JSI reminds all eligible telecommunications carriers (ETCs) that they are required to publicize the availability of the Lifeline program to reach customers who may be eligible but are not aware of the service. As well, we urge clients to review the FCC’s changes to Form 555, which is used for ETCs to report the results of the recertification of their Lifeline customers’ eligibility, now that recertification is completed on a rolling basis.

During the recent FCC Form 481 process, JSI encountered clients that had not updated their Lifeline materials to include the recent rule changes in the 2016 Lifeline Modernization Order. Many companies had not updated their websites, tariffs, marketing materials or advertising to include new requirements, such as adding broadband as a supported service, implementing minimum service standards for Lifeline, and updating eligibility qualifying programs. Pursuant to CFR §54.405, Lifeline customer outreach can be done using print, audio, video and web materials. Tariffs and terms and conditions also should be updated. In addition, ETCs may advertise with social service agencies, Tribal organizations, community centers, public schools, nursing homes, AARP and United Way.

Lifeline recertification forms should also be updated to ensure that the form contains all the relevant information and customer certifications required under FCC rules. Further, it is important that your company follows the state and federal Lifeline program requirements. JSI recommends that you update your Lifeline materials to reflect these changes.

If you have any questions regarding advertising or updated tariffs for Lifeline please contact Lans Chase in JSI’s Georgia office at 770-569-2105 or Lisa McLaughlin in our Texas office at 512-338-0473.

Changes to FCC Form 555
The FCC has recently made changes to Form 555. The next Form 555 is due by January 31, 2018.  Now that recertification is performed on a monthly rolling basis according to the subscriber’s anniversary date, the FCC has made the following changes to its Form 555.

  • ETCs will use the Detail Active Subscriber Report from National Lifeline Accountability Database (NLAD), not the February 2017 Form 497 data, to prepare the form.
  • All forms must be filed online using e-file. Paper or email forms are no longer accepted.
  • Recertification results now will be broken out by month on the annual form. ETCs will not be required to report recertification results each month, but must be able to break out monthly results for the annual filing.
    1. There is a tracking tool available on USAC’s website.
    2. This tool allows ETCs to track rolling recertification on a monthly basis and will make it easier to prepare the Form 555 in January.
  • On the January 31, 2018, Form 555, ETCs will report only July 2017 through December 2017 rolling recertification results.

If you have questions regarding rolling recertification or Form 555, please call Lans Chase in JSI’s Georgia office at 770-569-2105 and Lisa McLaughlin or Cindy Neugebauer in our Texas office at 512-338-0473.