Clients should begin planning now

The FCC’s new Lifeline Snapshot rule takes effect on August 15, 2016, and all ETCs must be prepared to comply with the new rule no later than September 1, 2016. The new rule requires ETCs to take a “snapshot” of the number of eligible Lifeline subscribers they have on the first day of each month and use this number on their monthly FCC Form 497. The rule requires all ETCs to use the uniform snapshot date to request reimbursement from USAC for providing Lifeline support. Previously, carriers could use their company’s normal billing date.

Although the first required snapshot date will be September 1, ETCs do not need to wait until the deadline to switch to the first day of the month. JSI recommends that clients begin preparing now to ensure they have enough time to make any changes necessary to their billing systems. The snapshot date is the first day of the month, even if that day falls on a holiday or weekend. Subscribers who are enrolled and de-enrolled between snapshot dates are not included in the Form 497 for reimbursement.

Companies in default states, such as Texas, that receive a monthly list of eligible Lifeline subscribers from a state Lifeline administrator are also required to use the first day of the month snapshot date for filing the Form 497. Carriers are not required to provide a copy of the snapshot records with the Form 497, but should keep copies of the snapshot for audit purposes.

Resale of Lifeline Rule
Carriers also have until August 15 to change any practices necessary to comply with the requirements of the Lifeline resale rule. After that date, only ETCs that provide Lifeline service directly to subscribers are eligible to receive Lifeline support, eliminating incumbent LECs’ obligation to resell retail Lifeline-discounted service. Again, ETCs do not need to wait until the effective date to make the transition.

Retention of Proof of Eligibility
We also remind clients that they must retain any documents customers present to prove their Lifeline eligibility. Carriers must keep this documentation for as long as the customer has Lifeline, plus an additional three years. Companies must ensure they have the proper security measures in place. For instance, those that retain documents electronically must have firewalls and boundary protections, protective name conventions, user authentication requirements and usage restrictions. ETCs who retain hard copies must also keep customers’ eligibility information secured, e.g. locked in a secure file cabinet. If your company has not already begun retaining proof of eligibility information, you must begin doing so now. If you’d like more information on these documentation rules and ways to protect those sensitive documents, you can purchase a recording of JSI’s recent webinar, “Lifeline Recordkeeping: Protecting Your Customers (& Yourself).”

If you have any questions or you would like JSI’s help with any of these Lifeline changes, please contact Lans Chase in JSI’s Georgia office at 770-569-2105 or Lisa McLaughlin in our Texas office at 512-338-0473.

Source: JSI e-Lert