December (the most wonderful time of the year) often carries with it a sense of retrospection.  We start looking back on the year that was, compiling “Best of” lists, tying up loose ends, getting those last donations and expenses in under the wire. Of course, there’s also plenty of forward-looking at what the new year might bring.  This post falls into the latter category and it’s looking at the wonderful FCC-related deadlines that will await us as we return from our holiday breaks.

Please note that the list is NOT exclusive, so there may be others. For help meeting these deadlines or answering questions about any that may not be listed here, please contact FHH at 703-812-0400.

Broadcast Deadlines:

January 10, 2019 –  Repack Transition Progress Report – All full-power and Class A television stations repacked as a result of the incentive auction, other than those in Phase 1 that have completed the repack process, must file a report in LMS to detail their progress toward completion of the transition.

Children’s Television Programming Reports – For all commercial television and Class A television stations, the fourth quarter 2018 children’s television programming reports must be filed electronically with the Commission.  These reports are usually automatically transferred by the FCC to the station’s online public inspection file, but we recommend that stations double-check that this has occurred, as ultimate responsibility for compliance lies with the station.  Please note that the required use of the Licensing and Management System for the children’s reports means that you should have the licensee FRN and password at hand before you start the process.

Commercial Compliance Certifications – For all commercial television and Class A television stations, a certification of compliance with the limits on commercials during programming for children ages 12 and under, or other evidence to substantiate compliance with those limits, must be uploaded to the online public inspection file.

Website Compliance Information – Television and Class A television station licensees must upload and retain in their online public inspection files records sufficient to substantiate a certification of compliance with the restrictions on display of website addresses during programming directed to children ages 12 and under.

Issues/Programs Lists – For all commercial and noncommercial radio, television, and Class A television stations, a listing of each station’s most significant treatment of community issues during the past quarter must be placed in the station’s online public inspection file.  The list should include a brief narrative describing the issues covered and the programs which provided the coverage, with information concerning the time, date, duration, and title of each program.

Class A Television Continuing Eligibility Documentation – The Commission requires that all Class A Television stations maintain in their online public inspection files documentation sufficient to demonstrate that the station is continuing to meet the eligibility requirements of broadcasting at least 18 hours per day and broadcasting an average of at least three hours per week of locally produced programming.  While the Commission has given no guidance as to what this documentation must include or when it must beVOIPadded to the public file, we believe that a quarterly certification which states that the station continues to broadcast at least 18 hours per day, that it broadcasts on average at least three hours per week of locally produced programming, and lists the titles of such locally produced programs should be sufficient.

February 1, 2019 – EEO Public File Reports – All radio and television stations with five (5) or more full-time employees located in Arkansas, Kansas, Louisiana, Mississippi, Nebraska, New Jersey, New York, and Oklahoma must upload EEO Public File Reports to their online public inspection files. For all stations with websites, the report must be posted there as well. Per announced FCC policy, the reporting period may end ten days before the report is due, and the reporting period for the next year will begin on the following day.

EEO Mid-Term Reports – All television stations with five (5) or more full-time employees in New Jersey or New York must electronically file a mid-term EEO report on FCC Form 397, with the last two EEO public file reports attached.

Telecom Deadlines: 

January 15, 2019 – Hearing Aid Compatibility Status Reporting (FCC Form 655) ELIMINATED. On November 16, 2018 the FCC streamlined its hearing aid compatibility rules. Among other changes, the Commission eliminated Form 655 filing requirements for wireless service providers. In its place, the FCC adopted a certification process. Starting in 2020, the annual certifications will be due January 15 each year. For 2019, the FCC will notify providers when the certifications are due once the streamlined rules take effect. Providers need not file a hearing aid compatibility status report (Form 655) on January 15, 2019.

February 1, 2019Quarterly Telecommunications Reporting Worksheet (FCC Form 499-Q) – FCC rules require telecommunications carriers and interconnected VoIP providers to file quarterly revenue statements reporting historical revenue for the prior quarter and projecting revenue for the next quarter.  The projected revenue is used to calculate contributions to the Universal Service Fund (USF) for high cost, rural, insular and tribal areas as well as to support telecommunications services for schools, libraries and rural health care providers.  USF assessments are billed monthly.

Rural Call Completion Reporting (FCC Form 480) ELIMINATED. On April 17, 2018, the FCC released on Order removing the rural call completion reporting requirements. Starting with the May 1, 2018 rural call completion report, covered providers (i.e. certain long-distance voice providers ) have no longer been required to file FCC Form 480 on a quarterly basis. Therefore, there is no rural call completion reporting requirement for February 1, 2019.

Numbering Resource Utilization Forecast (NRUF) (FCC Form 502) – Twice a year, service providers with numbers from the North American Numbering Plan Administrator (NANPA), a Pooling Administrator, or another telecommunications carrier must file a numbering resource utilization forecast. Subscriber toll-free numbers are not included in the report. Interconnected VoIP providers are subject to the reporting requirement along with other service providers who receive NANPA numbers, such as wireless carriers, paging companies, ILECs, and CLECs. The next biennial reporting deadline is February 1, 2019.

February 14, 2019Quarterly PIU Certification – Prepaid calling card providers must file a certification stating that it is making the required Universal Service Fund contributions. The certification must be signed by an officer of the company under penalty of perjury and can be filed electronically using the FCC’s ECFS system. The Quarterly PIU Certification due February 14, 2019 will cover the Fourth Quarter of 2018 (October 1, 2018 through December 31, 2018).