Companies have until March 25 to register their Lifeline representatives
The FCC’s rules establishing the new Lifeline Representative Accountability Database (RAD) were published in late December in the Federal Register, making the mandatory rules effective March 26, 2020, but carrier representatives should be registering in RAD now. The RAD is a registration system that validates the identity of service provider representatives performing transactions in the National Lifeline Accountability Database (NLAD) and the National Verifier (see our June 25 and August 19 e-Lerts for more information). All NLAD and National Verifier users must have RAD-generated ID numbers in order to access either system beginning March 26.
USAC will offer a series of RAD training sessions on February 12, February 20 and February 27. More information on this training is available on USAC’s website.
The FCC did not make changes to RAD to address industry-wide concerns about providing Personally Identifiable Information (PII) in order to receive the unique identifier. The FCC did acknowledge the privacy concerns, but only directed USAC to comply with the Privacy Act of 1974 and the Federal Information Security Management Act of 2002 to protect this sensitive information.
Any ETC representatives who are involved in Lifeline transactions in NLAD or the National Verifier, such as enrollment, eligibility checks or recertifications, must provide their full names, dates of birth and personal emails or residential addresses in order to receive a unique identifier, but the FCC has made the last four digits of the representative’s Social Security number (SSN) optional. However, representatives who decline to provide the last four digits of their SSN may not automatically be validated and may be required to provide additional documentation to verify their identity. Once assigned, the representative identification number cannot be transferred to another representative.
The RAD-generated ID number must then be provided to each service provider they work for and the service provider will use the ID number to create new or update existing NLAD and/or National Verifier account credentials for the representative. The representatives also must sign an NLAD and National Verifier User Agreement. These agreements must be resubmitted annually or within 30 days of any changes to the representative’s contact information.
Companies whose representatives are required to register under this rule, but fail to register and receive the unique identifier, will be subject to enforcement for noncompliance with this requirement.
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