployment obligations for rate-of-return carriers that are not currently receiving A-CAM I support, or the new “five-year plan” which companies can compare to the A-CAM II offer. This data shows how many 23/5 locations must be built out over the period of five years from 2019 to 2024. Companies that choose to stay on CAF-BLS can have their deployment obligations determined either by a calculation with the weighted average cost per loop or with the A-CAM II cost per location. It is our understanding that in the near future, USAC will be reaching out to obtain each company’s choice as the agency did for the previous five-year plan.

Assistance for Companies Considering A-CAM II
To assist clients in making the decision whether to remain Legacy or elect A-CAM II, JSI can provide detailed analysis which compares the support that a company would receive under A-CAM II with projected support under CAF-BLS for 10 years. Clients for which we have already performed this analysis should discuss with their JSI consultants any changes to their A-CAM II support offer that may have been revised in today’s offer, as it was based on Form 477 data that was also just released today. Additionally, JSI can produce maps showing the funded census blocks and location data and we can assist companies remaining on Legacy support with HUBB reporting related to the revised buildout requirements.

JSI will be covering A-CAM II in our Management Seminars which begin next week. We also plan to host a webinar prior to the election deadline to review implementation considerations, such as tariff-related matters, HUBB reporting, and ways to ensure your company can meet the buildout requirements.

Please contact your cost consultant, Steve Meltzer, Brian Sullivan, or John Kuykendall in JSI’s Maryland office at 301-459-7590 if you would like JSI to perform an in-depth A-CAM II analysis, would like our mapping service, or if you have any questions regarding the A-CAM II offer.

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