Back in October, the FCC released an order implementing the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA). Among other things, the order expanded the pool of contributors to the Telecommunications Relay Service Fund to include virtually all VoIP providers, including those that did not fit the FCC’s definition of “interconnected” VoIP.

To implement this contribution requirement, non-interconnected VoIP providers are required to register with the FCC by filing FCC Form 499-A, which is better known as the form used for universal service fund contributions. (The Form 499-A is used for other revenue-based support funds as well.) Providers must file this form no later than December 31, 2011. At this time, it appears that fewer than a dozen new providers have registered to date.

For the FCC’s CVAA order, see this link. A non-interconnected VoIP provider offers a service that (i) enables real-time voice communications that originate from or terminate to the user’s location using Internet protocol or any successor protocol and (ii) requires Internet protocol compatible customer premises equipment, but (iii) is not an interconnected VoIP service.

VoIP service providers should consult with their counsel to determine whether this new requirement reaches their activities.

Reminder: Non-Interconnected VoIP Providers Must Register by December 31