The FCC announced that the Proposed First Quarter 2021 Universal Service Contribution Factor (DA 20-1480) will be 31.8% — the highest ever and the first time it has been over 30%. As we said when the contribution factor first broke 10%, then 15%, 20%, and 25%, this cannot keep increasing. At some point the FCC, which has been ducking this problem for years, must act.
As shown in the chart above, while the upward trend has been bad enough, the last few quarters have been horrendous. The important point to understand is that the recent increases in the contribution factor have less to do with the demand for universal service funds than with a decline in interstate telecommunications revenue. Here’s how the quarterly contribution factor is calculated:
Quarterly Contribution Factor =
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Estimated USF Requirements
Estimated Contribution Base
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The graph below shows the real problem. The demand on the fund has been relatively flat. E-rate, for example, has only required about $2 billion in new funds the past few years, roughly half of its authorized total. In contrast, the contribution base, now entirely supported by international telephone revenues, has been steadily declining.
One obvious way to solve this problem is to increase the revenue contribution base. The last serious approach to this solution was proposed in October 2019 when the state members — but not the federal members — of the Federal State Joint Board overseeing the Universal Service Fund recommended expanding the base to include a broader class of services, e.g., broadband internet services (see our newsletter of October 21, 2019).
There has been a lot of discussion of what the FCC may do in 2021 — including the possibility of making off-campus remote learning eligible for E-rate discounts — when the FCC Commissioner balance is realigned with the new Administration. It is hard to envision any new USF initiatives unless and until the contribution factor is addressed.