On April 2, 2021, USAC announced that the FCC Form 473 (the Service Provider Annual Certification form, or SPAC) has been updated to require service providers to certify that they are compliant with provisions of the Secure and Trusted Communications Networks Act of 2019, a part of which prohibits Universal Service Fund (USF) recipients from using USF funds “to buy new equipment or to support or maintain equipment already in inventory” from companies on the FCC-issued “Covered List” as well as any of those companies’ parents, affiliates, or subsidiaries. The Covered List identifies equipment and services from companies “deemed to pose an unacceptable risk to the national security of the United States.”
USAC notes that there are now two new certifications on the Form 473:
The first certification affirms compliance with the section 54.9 prohibition on using USF support to purchase, obtain, maintain, improve, modify, operate, manage, or otherwise support equipment or services produced or provided by the covered companies. The second certification affirms compliance with section 54.10, which prohibits the use of any federal subsidies on any communications equipment and services on the Covered List.
The new certifications will be required for all SPACs for FY2021, as well as FY2020 SPACs which have yet to be filed. USAC also notes that they will “start to conduct compliance audits regarding national supply chain rules” this summer.