Client Advisory: Connecticut Public Utilities Regulatory Authority Adopts Quarterly E-911 Reporting Requirements for VoIP, CMRS, and Local Service Providers

Earlier this year, the Connecticut Public Utilities Regulatory Authority (“PURA”) released an order relating to E-911 regulatory fees which, among other things, adopted new quarterly reporting requirements for certain providers offering communications services in Connecticut. The new reporting requirements apply to local telephone companies, Commercial Mobile Radio Services (“CMRS”), customer-owned coin operated telephone services (“COCOT”), and Voice Over Internet Protocol (“VoIP”) providers. The deadline for the first quarterly report is this Friday, October 25. The order can be found  here, and the reporting form is available  here. A summary of the reporting requirements follows. Quarterly Reporting Requirements Starting October 25, 2019, and every three months thereafter, all telephone companies, as well as CMRS, COCOT, and VoIP providers, must report to the PURA the E-911 surcharges collected from their end-users for the previous three months as reflected on the E-911 Surcharge Remittance Form. The table below lists the reporting deadline for each quarter, as well as each applicable reporting period.
Reporting Quarter Reporting Deadline Applicable Surcharges
Fourth Quarter Oct. 25, 2019 Jul. 1 – Sept. 30, 2019
First Quarter Jan. 27, 2020 Oct. 1 – Dec. 31, 2019
Second Quarter Apr. 27, 2020 Jan. 1 – Mar. 31, 2020
Third Quarter Jul. 27, 2020 Apr. 1 – June 30, 2020
  In addition, each provider must submit to PURA a copy of the monthly remittance forms filed with the Connecticut Department of Emergency Services and Public Protection (“DESPP”). Non-DESPP forms and incomplete forms will not be accepted. Therefore, it is critical that covered providers strictly follow all applicable procedures to ensure compliance with these requirements. While Connecticut’s new E-911 quarterly reporting requirements may not seem complex, the PURA will require strict compliance with all procedural rules concerning the submission of these reports. Therefore, it is imperative that covered providers understand and follow these rules to avoid fines and other regulatory sanctions. For questions or additional information about the new reporting obligations, please contact your assigned attorney or Allison D. Rule, Esq.,  adr@commlawgroup.com or (703) 714-1312.
Cloud Communications Alliance

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