FCC Grants Waiver of RHC Invoice Filing Deadline Where HCPs are Unable or Unwilling to Provide Service Delivery Certifications

On February 4, 2026, the FCC’s Wireline Competition Bureau (WCB or Bureau) released an order granting an appeal filed by ENA Healthcare. 

In the appeal, ENA Healthcare sought a waiver of the invoice processing rules because certain HCPs had failed to file their Forms 467.  

When an HCP does not complete its part of the invoicing process, the carrier cannot receive reimbursement for the services it provided.  To provide the requested relief, the Bureau instructed USAC to seek alternative documentation from ENA Healthcare to verify its reimbursement claims, such as proof ENA Healthcare provided the requested service to the HCP, documentation showing an HCP has dissolved, or evidence of multiple attempts to communicate to the HCP that it must file the FCC Form 467.

The Bureau also reminded program participants that they have an obligation to comply with the invoice filing requirements.  As such, the waiver only applied to the requests specified in the order and was based on the special circumstances concerning HCPs who are unable or unwilling to file the FCC Form 467.  It has no bearing on the need for all HCPs to file the FCC Form 467 or its successor Form 469 on time.  Further, the Bureau stated that it takes no position on the merits of any future requests for waiver of its standard protocols for reimbursement.  

Broadband Legal Strategies represented ENA Healthcare in the appeal.