The FCC's Wireline Competition Bureau released a Public Notice earlier this month seeking public comments to refresh the record on whether the FCC should exercise its authority under Section 254(d) of the Communications Act to subject revenues from one-way VOIP calling services to federal universal service fund contribution obligations. Call centers and other companies that rely heavily on one-way VoIP calls could be significantly impacted by a USF assessment on their end-user revenues; the contribution factor on such revenues currently exceeds 20%.

The current FCC record on these issues is based on comments filed in response to a Further Notice of Proposed Rulemaking released in 2012. The FCC specifically asks parties to address the questions raised in that FNPRM given today's market factors. The FCC also asks whether one-way VOIP services should be required to pay regulatory fees or other fees currently applicable to interconnected VoIP services. Comments are due July 13, 2020 and reply comments are July 27, 2020.