October 15th Deadline for Initial Filings for Radio Stations Seeking Reimbursement for TV Repack Expenses

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Subject: October 15th Deadline for Initial Filings for Radio Stations Seeking Reimbursement for TV Repack Expenses

From:   Michael Beach, VP, Distribution
            Michael Riksen, VP, Policy & Representation

Date: September 26, 2019

The FCC is starting the reimbursement process for FM stations, LPTVs and translators that incur costs due to TV spectrum repack work and recently announced the availability of reimbursement claim forms and payment instruction forms, along with detailed instructions and procedures.

Radio stations are reminded that the deadline for the submission of initial reimbursement forms to the FCC for TV repack-related expenses is October 15, 2019.  Radio stations that intend to request reimbursement must submit the Reimbursement Form 399, including an Eligibility Certification, information regarding their existing broadcasting equipment, estimated and/or incurred reimbursable expenses, and supporting documentation, by the October 15th deadline. Although TV repack work is ongoing, both stations that have already incurred expenses as well as stations that expect to incur eligible repack-related expenses in the future need to meet this initial filing deadline if they want to claim reimbursement.

The FCC has developed a suite of materials summarizing the eligibility requirements and procedures for radio stations:

  • FCC Webinar held on August 28th with information and Q&A for FM stations, LPTVs and Translators, now posted online here.  
  • FCC Reimbursement Fund Page provides an overview of the reimbursement program and links to key FCC documents and information. The tabs across the top link to a helpful outline of eligibility criteria and required documentation for FM stations and other entities, step-by-step reimbursement procedures for FM stations, and additional reference materials.
  • FM Station FAQs is a recently added, handy resource focused on reimbursement for FM stations.

The FCC reimbursement procedures are highly detailed. We encourage stations affected by the TV repack to carefully review these materials, and to consider consulting with counsel or repack project management experts to help navigate the detailed requirements, multiple reimbursement forms, and exacting online filing procedures.

For more information:

  • Reimbursement Claim “Form 399”: The FCC Public Notice on Reimbursement Claims Process establishes an October 15th deadline to file the initial “Form 399” using the FCC online system, along with detailed instructions.

Stations may be reimbursed for both “hard” costs, such as new equipment and tower rigging, and “soft” costs, such as engineering, project management, and legal expenses. The Reimbursement Form includes an embedded cost catalog with an extensive list of likely estimated expenses. The cost catalog is not exhaustive and additional expenses may be submitted for consideration. If stations have already incurred costs, they should use the actual cost and invoice for their estimate.

The FCC advises stations to submit the Form 399 before the deadline to avoid any last-minute surge on the filing system. Once the FCC reviews the initial cost estimates and actual expenses, it will make an initial allocation from the Reimbursement Fund for each eligible radio station, which will be available for draw down as expenses are incurred. Stations may submit multiple reimbursement requests as they incur expenses and are required to update their cost estimates throughout the reimbursement process if there are changes. The FCC may make subsequent allocations as needed, to the extent funds remain.

  • Reimbursement Payment Instructions: This FCC Financial Procedures Public Notice sets forth detailed procedures for submitting bank account information and certifications required to receive reimbursement payments. The process includes online registration, filing an “FCC Form 1876” with payment instructions, then review and verification. There is no deadline for filing the banking Form 1876, but it may take more than four weeks from submission for bank account information to be validated and payments to begin, so it’s wise to submit early.

Please connect with us if you have questions or need additional information.

 

 

Posted: September 26, 2019