As we push deeper into 2018, JSI would like to highlight several key Lifeline issues that will impact all Lifeline Providers.
New Universal Lifeline Forms
The FCC’s Wireline Competition Bureau released a Public Notice last week announcing that all eligible telecommunications carriers (ETCs) will be required to use new universal Lifeline forms no later than July 1, 2018. ETCs must use these new forms for Lifeline Initial Enrollment (FCC Form 5629) and Recertification (FCC Form 5630), as well as the One-Per-Household Worksheet (FCC Form 5631). The forms are now available on USAC’s website in both English and Spanish and are for use in all states and territories unless a state law, regulation or a state agency requires ETCs to use a pre-existing form for Lifeline subscribers in that state. ETCs do not have to wait until July 1 to use these new forms. Finally, ETCs that use noncompliant forms to claim Lifeline reimbursement for a subscriber whose initial enrollment or 60-day notice period for recertification began on or after July 1, 2018, will be subject to repayment of Lifeline funds and possible enforcement actions.
2018 Federal Poverty Guidelines
On January 18, the Federal Poverty Guidelines (FPG) for 2018 were updated and published in the Federal Register. Since income-based eligibility is set at 135% of the FPG for Lifeline, companies will need to update their Lifeline Initial Enrollment and Recertification forms with the 2018 FPGs. However, as JSI notes above, new universal forms are now available and must be in use beginning no later than July 1, 2018. Accordingly, clients may find it easier to begin using the new forms rather than updating existing forms with the 2018 poverty guidelines.
Clarification of Rule Regarding Application of Lifeline Support
In its Fourth Report and Order on Lifeline in December 2017, the FCC clarified the rule that requires the Lifeline support must first go to waive the End User Common Line Charge (EUCL). This rule clarification became effective February 15. Specifically, the FCC clarified that the rule only applies to customers receiving Lifeline-supported stand-alone voice telephone service or a bundled offering where the support is applied to the voice telephony component of the bundle. This rule does not apply to customers receiving stand-alone broadband.
Port Freeze Elimination
Another key change that came out of the FCC’s Fourth Report and Order on Lifeline was the elimination of port freeze rules. This change will become effective March 19 and eliminates the current 60-day port freeze for voice service and the 12-month port freeze for broadband. Customers will now be able to change service providers when they are not satisfied with the service they are receiving without losing their Lifeline benefit. When this change is implemented, all customers currently under a port freeze will have that restriction removed.
If you have questions regarding this information or anything Lifeline related, please contact Lans Chase in JSI’s Georgia office at 770-569-2105 or Lisa McLaughlin in JSI’s Texas office at 512-338-0473.