On September 30, 2015, JSI and NTCA–The Rural Broadband Association submitted reply comments to the FCC regarding its proposed changes to the Lifeline program as outlined in its Second Further Notice of Proposed Rulemaking.

In these reply comments, JSI and NTCA urged the FCC to:

  • Remove providers from the Lifeline subscriber eligibility verification process, as taking this responsibility out of the hands of providers will no doubt improve the efficiency and integrity of the program, for the benefit of consumers and ratepayers alike;
  • Carefully coordinate the modernization of the Lifeline and the High-Cost programs, specifically with respect to giving consumers the choice of voice or broadband service, together or on a standalone basis;
  • Adopt uniform Lifeline forms and hold faithful in all respects to the carefully designed statutory provisions and rules regarding the Eligible Telecommunications Carrier (ETC) designation process;
  • Adopt uniform Lifeline enrollment and recertification templates; and
  • Postpone using the National Lifeline Accountability Database (NLAD) for Lifeline disbursements until certain veracity and transparency issues are resolved.