FCC Adopts Final Deadlines for Submission of C-Band Reimbursement Claims

On December 5, 2023, the FCC released a Public Notice adopting two final reimbursement claims submission deadlines for eligible incumbents and stakeholders as part of the ongoing transition of the 3.7-4.2 GHz band (C-band"). Claimants seeking reimbursement for all claims for C-band transition costs incurred and paid by claimants as of December 31, 2023, including all lump sum election claims by incumbent earth station operators, must file no later than February 5, 2024. For any costs incurred after December 31, 2023, claimants will have until July 1, 2024. Claimants must submit any and all reimbursement claims to the C-band Relocation Payment Clearinghouse (RPC") by these dates.

The RPC has been accepting C-band reimbursement claims for processing since August 2021, and the Commission anticipates wrapping up the C-band reimbursement program by the middle of next year. In order to facilitate the RPC's processing of claims on a rolling basis and to expedite the completion of the C-band reimbursement program, the Commission strongly encourages claimants to submit any claims incurred within 30 days of payment and not wait until the deadlines to do so.

For the small number of anticipated claims that may be incurred and/or paid after July 1, 2024,whether a one-time or recurring cost, the claimant must submit the claim(s) for RPC review through its Coupa portal to be considered for reimbursement, and pursuant to its procedures before the July 1, 2024 deadline, must include the best supporting documentation and information available at that time. Any claims which are not submitted in this manner by the relevant deadline will be considered by the RPC as untimely and will not be processed or reimbursed.

If you have any questions or would like assistance with filing any C-band reimbursement claims, contact your FHH attorney for guidance.