ISP’s Frequently Asked Questions.

As the Affordable Connectivity Program (ACP) approaches its scheduled conclusion, Internet Service Providers (ISPs) face critical changes as this funding program comes to an end. The Federal Communications Commission (FCC) mandates specific actions and compliance measures during this transition period. Tammie Herrlein, Vantage Point Solutions Senior Analyst, addresses frequently asked questions to guide ISPs through the necessary steps to ensure a smooth and compliant shift away from ACP benefits. By following these guidelines, ISPs can effectively communicate changes to their customers, maintain regulatory compliance, and manage service modifications responsibly.

FAQ 1: What do I charge ACP households on their May invoice? Do I apply a credit?

ANSWER: That depends on which scenario you fall under:

SCENARIO 1: Your ISP did not complete an election with the USAC for May 2024 partial reimbursements.

No ACP credit should be applied. Move forward to FAQ 2.

SCENARIO 2: Your ISP completed an election with the USAC.

You should apply the maximum partial benefit amount that was issued by the USAC. This is expected to be $14 or less.

Please note: The USAC credit amount will be applied to May invoices only. In June, the billing amount will not include a credit. This information should be communicated in your May invoice if you haven’t already included the following messaging:

• Communicate Changes Clearly: Indicate that this will be the final bill received at the reduced rate.
• Outline New Rates: Inform customers of the new rate they will pay for their current service without the USAC credit, effective June 1st, 2024.
• Offer Alternatives: Provide options for customers to cancel services or switch to another package.

FAQ 2: What if ACP households haven’t opted into services?

ANSWER: All ACP households need to affirmatively opt-in to continue their services. This includes:

• Acknowledgment of “required disclosures”.
• Willingness to pay for broadband service. This is demonstrated if:
  • They have provided oral or written confirmation that the provider may continue to provide services at a higher rate.
  • They were an existing customer before ACP enrollment.
  • They currently pay a fee.

FAQ 3: Should I disconnect services if I haven’t received an affirmative opt-in or if the subscriber isn’t paying their bill?

ANSWER: Carefully review your non-paid disconnect policies and processes.

There is a 90-day disconnect requirement before disconnection is allowed. Review the FCC Public Notice here.  

FAQ 4: Should our ISP move forward with offering a low-cost package to replace ACP?

ANSWER: Before offering a low-income package as a replacement for ACP, we strongly encourage you to view our recommendations here: https://vantagepnt.com/2024/04/10/digital-discrimination-moving-forward-in-the-new-frontier/

FAQ 5: The ACP rules require de-enrolling subscribers when no longer eligible.  Should service providers that didn’t elect to apply a partial payment de-enroll their subscribers for May 2024?

ANSWER: No.  Existing ACP subscribers are still eligible for the program. 

Funds are just not available to provide the credits.  In addition, if additional funds become available all of the de-enrolled subscribers would then need to be enrolled.

USAC will be providing additional information regarding the next steps.  Service providers with an API (billing system electronically connects to the NLAD) may need to review business processes to ensure the amounts are being invoiced due to the subscribers still being in NLAD but no longer eligible for the invoice credit.

Navigating changes to ACP credits can be confusing. The Vantage Point team is here to help. If you need assistance with communicating these changes with specific language on your website or in your billing notices, reach out to Tammie Herrlein or contact the Marketing Services Group to craft a tailored message for your ISP.