The FCC recently solicited comments on the Rolka Loube Saltzer Associates (RLSA) annual payment formula and fund size estimate for the Interstate Telecommunications Relay Service (TRS) Fund. This year RSLA recommends that the FCC adopt a TRS contribution factor of 0.01635 (1.635%). Last year’s TRS contribution factor was 0.01219 (1.219%).
Since the proposed contribution factor varies, the FCC must determine the appropriate contribution mechanism before the final rate can be set. We anticipate the FCC will issue an order in late May or early June approving a final TRS contribution factor. Following approval, RSLA will issue invoices for carrier contributions to the TRS Fund by late June/early July based on the amounts reported in FCC Form 499-A.
The annual TRS Fund support payments must be paid by all interstate wireline telecommunications carriers and interconnected VoIP service providers. RSLA will apply the proposed contribution factor against all contributors’ interstate and international telecommunications revenue, as reported in the recent FCC Form 499-A filed April 1st. There is no de minimis exemption for TRS contribution and filers that qualify for the FCC’s de minimis exemption to the USF must still pay TRS fees.
Details and Important Reminders
- Duty to Pay
A regulated carrier’s obligation to pay TRS support contributions exists by virtue of having provided interstate or international telecommunications services or interconnected VoIP services during the past year, regardless of whether you receive an invoice from RSLA.
- Minimum Payment
The minimum annual contribution to the TRS Fund continues at $25. The minimum contribution is owed by all carriers holding Filer IDs during the past year, even if the carrier reported no revenue in its annual Form 499-A.
- Terms of Payment
Carriers with annual TRS funding obligations exceeding $1,200 may opt to pay in twelve equal monthly installments, but must immediately contact RSLA upon receipt of their annual RSLA TRS invoice to initiate monthly billing. Thereafter, invoices will be issued to monthly contributors with payments due the 26th of each month.
- Late Filing Penalty
RSLA will assess a late filing penalty of $100 to any carrier filing FCC Form 499-A after the April 1st deadline.
Consequences of Non-Payment/Delinquency
Any carrier who owes money to the interstate TRS Fund will be considered delinquent and in “red light status” if payment is not made by the due date reflected on the RSLA TRS invoice. Late payment charges will be applied to delinquent accounts not paid by the annual or monthly due dates. Furthermore, clients are reminded that if an annual contributor has not made its payment, including any late payment assessments, within 90 days of the RSLA TRS invoice due date, the delinquent amount will be transferred to the FCC pursuant to the Debt Collection Improvement Act of 1996. A monthly contributor whose payment is 90 days past due will also have its delinquent balance transferred to the FCC.