Telecom and VoIP Providers: Annual FCC Form 499-A Worksheet and CVAA Accessibility Certifications Due April 1, 2019

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By: Alex Simser

Telecommunications providers are subject to a panoply of federal regulations and reporting requirements under the Communications Act, including regulation and reporting regarding privacy and security, contributions for the support of universal access to telecommunications services, and accessibility for disabled persons. Two of those reporting requirements have filing deadlines on Monday, April 1st.

FCC Form 499-A Telecommunications Reporting Worksheet

With very limited exceptions, all United States telecommunications providers, including traditional wireline and wireless telecommunications providers, VoIP providers, prepaid calling card companies, and satellite service providers must hold a 499 Filer ID and file Form 499-A with the Universal Service Administrative Company (USAC) on an annual basis by the April 1st filing deadline. The form is used to report telecommunications revenues for purposes of determining a provider’s required contributions to the Universal Service Fund (USF), as well as the Local Number Portability Administration (LNPA), North American Numbering Plan Administration (NANPA) and TRS funds.

Note that even telecommunications resellers and providers whose revenues are de minimis must file.

The FCC Form 499-A must be submitted through USAC’s E-File system, available at https://www.usac.org/about/tools/e-file.aspx/.

21st Century Communications and Video Accessibility Act (CVAA) Recordkeeping Compliance Certification and Contact Information Reporting

Telecommunications service providers, providers of advanced communications services (ACS), including electronic messaging providers, video conferencing providers, interconnected VoIP providers, and equipment manufacturers required to comply with Sections 255, 716 and 718 of the Communications Act must file the recordkeeping compliance certification on an annual basis by the April 1st filing deadline. The certification must state that the company has established operating procedures adequate to ensure compliance with the FCC’s accessibility recordkeeping rules and must be supported with an affidavit or declaration under penalty of perjury, signed by an authorized officer of the company. The certification must also include contact information for consumers to report accessibility complaints and contact information for the company’s designated agent for service.

Note that, for the first time, video game software developers that were previously exempt are now required to comply.

The certification must be submitted through the FCC’s online filing system, available at https://apps.fcc.gov/rccci-registry/login!input.action.

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