The FUSF Rate changes every quarter and a Carrier’s billing company updates these changes each quarter – to bill at either the FUSF rate, Safe Harbor or Traffic Study percentage. This billing will be the same percentage for 3 months – and then it changes again.
If you wanted to change from safe harbor reporting to traffic study reporting, you would have to change reporting at least 2 of the quarters with Traffic Study for the year to get started. The following year, you would be reporting 4 quarters of traffic studies.
Below are the methods that can be used:
Actual call detail records (CDRs)
This method is the most accurate and if you are able to get these records and use them, you should do so.
Safe Harbor
Telecommunications service providers can use a “safe harbor” presumption that a certain percentage of total service revenue is attributable to interstate telecommunications services if they are unable to ascertain their interstate and international traffic in a bundled product. Revenue percentages satisfying the safe harbor rule are as follows:
(1) VoIP – 64.9%;
(2) Wireless – 37.1%;
(3) Paging – 12.0%; and
(4) Analog SMR Dispatch – 1.0%.
Traffic Studies
Wireless and VoIP providers may use traffic studies to determine the revenue amounts to attribute to Intrastate, Interstate and International revenues derived from telecommunications service. Traffic studies may rely on statistical sampling to estimate the proportion of minutes allocated to intrastate, interstate and international jurisdictions. Traffic studies must be designed to produce a margin of error of no more than 1% with a confidence level of 95%. The traffic studies should also include, at a minimum, an explanation of: (1) the sampling/estimation methods employed; and (2) why the study results are accurate/ unbiased. Such studies are subject to FCC and USAC review. A traffic study must be submitted every year with their 499A filing to USAC.
Changing from Safe Harbor to Traffic Studies
Filers should use the same Methodology for the FCC Form 499-A and the FCC Form 499-Qs. If a carrier wanted to change from safe harbor reporting to traffic studies reporting, they would have to change reporting at least 2 quarters with Traffic Studies, at a minimum, for the changeover to get started. And when reporting on that calendar year’s 499A, your reporting must reflect the use of safe harbor and traffic study. For example, if a filer projected revenue based on a safe harbor for the first two quarters and based on traffic studies for the final two quarters, the amounts reported in the FCC Form 499-A for the first two quarters would be based on actual billings for those quarters and the relevant safe harbors %’s, and the amounts reported for the final two quarters would be based on actual billings for those quarters and the traffic studies for those quarters. The following year, you would be reporting 4 quarters of traffic studies if you decide to continue with that methodology.