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Reminder: April 1st Filing Deadlines for FCC Form 499-A and Accessibility Recordkeeping Certificates

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Reminder: April 1st Filing Deadlines for FCC Form 499-A and Accessibility Recordkeeping Certificates

Companies that provide telecommunications and Voice over Internet Protocol (VoIP) service are reminded that FCC Form 499-A is due Friday, April 1, 2016. FCC Form 499-A reports annual revenue to the Universal Service Administrative Company (USAC) and the Federal Communications Commission (FCC), as well as other fund administrators. This form must be filed by all interstate telecommunications carriers, interconnected VoIP providers, providers of interstate telecommunications that offer service for a fee on a non-common carrier basis (including stand-alone audio bridging companies), and payphone providers that are aggregators.
 
In addition, non-interconnected VoIP providers are required to file this form for the assessment of fees to support the Telecommunications Relay System (TRS).
 
The revenues reported on Form 499-A provide the basis for true-up of a company’s Universal Service contributions for the previous calendar year and serve as the basis for assessing annual fees for the TRS, the Local Number Portability (LNP) fund, the North American Numbering Plan Administration fund, and the FCC’s annual fee.
 
FCC Form 499-A must be filed electronically with the USAC. The filing interface can be found here.
 
Instructions for completing the FCC Form 499-A can be found here.
 
Certificates regarding disabled persons’ access to services are also due Friday, April 1, 2016. Telecommunications carriers, equipment manufacturers, Voice over Internet Protocol (VoIP) providers, including non-interconnected VoIP providers, wireless carriers, and advanced communications service providers are required to file a certificate with the FCC stating that they maintain records of any and all efforts undertaken to ensure their products and services are accessible to those with disabilities. Specifically, companies must maintain records of:

  • Their efforts to consult with individuals with disabilities;
  • Descriptions of the accessibility features of its products and services; and
  • Information about the compatibility of these products and services with peripheral devices or other equipment typically used to gain access to the company’s services, such as hearing aids.

The certificate must identify both a contact within the company who is authorized to resolve complaints, as well as an agent to receive any informal complaints that may be received by the FCC regarding the company alleging violations of the Commission’s accessibility rules, or Sections 255, 716, and 718 of the Communications Act of 1934, as amended (the Act). These sections of the Act requires providers to ensure that their services and equipment are accessible by the disabled, including that any Internet browsers included on mobile telephones are accessible by those who are visually disabled (unless doing so is not achievable), and to maintain the records described above. In addition, the certificate must be supported by a declaration or affidavit signed under the penalty of perjury by an officer of the company who has personal knowledge of the company’s recordkeeping policies and procedures.
 
The FCC has established a filing portal for this certificate, which can be found here. More information can be found in the Public Notice found here. (DA 16-248)
 
For further information, please contact Katherine Barker Marshall or the Arent Fox professional who handles your matters.

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