Posted March 26, 2013
By Scott R. Flick and Lauren Lynch Flick
At the end of every quarter, TV stations across the land must electronically file with the FCC a Form 398--The Children's Television Programming Report. However, stations attempting to do that filing for the first quarter of 2013 are discovering that the FCC's online filing system for those forms ends with the fourth quarter of 2012. As a result, it is preventing many TV stations from preparing their electronic report for the first quarter of 2013, rejecting all efforts to select "First Quarter 2013" as the report to be filed.
At first, it appeared that the FCC had bought into the "Mayan Prophecy" that the world was ending in December 2012, marking the end of the Mayan (and perhaps the FCC's) calendar. And, had the world actually ended in 2012, filing a Form 398 covering the first quarter of 2013 would have indeed ranked low on most broadcasters' "to do" lists. However, with 2013 well under way, TV stations are now flummoxed as to how to get the FCC's electronic filing system to allow the preparation and filing of a first quarter 2013 kidvid report.
Fortunately, there is an answer, but it requires a little background. We reported in a 2010 KidVid Advisory that the FCC had suddenly begun requiring stations to enter their FCC Registration Number and password as the final step before permitting a Form 398 to be filed. As it turned out, this was apparently the first step in creating a new FCC Form 398 filing system.
In July 2012, the FCC released what it termed an "alternate" link for accessing the Form 398 filing system and updated its user manual to indicate that the web address for filing the form is the alternate link. However, the FCC's main Children's Television Programming page on the Internet continues to show that the original link is the one to use for filing a Form 398, and until this quarter, that original link has continued to work correctly. Of course, most TV stations just have the original link bookmarked, and have no reason to visit the FCC's website/user manual to see if the filing procedures have been changed. Adding to the confusion is the fact that following the original link does not generate a warning or error message, but takes you to the same filing page stations have been using for years. It is only when a station tries to create a report for first quarter 2013 that a problem arises.
As a result, the "alternate" link is not just an alternate any more, and must be used to file all post-2012 kidvid reports. So, from here on out, use this link for filing your kidvid reports: http://licensing.fcc.gov/KidVidNew/public/filing/submit_login.faces
Note also that, at the new link, you will have to provide your call sign, Facility ID, FCC Registration Number and Password to even be able to log into the system. This is all information you previously needed to file a Form 398, but you supplied it at the end of the filing process. Now, you can't even get started without it. For TV stations that have been banging their heads against the wall trying to figure out why they can't prepare, much less file, their Form 398, using the alternate link should solve that problem. It may be a small problem compared to the end of the world, but then the Mayans never had to deal with online filing.