TRS Billing FAQs
How is the Interstate TRS Fund assessment calculated?
The assessment is calculated based on the 499-A data that is due to USAC by April 1st. There will be two separate transactions listed on the invoices starting in July 2020 due to the FCC Order 19-118 that initiated a second obligation to be calculated to help cover the Internet Protocol Captioned Telephone Service (IPCTS) costs. One obligation will be calculated based on the Interstate and International revenues (499-A form Line 514b) multiplied by the non-IPCTS approved rate and the second obligation will be calculated on the total TRS revenues (499-A form Line 514a) multiplied by the IPCTS approved rate.
What changes cause the assessment to be higher than in previous years, other than the amount reported on the 499-A form?
The assessment rate changes each year. Contemporary rate information can be found here.
Why do you use a portal for payment?
In December 2019, the Telecommunications Relay Service Fund account was moved inside of the United States Treasury. All payments must be initiated through the RL Pay Site. Through this portal:
- Invoices are delivered faster than USPS can deliver it.
- You have the flexibility to print your invoice whenever you like.
- The time between receiving the TRS invoice and the due date are greatly expanded.
- You can review unpaid and paid invoices.
- All payments must be received by 3pm on the Thursday before the invoice is due to allow adequate processing time. Payments received after this, may result in the company being placed on Red Light Status.
- The expense your company experiences (for the check stock, envelope, mailing, and handling costs) is reduced.
- Copies of the invoice can be distributed more widely at reduced expense in less time.
- RolkaLoube can quickly keep your contact information up to date.
What do I do if I forgot my portal password, or if I try to log in to the portal, and receive an “invalid login” message?
Use the “Forgot Password” option:
- Select forgot password, and enter your email address associated with the portal account.
- You will receive an email from the website with a link to reset your password. If you do not see the message within 60 minutes, please check your spam/junk folder.
- If you are unsure of which email address is linked to your portal account, please contact firstname.lastname@example.org requesting a password reset.
- Once you reset your password, you will be able to log into the portal with the new password.
Why do we receive a notification from the TRS Fund that our invoice is available on the portal instead of receiving it via USPS?
RolkaLoube recognizes that your company may be used to receiving Interstate TRS Fund invoices through USPS. We have set up a modern electronic portal which will notify you via email when a new invoice has been posted to RL Pay. Please contact RolkaLoube if you need to discuss the delivery of invoices.
For payments authorized through the portal, what is the ACH information we would expect to see when clearing our account?
You will see the following information displayed on your banking statement: “TRS Payment Obligation.”
I clicked to download my invoice and I am unable to find it.
Once you click “Download my Invoice,” the invoice will be downloaded into your downloads folder on your computer. Please check your downloads folder on your computer once the processing flag has cleared, for a copy of your invoice.
What is the penalty for filing a late 499-A form?
All companies are subject to late filing sanctions regarding the Form 499-A, as it is a required filing regardless of de minimis status. If a TRS Fund contributor is more than 30 days late (i.e., delinquent) in filing a Telecommunications Reporting Worksheet (“Worksheet”) Form 499-A, the Administrator may assess an administrative remedial charge for reasonable administrative expenses resulting from improper filing or failure to file, as well as interest on overdue contributions. The minimum administratively imposed remedial charge for failure to timely submit a Worksheet is $100. The Commission may also pursue enforcement action against delinquent contributors and late filers as well as assess costs for collection activities, in addition to those imposed by the Administrator.
What are my options for how my company is billed?
The fund offers annual billing or monthly billing. If your company’s annual assessment is more than $1200, and your account has been in good standing, you will be sent a monthly invoice for 1/12 of your annual assessment. If your annual assessment is below $1200, or your account has not been in good standing, you will be invoiced for your full annual assessment.
If your company is being billed monthly and you wish to be billed the remaining amount for the year, you can request this change via an email to email@example.com. Companies who are being billed monthly and want to overpay are welcome to do so when making a payment through the portal. See the RL Pay User Guide for instructions on how to pay via the new portal.
We do understand that situations arise. Any other payment plans will need to be requested by submitting a payment plan request to firstname.lastname@example.org. Our accounting department will then review your account and respond with the options that you have for a payment plan.
How is the late payment fee determined?
The finance charge rate applicable to late payments is the Internal Revenue Service (IRS) interest rate for underpayments for the calendar quarter beginning July 1st. The rate can be found on the IRS website, www.irs.gov, or at 26 CFR 301-6621-1. The minimum late payment penalty charged each month will be $1.00. There will be a $35.00 administrative charge per invoice for delinquencies that are 30 days overdue.
Our 499-A form was filed on time, but we have been assessed a late filing charge. Why?
As the Interstate TRS Fund administrator, RolkaLoube receives filing data from USAC. If we have assessed a late filing penalty, but your company’s filing was timely, contact USAC to have them correct the data they have provided to us. RolkaLoube can only adjust your account after USAC corrects the data. USAC can be reached at 888-641-8722 or email@example.com.
Where can I find FCC Form 499-A information
You can find Form 499-A information on USAC’s website at https://www.usac.org/service-providers/contributing-to-the-usf/forms-to-file/.
What are the payment options?
All payments must be initiated through the RL Pay billing and collections portal at https://pay.rolkaloube.com. Through the site, you can either pay online via credit card by selecting Pay Online Now, or set up an ACH debit or credit transfer from your bank by selecting the ACH option.
Can we send payment via check for our contribution payment?
We are no longer accepting check payments. For available payment options, see above, under payment options.
Can we pay by wire transfer?
Wire transfers are no longer accepted. For available payment options, see above, under payment options.
Where can I find a completed W9 for the Interstate TRS Fund?
Click here: Interstate TRS Fund W9 Form.
How can I contact USAC?
You can contact USAC at 888-641-8722 or firstname.lastname@example.org.
Who do I contact if I have additional questions?
Questions can be directed to RolkaLoube’s Customer Service Team at 717-585-6605 Option #1, or email@example.com.
Are there costs that the NDBEDP will not cover?
Yes. Please see “Examples of Reimbursable Expenses” for a list of expenses that are reimbursable and those that are not.
Does the NDBEDP reimburse for the cost of cables, switches, clamps, and adaptive accessories necessary to use the distributed equipment?
Yes. The reasonable costs of cables, switches, clamps, and adaptive accessories will be reimbursed by the NDBEDP if they are necessary for the consumer to use the equipment distributed. Personal accessories that facilitate or enable other life functions are not reimbursable (e.g., a wheelchair to facilitate mobility).
Are the costs of alerting devices reimbursable?
Yes. The reasonable costs of alerting devices such as flashing lights are reimbursable when they are necessary to use the equipment distributed to make telecommunications, internet access, or advanced communications accessible to low-income individuals who are deaf-blind. Assistive lighting that is used separate and apart from the distributed equipment is not reimbursable.
Are the costs for batteries or upgrades reimbursable for equipment that was not distributed by the NDBEDP?
Yes. The NDBEDP will reimburse for batteries or upgrades on previously distributed equipment (hardware, software, applications, etc.) as long as these are reasonable and necessary to make telecommunications, internet access, or advanced communications accessible to low-income individuals who are deaf-blind.
When an equipment recipient moves to another state, which state certified program will be responsible for the upkeep of the equipment?
When an equipment recipient relocates to another state, the former state’s certified program will no longer be responsible for upkeep of the recipient’s equipment, nor will it be permitted to seek reimbursement for maintenance of such equipment no longer in use within the former state. In such cases, upon the request of the recipient, the former state must transfer the recipient’s account and any control over the distributed equipment to the new state’s certified program. The certified program in the state where the recipient relocates then will be responsible for the cost of upkeep of the distributed equipment. If the recipient needs new equipment after relocating, the recipient will be permitted to apply for such equipment in the new state.
Is there a searchable national database that certified programs can use to determine if program applicants have received NDBEDP equipment in another state?
With the start of the permanent program, the FCC was tasked with developing a national database. Entities will be notified when it is operational. As noted above, when a recipient relocates to another state, upon the recipient’s request, the certified program must transfer the recipient’s account and any control of the distributed equipment to the new state’s certified program so that the individual need not reapply.
Could one person receive two identical pieces of equipment?
Yes. With appropriate justification (such as one for home and one for residential school housing), one person may receive two identical pieces of equipment; it is within the certified program’s discretion to determine how it will distribute equipment.
Do NDBEDP equipment recipients have a right to newer, better, or upgraded equipment when it becomes available?
No. However, each NDBEDP certified program has the discretion to determine whether it will provide newer, better, or upgraded equipment, with the reasonable costs of such upgrades and replacements being reimbursable. Because NDBEDP funding is not unlimited, certified programs may want to consider carefully how best they can use their limited funding to distribute equipment to the largest number of low-income individuals who are deaf-blind.
Will the NDBEDP provide reimbursement for an inventory of loaner equipment which would be available for use when program distributed equipment is being repaired?
Yes. Reasonable costs for an equipment loan program, to be used when previously distributed equipment is being repaired, are reimbursable, but a loan program is not required. Loaner equipment is reimbursed under Maintenance of an Inventory, which also includes equipment that is used for assessments, training trainers, and outreach demonstrations.
Can a certified program charge a client for damage to NDBEDP equipment, caused by the client’s negligence?
The NDBEDP rules neither require nor prohibit certified programs from charging a client for negligent damage to distributed equipment.
Can the NDBEDP certified program pay for a portion of a piece of equipment in conjunction with another program?
Yes, as long as the equipment is covered by the NDBEDP program rules and partial payment for the equipment is noted as part of the reimbursement request in reports to the FCC and/or TRS Fund Administrator.
Can the NDBEDP certified program pay for a portion of a piece of equipment in conjunction with another program, and the NDBEDP certified program cover the cost for the associated training?
Yes, as long as the equipment is covered by the NDBEDP program rules and partial payment for the equipment is noted as part of the reimbursement request in reports to the FCC.
If there is another funding source to pay for equipment, could the NDBEDP cover the costs of related services (such as training) associated with that equipment, even if the NDBEDP does not cover any part of the cost of the equipment?
No. To be reimbursed, related services need to be associated with the distribution of a piece of equipment that is covered under and paid for, in whole or in part, by the NDBEDP.
Does the NDBEDP reimburse the cost of providing interpreter or translation services for languages other than English or American Sign Language?
Yes, interpreter or translation services will be provided when they are needed to ensure effective communication with program clients and to facilitate equipment distribution and the provision of related services that are permissible under the NDBEDP.
Can the attestations for eligibility determination be made by e-signature?
Yes, to the extent that such form of signature is recognized as a legally valid signature under applicable federal law or state law.
How do we determine low-income eligibility when a student who is deaf-blind is not living with his or her family?
If the deaf-blind student could be claimed as a dependent by another taxpayer (as a qualifying child or qualifying relative), then the certified program should consider that taxpayer’s family or household size and income to make an income eligibility determination.
Can certified programs shift its certification to other entities?
No. Certification is granted to a single entity in each state that is eligible for reimbursement. While certified programs may contract with other entities to perform NDBEDP-related tasks, ultimately the certified entity remains responsible for ensuring that all NDBEDP-related tasks are performed and is the only entity authorized to receive compensation from the TRS Fund.
Is there a limit on the amount of money a certified program can spend on each client?
No, this is within the discretion of the program so long as each amount is reasonable.
If a certified program does not have enough qualified trainers in-state, can a qualified trainer be brought in from another state?
Yes. The NDBEDP will reimburse certified programs for a trainer’s reasonable travel costs.
Are the percentage caps for administrative, outreach, and train-the-trainer costs based on the certified program’s annual funding allocation or the certified program’s total reimbursable expenses?
The caps (15% for administrative, 10% for outreach, and 2.5% for train-the-trainer) are all based on the certified program’s total annual funding allocation and not on current reimbursable expenses.
Are the costs of renting physical facilities for the distribution of equipment or provision of related services reimbursable?
Yes. The cost of renting physical facilities is reimbursable as an administrative expense, subject to the 15% cap for administrative expenses.
How is “income” defined for the purpose of determining income eligibility for the NDBEDP?
“Income” is all income actually received by all members of a household. This includes salary before deductions for taxes, public assistance benefits, social security payments, pensions, unemployment compensation, veteran’s benefits, inheritances, alimony, child support payments, worker’s compensation benefits, gifts, lottery winnings, and the like. The only exceptions are student financial aid, military housing and cost-of-living allowances, irregular income from occasional small jobs such as baby-sitting or lawn mowing, and the like.
How is “household” defined as it is used within the definition of income for the NDBEDP?
A “household” is any individual or group of individuals who are living together at the same address as one economic unit. A household may include related and unrelated persons. An “economic unit” consists of all adult individuals contributing to and sharing in the income and expenses of a household. An adult is any person eighteen years or older. If an adult has no or minimal income, and lives with someone who provides financial support to him/her, both people shall be considered part of the same household. Children under the age of eighteen living with their parents or guardians are considered to be part of the same household as their parents or guardians.
Is the FCC asking for a higher than regular audit standard, such as a forensic standard, specifically designed to prevent and detect fraud, waste, and abuse?
What kind of audit is needed to comply with the NDBEDP audit rule?
For purposes of complying with the NDBEDP audit rule, an independent auditor must conduct a program audit that includes a traditional financial statement audit, as well as an audit of compliance with the NDBEDP rules that have a direct and material impact on NDBEDP expenditures and a review of internal controls established to ensure compliance with the NDBEDP rules.
Compliance areas to be audited include, but are not limited to, allowable costs, participant eligibility, and reporting. The audit report must describe any exceptions found, such as unallowable costs, lack of participant eligibility documentation, and missing reports. The report also must include the certified program’s view as to whether each compliance exception is material and whether any internal control deficiencies are material.
If the auditor finds evidence of fraud, waste, or abuse, the auditor must take appropriate steps to discuss it with the certified program management and the FCC and report the auditor’s observations as required under professional auditing standards. This program audit standard is comparable to that required for Office of Management and Budget (OMB) Circular A-133 audits. We believe that such audits of NDBEDP certified programs, conducted annually by an independent auditor, will detect and prevent fraud, waste, and abuse, which will satisfy the NDBEDP audit rule.
Would an audit performed in accordance with OMB Circular A-133 comply with the NDBEDP audit rule?
Questions about whether the Single Audit Act applies to the Interstate Telecommunications Relay Service Fund (the TRS Fund) and whether reimbursement of NDBEDP expenses from the TRS Fund should or should not be included in an OMB Circular A-133 audit should be directed to OMB. However, because the program audit criteria described above are similar to that of an OMB Circular A-133 audit, an audit performed in accordance with OMB Circular A-133 will satisfy the NDBEDP audit rule.
TRS Service Provider FAQs
When can a service provider first submit a request for reimbursement from the Interstate TRS Fund?
Service providers can submit the first request for reimbursement 30 days after RolkaLoube receives 1) notice of participation and 2) if a VRS provider, a call center list. For example, if RolkaLoube receives the form(s) on December 31st, RolkaLoube cannot accept the service provider’s first request for reimbursement until January 30th. In this case, the deadline to submit for January service would be the 10th business day of February. If the reimbursement request made the filing deadline, it would be considered for reimbursement on the March payment schedule. If the reimbursement request missed the filing deadline, it would be delayed for reimbursement.
How does a company get access to the Extranet?
The Interstate TRS Fund Extranet is only for registered TRS service providers, not telecommunications carriers. To gain access to the Extranet, click here for the form needed to register. Providers will also need to acquire an FCC Registration Number (FRN), which may require a separate registration process with the FCC. See https://fjallfoss.fcc.gov/coresWeb/publicHome.do for details.
What happens when a service provider misses the filing due date?
Requests for reimbursement that are uploaded to the Extranet after the 10th business day following the end of a month will only be considered for reimbursement if they are made within four and a half months of the services having been provided. Reimbursements for late filings will not be made according to the prescribed payment schedule.
Does the Fund reimburse providers for all IP calls?
Not all IP calls are compensable. There are a number of criteria used to determine if a call is compensable or not. For example, the Commission does not allow for compensation for IP Relay calls that originate or terminate outside the United States. See Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, Order 19 FC Rcd 12224, 12242, at ¶ 48, n.121(2004).
Who do I contact if I have additional questions?
Questions can be directed to RolkaLoube’s Customer Service Team at 717-585-6605, Option #2 or firstname.lastname@example.org.