Universal Service Contribution AI Agent

What this agent does

Assembles the worksheet, not the certification

A revenue line is classified, and the classification is held with the system and the as-at date behind it.

A projection is reasoned, because 47 CFR 54.711(a) wants a good-faith estimate from your own procedures.

Reason

A quarter closes, and the Form 499-Q projection limb is the one with no system of record to point at.

A revision would decrease a contribution, and that window shuts on 31 March of the following year.

An upward correction stays owed after the same window, so the clock runs in one direction only.

Decide

A due date lands on a weekend, and it shifts — a form counts as filed when USAC receives it, not before.

A de minimis year arrives, and the annual Worksheet is still owed; the other fund and fee duties have no exemption.

Out

A registration detail changes, and the Worksheet instructions give one week to report the change.

Execute write actions only inside the approval boundaries agreed during implementation.

→ Product statement

The agent assembles and traces; a named officer examines the Worksheet, certifies it and files it, and the filer answers.

Example workflow

One revenue line, source to filing

AgentHuman

1Revenue records receivedBilling, rating and general-ledger extracts, each with its as-at date

2Line coverage assembledProduct, jurisdiction, customer class and the system each figure was taken from

3Worksheet assembledThe annual blocks, the quarterly projection and the reasoning behind each

4Controls appliedProvenance checks, true-up checks, revision-window checks and completeness confidence

No human action required

Stages 1 to 4 run unaided, and nothing is certified at any of them — the agent is assembling, and the regulatory lane opens at the completeness gate.

5DecisionBranches at the completeness gate

Provenance complete

Goes to the certifying officer to sign.

Anything thin

Adds a regulatory counsel read first.

Regulatory review

The assembly is held with its provenance, its projections and its gaps.

Certify and file · Append provenance · Send to counsel

Filed — by a named officer▼

6Revenue and filing records updatedOnly where write access and § 54.711(b) confidentiality allow it

7Outcome evaluatedProvenance completeness, true-up variance, counsel corrections and what audit found

Corrections

Each counsel correction is counted in the evaluation.

What should not run autonomously

Human approval stays in control

Outside the boundary — human approval required8 items

Certifying a Worksheet under the 18 U.S.C. § 1001 warning.

Signing or filing the annual or quarterly Worksheet.

Deciding a revenue line sits in the contribution base.

Judging a projection to be a good-faith estimate.

Automation boundaryAgent acts unaided

✓Trace each revenue figure to the system and the as-at date behind it.

✓Bind each worksheet line to the product and jurisdiction it reports.

✓Hold the reasoning behind each revenue projection.

✓Track the revision window and the true-up against.

Nothing is certified or filed except by a named officer, inside agreed boundaries.

Claiming de minimis status for a filing year.

Telling a customer what a surcharge recovers.

Electing the Block 6 confidentiality certification.

Changes to classification rules or projection method.

Example output

One revenue line, annotated

Our billing and revenue-assurance agent reconciles these records; the revenue it reconciles is the revenue this page classifies.

Worksheet assembly · single revenue lineIllustrative example

Revenue line

Assembled as

Jurisdiction

System of record

Confidence

Held for

Bundled voice and data

Reported line, contribution base, provenance attached

Interstate and international

Billing extract, 31 January 2026

Held uncertified

The certifying officer, in person

As receivedTaken from the billing extract and the rating records — it reaches as far as the extract does.

What the record holds Product and jurisdiction System and as-at date Projection reasoning

Why no base call hereBase membership is an officer call under 47 CFR 54.711(a), not a model output.

ActionCertify and fileAppend provenanceSend to counsel

What the score decidesBelow the configured threshold the assembly picks up a counsel read before.

Value

Where AI adds value

The same four claims, placed at the point in the workflow where each one applies.

Where the value landsValue 01 – 04

Every revenue lineFrom the system that billed it

03Provenance

Same fund, opposite end

Our E-Rate bidding and certification agent stands on the applicant side of universal service; this page is the contributor side, and the money runs the other way.

01Approved path

A one-way clock on corrections

The Form 499-A instructions shut a decreasing revision on 31 March of the year after the filing was due; an upward correction stays owed after it, and delinquency draws interest and a remedial collection charge.

02Human review

What the Court decided, and did not

FCC v. Consumers’ Research, decided 27 June 2025 and not unanimous, reversed the Fifth Circuit en banc ruling of 24 July 2024; it left tax versus fee undecided and reaffirmed the intelligible-principle test.

04Build an evidence trail

The revenue line, the system it came from and the officer who certified stay on the worksheet.

Integrations

Typical integrations

Five system groups connect to the same agent. Which of them are in scope is decided in discovery.

Filing and administrationUSAC E-File · Form 499-A
Form 499-Q · registration

Billing and rating systemsRated events · invoices
Mediation and settlement feeds

Revenue recordsGeneral ledger · revenue books
Product and jurisdiction tables

Agent

USF contribution assembly

Reads the revenue
Assembles the worksheet
Holds for the officer

Filing and case systemsDocument management
Audit and correspondence files

Observability & evaluationOpenTelemetry · Langfuse
Supported monitoring/evaluation sources

Integration availability depends on the client's existing systems and API access.

Agent controls

Six filters between the model and the worksheet

Six filters in series, each finer than the last. Whatever survives is set out in the map below.

L6 · Outermost — last line of defenceInward → L1 · closest to the model

L6Rollback / safe modeReturn the agent to provenance assembly when evaluation or production signals degrade.Roll back

L5Version monitoringTrack model, prompt and rule changes; the due dates live in the instructions, not in 47 CFR 54.711.Track

L4TraceabilityRecord each revenue line, its system and its as-at date; the retention period is three years.Record

L3Officer releaseHold the assembly for a named officer; it governs filing, not what the contribution base includes.Gate

L2Policy guardrailsTest the assembly against the base as it stands; WC Docket 26-173 is an NPRM and changes nothing yet.Restrict

L1Confidence thresholdsRoute a thin assembly to a counsel read before the certifying officer sees it.Require review

Model coreWorksheet assembled — the lines, their systems, the projections and completeness

L1 – L2Test whether an assembly may stand

L3Puts the certification in a person's hands

L4 – L5Keep the line and the system behind it

L6Holds the worksheet unfiled when signals degrade

How Nestack evaluates it

Evaluate the whole assembly — not only the worksheet that comes out.

Coverage runs the whole depth of the workflow, and every layer is cut by slice.

Surface — the worksheet an officer certifies

Depth of coverage ▼

E1Final-output evaluationDid the assembly name the system behind each revenue line?

E2Step-level evaluationDid the agent read the right period, the right jurisdiction and the current extract?

E3Tool evaluationDid it read and write the correct revenue record and the correct filing period?

E4Confidence calibrationDo low-confidence assemblies actually attract more counsel corrections?

E5Slice evaluationHow does performance change across specific revenue categories?

E6Business outcomeHow many assemblies needed a correction before the officer certified?

Floor — the outcome the filer answers for

Failure modes

Where each failure originates in the agent

Seven failure modes, each placed where it starts inside the agent.

Agent lifecycleDirection of processing →

01 · Retrieval1 mode

IP-03

Superseded extract read

The revenue figure read is not the one now booked.

Stage gathersThe revenue, the systems, the periods and the rules

02 · Reasoning2 modes

IP-04

Invoice logic used for the line

A category right for the invoice is wrong here.

IP-06

Projection left unreasoned

A figure carries forward with no procedure behind it.

Stage proposesThe lines, their systems, dates and completeness

03 · Tool / write2 modes

IP-02

Thin assembly passed forward

An assembly moves on without the counsel read.

IP-05

Period mis-assigned

Revenue is reported in the wrong filing period.

Stage writesOnly where write access and approval policy allow it

04 · Output1 mode

IP-01

Filed, provenance unrecorded

The record shows a worksheet but not what produced it.

Stage returnsThe worksheet an officer certifies and USAC receives

05 · Change / Version1 mode

IP-07

Silent classification drift

A rule change moves a line without moving the record.

Stage tracksModel, prompt, classification rules and templates

Sev-1 · a worksheet filed without an officer Sev-2 · a wrong revenue line on the record Sev-3 · source degrades, worksheet unfiled

See the complete Telecom failure-mode catalogue →

Affected slices

One revenue category absorbs the corrections

A category-level revenue-provenance figure can read clean while one category carries most of the corrections. Nestack reports the counsel-correction rate by revenue category, not only in total.

Slice performance — reported separately, not only in aggregateIllustrative example

Slice	Failure rate	Lift	Status
Bundled and packaged services	8.6%	3.7×	Review
Interconnected VoIP revenue	6.1%	2.6×	Review
International end-user revenue	3.8%	1.6×	Watch
Interstate end-user voice	2.2%	0.9×	Normal

Bar: counsel-correction-rate lift vs. interstate-end-user-voice baseline · scale 0–4.0× · tick marks the 2.0× review threshold 2 of 4 slices over threshold

Evidence-linked improvement

What an untraceable revenue line costs

A cycle ends when the missed revision window is a standing case. That suite is what the next worksheet assembled is measured against.

Improvement cycle · five stagesSwitchback — the path turns at Improve and returns at Learn

01Detect

Counsel-correction rate rises in one revenue category.

02Diagnose

The revenue category that was right for the invoice and wrong for the worksheet is read back until one cause remains.

03Improve

Changes leave numbered, and the revenue lines behind them travel attached.

04Verify

A single failing revenue case is enough to stop the release.

05Learn

The case is kept, and the classification rules are rewritten alongside it.

Learn → DetectThe return edge. The next worksheet is measured against a suite one case longer.

Typical build scope

Twelve workstreams across six weeks

The build scope read against the delivery timeline. Week structure follows the six-week plan — discovery, sources, worksheet assembly, evaluation, integration, then production validation and handover.

Workstream Week 1Week 2Week 3Week 4Week 5Week 6

01Contribution-filing discovery and boundary work.

02Billing, rating and ledger sources.

03Revenue-category and revenue-provenance mapping.

04Revenue extract ingestion.

05Product, jurisdiction and period binding.

06Completeness scoring and counsel routing.

07Officer certification workflow.

08Billing and ledger integration.

09Classification and projection cases.

10Guardrails and officer-signing controls.

11Worksheet-trail instrumentation.

12Deployment, documentation and Agent Care handover.

12 workstreams · 6 weeks · bar shows the weeks a workstream is active — several run in parallel Final scope and sequence confirmed in discovery

Engagement tiers

What each tier includes

Rows are the capabilities named in each tier's scope. Higher tiers include everything below them.

Capability✓ in scope · — not at this tier PilotOne category, one period ProductionProduction filing workflow AdvancedMultiple categories / entities

Introduced at Pilot

Worksheet assembly to your rules✓✓✓

Named-officer certification✓✓✓

Revenue-provenance baseline✓✓✓

Introduced at Production

Reporting by revenue category—✓✓

Certification workflow in your systems—✓✓

Approved write-back—✓✓

Billing-system integration—✓✓

Introduced at Advanced

Multi-entity filing duties——✓

Cross-period provenance packs——✓

High revenue-line volume——✓

Multi-period true-up controls——✓

Build price From $5,000 From $8,000 Custom quote

Final build priceConfirmed after discovery based on integrations, workflow complexity, transaction volume, approval controls and deployment requirements.

Separate from buildBuild pricing is separate from recurring Agent Care, which covers managed monitoring, evaluations, incidents and verified improvements after launch.

What we need from you

What you bring, and what we build with it

Each input maps to a piece of build scope and a week in the delivery timeline.

You bringWe build with it

01Your revenue records as they are booked → Revenue-line mapping and provenance captureWeek 1

02Representative invoices and rating extracts → Category binding, period binding and the assembly baselineWeek 2

03Your classification rules and projection method → Classification mapping, period binding and the automation boundaryWeek 1

04Access to relevant APIs, feeds or exports → Billing, rating and ledger assessment, then integration setupWeek 2

05Worksheets you would not want certified → Classification cases and the evaluation runWeek 4

06What no revenue projection may promise → Completeness scoring, counsel routing, guardrails and certification controlsWeek 3

07A named officer, as the instructions define one → Officer certification workflow, then pilot and production validationWeeks 5–6

Nothing else is required Deployment, documentation and Agent Care handover are ours.

Delivery timeline

Four phases across six weeks

The bars are drawn to the weeks the work really takes, which is why the fifth one carries a pair.

Phase W1W2W3W4W5W6

Discovery W1

Build W2 – W3

Evaluate W4 – W5

Pilot & Launch W5 – W6

Week focus W1Contribution filing discovery, classification mapping and the automation boundary W2Source integration and the revenue-provenance baseline W3Worksheet assembly, projection logic and certification controls W4Evaluation suite, classification cases and failure-mode testing W5Billing integration, pilot periods and targeted corrections W6One contribution year run under the certifying officer, then Agent Care handover

Reading the bandEach bar spans only the weeks its own work is named for. The fifth week carries two because both are real.

At the end of W6When the worksheet file validates, Agent Care picks the agent up.

DurationSix-week plan shown · typical delivery 4–6 weeks depending on scope confirmed in discovery.

Next step · Telecom AI agent

Build a USF contribution agent around a revision window that shuts one way.

Show us how a revenue line reaches Form 499 today and who certifies it. Which way does your revision clock run — one way, because a decreasing revision expires on 31 March of the year after and an upward one does not. Red-light status under 47 CFR 1.1910 reaches the agency.

Discuss this agent →

Nestack Agents · USF contributionsAGT-TL-20 · Agent Care available after launch