FCC to KidVid filers: Number, please – and password, too!

It’s that time of the year again – the end of a quarter, when commercial television stations must file Children’s Programming Reports (Form 398) with the FCC. They’re due next Tuesday (two days later than usual, thanks to Columbus Day). But heads up, all you KidVid reporters, there’s something new this time around: folks filing a Form 398 must now provide their FCC Registration Number (FRN) and password. With the reports due soon, filers (particularly those who may be inclined to put things off to the last minute) should take appropriate steps to have their FRN and password handy before trying to file.

The new FRN requirement doesn’t appear in the form itself, or in the on-line “Official Form 398 instructions” linked off the FCC’s KidVid page. In fact, unless you’ve tried to file a form this quarter – or happened to visit the FCC’s main KidVid webpage lately (what, you don’t routinely pop in there every couple of weeks?) – you can be forgiven for not knowing about this requirement. That’s because the FCC doesn’t appear to have issued any conventional public notice regarding the change. The only notice we could find was a brief entry on the main KidVid web page (but not on the page where you prepare and submit the form itself). There it was reported that as of September 24, authentication using an FRN and password would be required. How come? Why, “to enhance the security and integrity of the KidVid database”, of course.

In these troubled times, you can’t be too sure about your KidVid data.

But we shouldn’t feel dissed just because the FCC didn’t give us any conventional public notice, because the Commission doesn’t appear to have notified the Office of Management and Budget (OMB) either. As readers may recall from the saga of the FCC’s recent changes to its ownership reports, changes to forms and other “information collections” generally must be approved by OMB before those changes can go into effect. While the Commission may have once again skipped a step by not submitting an FRN/information collection-related change to OMB, it’s unlikely that this new requirement will create major problems on that front. That’s because any licensee filing a Form 398 should already have an FRN. 

(As readers will recall, that wasn’t the case with the Form 323 ownership report requirement the FCC tried to blow past everybody last year and earlier this year. The revised 323 would have forced scads of individuals to cough up their social security numbers for the first time. That requirement has since been sidelined, thanks to the Court of Appeals and us here at FHH, among others. What, you hadn’t heard? That may be because the FCC didn’t bother to issue any notice about that development, either. So much for transparency.) 

In any event, anyone filing a children’s programming report should be sure to have their FRN and password handy.