High Cost

Step 5: File Line Count Data

All eligible telecommunications carriers (ETCs) are required to submit line count data needed for USAC to calculate support amounts for both incumbent carriers and competitive carriers.

Incumbent local exchange carriers file line count data with the National Exchange Carrier Association, Inc. (NECA) with their annual cost data filings July 31 or quarterly as indicated in the table below.

 

Component

Line Counts Due

For Period Covering

HCL, SNA, SVS, LSS, HCM, ICLS

March 30

Quarterly line counts as of September 30 of the previous year

July 31

Quarterly line counts as of December 31 of the previous year

September 30

Quarterly line counts as of March 31 of the same year

December 30

Quarterly line counts as of June 30 of the same year

IAS
Due on last business day

March

Quarterly line counts as of December 31 of the previous year

June

Quarterly line counts as of March 31 of the same year

September

Quarterly line counts as of June 30 of the same year

December

Quarterly line counts as of September 30 of the same year

 

Submitting Line Counts
Line count information for rural carriers
With the exception of Interstate Access Support (IAS), rural ILECs must submit line count information at the study area level or consistent with the Disaggregation Plan adopted pursuant to the FCC's Rural Task Force Order. Rural ILECs in whose service areas a competitive ETC has initiated service and reported line count data to USAC must update line count data on a quarterly basis. Rural ILECs without competition may voluntarily submit updated quarterly information.

Line count information for non-rural carriers
Non-rural ILECs are required to submit updated line count data at the wire center level on a quarterly basis. High Cost Model support is calculated and distributed at the wire center level.

Line count information for competitive carriers
Competitive eligible telecommunications carriers (CETCs) must file line count data in the same manner as the ILEC in whose service area the CETC competes.

IAS line count information
A carrier must file the number of lines served within each price-cap local exchange carrier study area in which it serves. The line counts must be submitted at the unbundled network element (UNE) zone level if UNE zones have been established within the study area. Residential/single-line business and multi-line business line counts must be shown separately.

ICLS line count information
Line count information must be filed each July 31 to provide line count data for each study area by customer class (residential/single-line business and multi-line business) as of December 31 of the preceding year. Carriers must file disaggregated line count data on the July 31 annual line count filing, if such zones have been established within the study area.

Rate-of-return incumbent carriers in whose study areas a CETC has initiated service and reported line count data to USAC have additional line count filing requirements.  These incumbent carriers must also file line counts as of September 30 of the preceding year on March 30, as of March 31 of the present year on September 30, and as of June 30 of the present year on December 30. Rate-of-return incumbent carriers located in study areas where there is not a CETC that has initiated service and reported line count data to USAC may voluntarily elect to submit updated quarterly line counts in accordance with the schedule above. CETCs must file with USAC quarterly line count reports according to the same schedule.

Line Count Forms
ILECs must submit Part 36 data to NECA and Part 54 data to USAC using the appropriate forms. For submissions to USAC, use the High Cost Filing Requirements and Deadlines Tool. Competitive carriers must use the Competitive Carrier Line Count Report (Form 525). The Part 54 data filings can be sent by mail, email, or fax to:

    Universal Service Administrative Company
    Customer Operations
    2000 L Street, NW, Suite 200
    Washington, DC 20036

    Toll-Free: (877) 877-4925
    Fax: (866) 873-4695
    E-Mail: hcfilings@hcli.universalservice.org

Line Count Documentation

In FCC Report and Order 07-150, the Commission clarified document retention requirements for High Cost beneficiaries, requiring "recipients of universal service support for high-cost providers [and their agents] to retain all records that they may require to demonstrate to auditors that the support they received was consistent with the Act and the Commission's rules, assuming that the audits are conducted within five years of disbursement of such support.  These records should include without limitation the following:  data supporting line count filings; historical customer records; fixed asset property accounting records; general ledgers; invoice copies for the purchase and maintenance of equipment; maintenance contracts for the upgrade or equipment; and any other relevant documentation. 

"Beneficiaries must make available all such documents and records that pertain to them, including those of NECA, contractors, and consultants working on behalf of the beneficiaries to the Commission's OIG, to the USF Administrator, and to their auditors." 

Please note that "to the extent other rules or any other law require or necessitate documents be kept for longer periods of time (e.g., to support the account balances in the Part 32 Uniform System of Accounts, continuing property records, pole attachment calculations, plant equipment age, cost, or useful life, depreciation rates)," the Commission "[did] not alter, amend, or supplant such rule or law.  High cost program recipients must keep documents for such longer periods of time as required or necessary under such other rules or law and make such documents available to the Commission and USAC." 

This Report and Order became effective 30 days after it was published in the Federal Register, January 31, 2008, pp. 5843-5. 


Last modified on 12/23/2010