It’s fine to reimburse Lifeline telecom carriers for actual instead of...

docket 11-42 on Friday. USAC’s current, projections-based disbursement “procedures are neither efficient nor conducive to promoting the Commission’s goal of eliminating waste, fraud and abuse in the disbursement of universal service fund,” CompTel said. CompTel was joined by Michigan regulators, who said in comments published Friday that “the change will result in program savings by reducing overestimated payments” (http://xrl.us/bmiym9). But CLECs are worried that “the downside” of moving to a system that disburses cash based on actual costs “is the financial shortfall” that telcos “will suffer during the month that USAC transitions,” CompTel said (http://xrl.us/bmiynf). “Both the Commission and USAC acknowledge that [telcos] will not only receive little or no reimbursement during the transition month, but may even incur a negative reimbursement that will be netted against the next month’s payment or invoiced to the” telco, CompTel said. The FCC could make things easier by ordering USAC “to shorten the window between receipt of a completed 497 and disbursement of payment in order to minimize the adverse financial impact on cash flow,” CompTel said. Companies use form 497 to report costs to USAC. If a Lifeline/Link-Up item is to be considered at the Dec. 13 FCC meeting, a draft order must circulate by Tuesday, by FCC tradition. Industry officials have scheduled a series of last-minute meetings for early next week. It appears that several reform ideas are still in play, including an overall cap on the fund, or a cap on reimbursements to Link-Up subscribers, telecom officials said.