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USF Traffic
Study - Get off Safe Harbor |
Do you want to
drastically reduce your USF contribution?
USF
Turnkey Traffic Study for wireless and VoIP Carriers
If you’re a wireless
carrier, MVNO, or Interconnected VoIP carrier there’s a great
likelihood you are over-contributing into the USF fund. Our USF PIU
Study can reduce that cost and save you hundreds of thousands of
dollars.
MVNO Case Study Example
Assume a customer base of 12,500 with an
average spend of $780. Here
are the results of an actual PIU study.
Using Safe Harbor
Using PIU Study
Interstate/Int’l Usage:
37.1%
16%
Yearly Revenue:
$9,750,000
$9,750,000
Multiplied by PIU:
37.1%
16%
USF Contribution:
$412,367
$177,840
You save: $234,527
Note: If your PIU is 25% you still save over
$134,000
The
2006 increase in the safe harbor by 30% (37.1 v. 28.5) wiped out much
of the benefit safe harbor offered, replacing it with a revenue drain.
It’s difficult to pass this along to your wireless customers,
and if you did you would likely suffer churn.
So why continue?
Using
statistical analysis that satisfies both the FCC’s mandated 95%
confidence and 1% error rate, our experts will determine the lowest
USF contribution rate possible.
And
as an added bonus, the very same data used to reduce your expenses can
help you better manage your business—and raise revenues!
And
the USF traffic study will protect you against a USAC audit.
The FCC
and USAC are coming down hard on USF waste, fraud, and abuse and our
telecom attorneys are advising their clients to be buttoned up in
supporting their 499A's and 499Q's.
Our low-cost turnkey traffic study
will
satisfy the FCC's 1% error rate and 95% confidence rate standards -
and will also tell the federal auditors, "Bother someone else, we
can prove our reporting is accurate."
The study
can be delivered within a week of receiving your cdr's and at a price
you can live with.
To
discuss the specifics of the engagement and hear ideas from one of the
nation's leading and most recognizable figures in telecom expense
management, please call 877.688.2200 contact
us here.
In the
meantime, you might want to review this recent bulletin from one of
our FCC attorneys.
All firm
clients providing wireless or interconnected VoIP services are advised
that the Instructions to the 2008 Telecommunications Reporting
Worksheet (“2008 Form 499-A Instructions”) requires providers of
wireless or interconnected VoIP services relying on “traffic
studies,” to determine USF contribution eligible revenues, to submit
their traffic studies to USAC and the FCC. Though established by
USAC in the absence of a formal FCC rulemaking proceeding, such Form
499-A “instructions” have, in the past, been given the force and
effect of law by the FCC. Therefore, failure to comply with the
traffic study submission requirement is considered a violation of FCC
Rules and could subject non-compliant providers to the FCC’s
enforcement mechanisms.
If you have not already done so, you are advised to submit to USAC and
the FCC copies of any traffic studies relied upon to determine 2007
revenue, as reported in their 2008 Form 499-As. Also, please
ensure all traffic studies relied upon for determination of the
jurisdictional allocation of 2008 revenue are accurate and conform to
applicable FCC standards; and to document, retain, and be prepared to
submit such traffic studies in the future.
- Jonathan Marashlian, The CommLaw Group

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