On November 22, 2019, the FCC adopted order FCC 19-118 which relates to the Internet Protocol Captioned Telephone Services (IP CTS) with the primary goal of adjusting the cost recovery method in order to not place an undue burden on only interstate telecommunications revenues.

Starting with the 2020-21 program year, the fund will calculate the annual obligation based on two factors (non-IPCTS related costs and IPCTS related costs). Below you will find some frequently asked questions we have been receiving with the hopes that this will help answer your questions as well.

When will this new change go into effect?

The change is to go into effect for the July 2020 – June 2021 program year. The information reported on the 499A 2020 (2019 revenues) will be used to calculate the obligations due to the fund.

When should the carriers begin to collect TRS on their Intrastate billings to end users?

The TRS fund does not provide guidance on whether carriers are allowed or when to collect the funds. We recommend reaching out to the FCC for guidance on this.

Which carrier types will be affected?

All carrier types are affected by this order.

Would carriers already contributing to the TRS on their Interstate and International revenues reported also pay on their Intrastate too? Or is this for Carriers that have never contributed to the TRS because they report 100% Intrastate on their 499’s?

As we mentioned above, this impacts all carrier types. There will be two separate transactions listed on the invoices starting in July 2020. One obligation will be calculated based on the Interstate and International revenues (499A form Line 514b) multiplied by the non-IPCTS approved rate and the second obligation will be calculated on the total TRS revenues (499A form Line 514a) multiplied by the IPCTS approved rate.

When will the new rates for the changes come out?

The rates are set effective July 1st of each year. Historically the rates have been published in an order right around July 1st of the year.

If you have additional questions, please contact trs@rolkaloube.com. You may also visit our website at http://www.rolkaloube.com/news/ for the latest news regarding the order and other factors affecting the Interstate TRS Fund.