March 23: The Day that Shared Services Agreements Became Part of the Public File Family

As of March 23, the FCC rule requiring the inclusion in the online public file of TV stations’ “shared services agreements” (SSAs) is now in effect. Under the

Paperwork Reduction Act, the effectiveness of the SSA filing requirement had to wait for approval by the Office of Management and Budget, which has now occurred. This means that any TV station that has executed an SSA prior to the effective date will have to include a copy of their SSA in their online public inspection file within 180 days after the March 23 effective date (by September 19, 2018). Those SSAs that are executed after the effective date will also need to be placed in the station’s online public file “in a timely fashion.” Either way, stations will have to upload their SSAs to a folder entitled, “Shared Service Agreements.”

This was all adopted in the 2016 FCC Ownership Order (which we wrote about here) and upheld on reconsideration in 2017. SSAs allow independently owned stations in local markets across the country to combine forces by sharing operations, staff, and facilities. This definition is broad and includes agreements for sharing any “station-related services.” If you’re unclear about whether your SSA needs to be included in your online public file, contact us at (703) 812-0400.