Lifeline Roundup: Enforcement Advisory, National Verifier and API Launch

The FCC has been busy this week with Lifeline-related items. The Commission first issued an enforcement advisory as a reminder for participating carriers to follow the program rules. Next it launched an interface companies can use to submit information directly into the National Eligibility Verifier. And finally, the FCC announced that the five additional states will begin using the National Eligibility Verifier on Monday.

Enforcement Advisory
On December 9, 2019, the FCC issued an
Enforcement Advisory reminding ETCs that they are ultimately responsible for complying with all FCC rules regarding the Lifeline program. ETCs enrolling in and seeking reimbursement for Lifeline subscribers are required to certify that they are following the Lifeline program rules. Per the Enforcement Advisory, companies that violate Commission rules could be subject to penalties.

The FCC created the National Lifeline Accountability Database (NLAD) to prevent Lifeline subscribers from receiving duplicative support and the National Verifier to make eligibility determinations using information provided by both the ETC and consumers. Both systems enhance the FCC’s efforts and goal to eliminate fraud and waste in the Lifeline program. However, the FCC reminds ETCs that it is their responsibility to assure the accuracy of the information that they submit to the National Eligibility Verifier and that they are in strict compliance with Commission rules for the Lifeline program.

ETCs also are reminded that they should have policies and procedures in place to ensure compliance with all Lifeline rules and ensure the accuracy of the information that the ETC submits as part of the initial eligibility process, the recertification process, and the Lifeline claims reimbursement process. ETCs are also responsible for the accuracy of information provided by its employees, agents, contractors and representatives. ETCs that violate FCC rules regarding the Lifeline programs may be subject to penalties set by the Commission which may include monetary fines, as well as recovering fraudulently obtained Lifeline reimbursements, and possible penalties from applicable state regulatory entities and the U.S. Department of Justice.

National Eligibility Verifier API
The FCC also launched the new
application programming interface (API) that USAC has been testing. The interface will be used by participating carriers to submit information when verifying a subscriber’s Lifeline program eligibility. The API will allow ETCs to send an applicant’s information directly to the National Eligibility Verifier to check eligibility for potential Lifeline applicants directly through the carrier’s systems. USAC has been working with carriers on API testing in the pre-production phase and has now fully launched the API. The online consumer portal will still be available after the API launches.

Five States Added to National Eligibility Verifier
As well, the Wireline Competition Bureau just
announced the December 16, 2019, soft launch of five additional states: Florida, Illinois, Minnesota, Ohio and Wisconsin into the National Eligibility Verifier.  The soft launch period allows time for the ETCs to become familiar with the National Eligibility Verifier. ETCs in these states should not begin the recertification process for Lifeline subscribers as of December 16, 2019. For recertification of subscribers that are already in process, those should be completed by February 21, 2020. The hard launch in these states will be announced at a later date.

If you have any questions about the Enforcement Advisory or Lifeline program requirements, or you are interested in purchasing JSI’s Lifeline Procedures Guide that can assist you with all compliance requirements for the federal Lifeline program rules, 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.