In early January 2016, JSI’s Tanea Foglia, along with representatives of NTCA – The Rural Broadband Association and WTA met with the legal advisors to FCC Commissioners Pai and Rosenworcel, the associate bureau Chief of the Wireline Competition Bureau, and several staff members from the FCC’s Telecommunications Access Policy Division to discuss the Commission’s various Lifeline reform proposals.

During each of these ex parte meetings on January 7, January 8 and January 11, 2016, they discussed the Wireless ETCs’ pending Petition for Reconsideration of the Lifeline Second Report and Order, as well as the new snapshot rule. JSI and the associations explained to the FCC staffers that the snapshot rule, which requires ETCs to report their number of Lifeline subscribers as of the first of each month for purposes of Lifeline reimbursements, will result in a number of situations where RLEC ETCs provide Lifeline benefits to eligible low-income consumers without receiving reimbursement for such service. They recommended the Commission allow RLEC ETCs to take a snapshot of their number of subscribers as of their carrier-specific billing dates.

They also discussed their carriers’ desire for a more efficient Lifeline eligibility verification process, possibly one that leverages existing state eligibility databases. In regards to ETC designations, the group urged the FCC to refrain from streamlining the ETC designation process because it could fail to fully consider support recipients’ qualifications, experience or commitment to universal service.

These ex partes were in addition to several filings JSI did in conjunction with NTCA and WTA in late 2015. In September 2015, JSI and NTCA submitted reply comments to the FCC regarding its proposed changes to the Lifeline program. As well, JSI filed joint comments with NTCA and WTA in support of the Wireless ETC Petitioners Petition for Reconsideration regarding the FCC’s Lifeline Reform Order. In October, the group filed joint reply comments in regards to those who opposed the Petition for Reconsideration.