USAC Wrongly Told ETCs to Report Partial-Month Subscribers, Carriers Say
AT&T saw nothing but industry support on its appeal of a Universal Service Administrative Co. audit. AT&T disputes a USAC order that eligible telecommunications carriers must report partial or pro-rata dollars for USF Lifeline subscribers who left the Lifeline program within the month they joined. AT&T said it doesn’t need to provide the information because it has never asked USAC for partial or pro-rata support. In comments filed Wednesday, USTelecom, Qwest, the Independent Telephone and Telecommunications Alliance, Embarq and Sprint Nextel supported the appeal. No one opposed it.
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Qwest and Embarq don’t report partial-month subscriber data, the companies said. Neither do “many other ETCs,” said Embarq. That’s because it’s “extraordinarily burdensome” for ETCs to track, said USTelecom. A carrier would have to pull the data from its billing system daily “or even more frequently,” it said.
It would be difficult to find a more efficient tracking system, ITTA said. “For example, carriers may utilize multiple billing cycles that are calibrated to bill or credit consumers for service one month in advance,” it said. But an ITTA survey “revealed that although these systems credit appropriately for mid-month LifeLine entry or exit, the ability to cull all bills and sum the total of partial month LifeLine data would be contrary to the design specifications of those programs.” Reprogramming would be “costly,” it said.
No law mandates reporting of partial-month Lifeline subscribers, USTelecom said. The form says “If claiming partial or pro-rata dollars, check the box,” it said. “Common sense dictates that if there is a box to be checked, checking the box is optional.” Form instructions aside, FCC history confirms reporting is optional, it said. In 2004, the FCC said it wanted to amend Lifeline reporting forms to require ETCs to report the information but never followed through, it said. “The fact that the Commission felt it needed to announce that it contemplated a change to the form makes clear that any change was a substantive revision.”
Carriers have no incentive to choose not to report partial-month subscribers, USTelecom said. “There is no reason for a carrier to discourage people from subscribing to LifeLine service since the carrier is fully reimbursed for the discounted rate.”