Responding to a WilTel complaint, AT&T told the FCC in a letter M...

Bureau’s proposed 8.9% universal service fund (USF) contribution factor because it doesn’t include AT&T enhanced prepaid card revenues. The request became moot Sept. 30 because the time period for the FCC to halt it expired, but the FCC in a different proceeding has been considering possible action against AT&T’s handling of its prepaid card revenues. AT&T argued in the letter that USF contributions aren’t required because the card is an information service and “WilTel’s suggestion that AT&T is not living up to its universal service obligations is absurd” because “AT&T is the single largest contributor to the USF.” AT&T criticized WilTel and BellSouth assertions “that AT&T is enjoying an unfair, discriminatory competitive advantage” by not paying universal service contributions. “Other providers are free to qualify their prepaid card services as information services, outside of the duty to contribute to the USF,” AT&T said. If the FCC adopts a numbers-based approach to USF contributions, “the regulatory classification of a service as an ‘information service’ or ’telecommunications service’ will no longer be determinative, because providers of both sets of services will be required to contribute to the USF based on their end-users’ assigned telephone numbers.” The company also noted that the “predominant users” of the enhanced prepaid card are military, low-income, minority, immigrants and retirees who depend on the cost-effective nature of the card. Requiring USF contributions “would shift the USF burden from more affluent consumers to individuals who are least able to afford it.”