That habit is worth revisiting this month. On September 14, the FCC posted the proposed federal universal service contribution factor for the fourth quarter: 42 percent, a record for the second quarter in a row. As recently as the summer of 2023 it was 29.2 percent. Unless the Commission intervenes, which it rarely does, the new factor takes effect October 1. Carriers are permitted, not required, to pass their contribution through to customers, and most do. The rules cap the line: a carrier may bill no more than the factor times the interstate telecommunications charges on the invoice.

That cap makes the universal service line unusual. It is one of the few lines on a carrier invoice that comes with a posted answer key. What is not posted is the other half of the multiplication: which services on your account the carrier treats as interstate telecommunications, and what share of each. That determination is the carrier’s, made service by service, and it appears nowhere on the bill.

It can be worked out, though. Take the federal universal service charge on any account and divide it by the factor in effect that quarter. The result, to a close approximation, is the dollar amount your carrier treated as assessable. Compare it with the services on that invoice. Private line and most business voice, interconnected VoIP included, are assessable in whole or in part; so is MPLS in most carriers’ treatment. Dedicated internet access and broadband are not; internet access revenue sits outside the contribution base. One caution: bundled and managed services are allocated by methods the FCC lets carriers choose, so the arithmetic produces a question, not a verdict. At 42 percent, it is a question worth ten minutes.

The factor keeps climbing for a plain reason. The fund’s demand is roughly flat, and the revenue it draws on keeps shrinking as spending moves off traditional telecommunications services. Your estate is probably part of that movement, and it changes what the number means for you. A private-line or MPLS circuit that lingers on the invoice after its site has moved to an internet-based connection does not just bill its rate. As of October, it bills its rate with up to 42 percent on top. And when a charge like that is disputed and credited back, the surcharge that rode on it should come back with it. Check that it did.

The same section holds a different sort of number, too. September 24 is the deadline for carriers to pay the FCC their annual regulatory fees. That obligation is the carrier’s. Carriers are allowed to pass costs like it along, and commonly do, legitimately, through lines with names like federal regulatory fee or administrative charge, printed a few rows from the taxes. But no agency sets those amounts. The carrier does, which makes each one a price, and a price is a matter for your agreement. In most of the agreements I have read, the rates run for pages and that whole section gets one sentence: the customer pays all applicable taxes, fees and surcharges. Applicable is a word worth asking about at renewal.

A TEM platform allocates everything below the subtotal across cost centers to the penny, as it should; that is processing, and it is necessary infrastructure. Whether 42 percent was applied to the right charges, and whether a carrier-set line has any footing in your contracted terms, are validation questions. BearGuard, our managed governance process, does not stop at the subtotal: taxes and surcharges are read line by item, every month, along with everything above them. One multi-brand retail portfolio had its invoices read that way, to the last line, for 31 months. The unauthorized charges identified, top of the invoice to bottom, came to $2,122,436.

I’ll leave you with one example of how a carrier-set line gets defended. We once asked a carrier about a new charge that had appeared at every location on an account. The answer, given in good faith, was that every customer was being charged it. I believe that was true. It was also not an answer, because whether every customer pays a charge has nothing to do with whether your agreement permits it. It took a while. The charge came off.