New Filing System for Children’s TV Quarterly Reports

Starting 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.

Previously, these reports were filed in the Children’s Television Online Filing (KidVid) System, but the link to do so is now disabled. So be prepared with your FRN to log in to LMS at this link. Full power, Class A and LPTV stations with must-carry rights must file the report by the 10^th day after each quarter of the calendar year.

It is unclear whether any data from prior reports will be available in the LMS system, or auto-fill in the form, so you may want to allow additional time in case you must re-type form information.

Also, 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.

Heads up – if you file a report on the 10^th day after the quarter, it will likely not appear until the next day, and could mean that even though you timely filed it, you were late for placing it in the public file. Failure to timely place a report in the file may result in sanctions.