es to an ICC dispute can't settle through negotiations, the next step is costly litigation in court. Individual disagreements over access fees run the gamut from $500,000 to $30 million in disputed fees. The Universal Service Fund The Telecommunications Act of 1996 codified universal service by establishing the Universal Service Fund (USF), which subsidizes costs in rural and high-cost (for example, mountainous) areas. The USF is paid for by contributions from long-distance, paging, and mobile carriers. Contributions are based on a percentage of revenue from these services. Carriers that mix voice and data on transmission lines that carry traffic to the Internet and to long-distance switches also contribute based on revenue from these lines. The USF additionally subsidizes services to healthcare facilities, libraries, schools, and people living below the poverty level. Every carrier, cell phone company, and paging company is required to pay a percentage of its interstate and international revenues to the fund, as are providers of interconnected VoIP traffic, which are VoIP calls to landline phones. Regulatory Issues The goal is to enable providers in rural and high-cost areas to offer services at reasonably comparable rates for similar services in urban areas. The portion of the USF that applies to schools and libraries is known as the E-rate. The E-rate subsidizes Internet access and infrastructure costs needed for high-speed Internet access. In 2000, subsidies were extended to Native American reservations. End-user line charges listed as subscriber line charges on home phone bills help subsidize the E-rate. However, with the exception of the E-rate and subsidies to rural healthcare provid- ers and schools, the USF covers only basic mobile and landline services, not broadband. The FCC is changing the rules, such that broadband will be classified as a universal service, eligible for subsidies. Changes to Access Fees and the USF In February 2011, the FCC issued a Notice of Proposed Rule Making (NPRM) that recommen