New Filing System for Children’s TV Quarterly Reports

In case you haven’t started preparing your quarterly children’s television report, don’t go to the old filing system to do so. Beginning with the first 2016 quarterly report, which must be filed between April 1-10, 2016 and will cover the first three months of the year, the FCC’s Form 398 Children’s Television Programming Report will have to be filed in the FCC’s new Licensing and Management System (LMS). The FCC’s February 9, 2016 public notice details the procedure to use for accessing the form once a station is logged in to LMS.

Our sage advice and tips from last month’s newsletter are worth repeating, so here goes. We have noted that forms filed in LMS periodically do not automatically appear in a TV station’s online public inspection file. Stations should double check to be sure that the filed form appears in the online public file, and not just assume that it will. The FCC’s public notice makes clear that if the report is not linked to the station’s online public file by the deadline for filing the report, the station licensee must manually upload a copy of the report to the online public file.

And here’s another note. If you file a report on the 10^th day after the quarter, it will likely not appear in the online public inspection file until the next day, and that could mean that even though you timely filed the form, you were late in placing it in the public file by the 10^th day of April. Failure to timely place a report in the file may result in sanctions. So if you file the report on April 10, check the online public file to be sure it appears there, and if not, print it out and upload it so you don’t end up on the FCC’s naughty list in your next renewal.