Lifeline Spring Cleaning; USAC Splits High Cost, Lifeline into Two Divisions

With just under two weeks to go until spring, now is a good time to discuss some necessary Lifeline “spring cleaning” for JSI’s clients.

NLAD Production Duplicates
USAC is continuing the never-ending process of removing duplicates from National Lifeline Accountability Database (NLAD). This time around, USAC is removing customers that were permitted to enroll in Lifeline with multiple companies once Lifeline went live. The process began last week with Arizona and Michigan, is continuing on to other states in two more waves. You can view the schedule on USAC’s website.

This process has two steps. During Round 1, USAC is running all customers through a third-party identity verification. If the customer passes verification with one company, but fails with the second company, the first company will keep the customer, and the second company must de-enroll the customer by the date on the schedule. As we have all experienced, the verification process has a high number of false fails causing significant distress to both your customers and staff. JSI encourages ETCs to review their “Duplicate Resolution De-Enroll Report” as soon as it becomes available and bring any anomalies to the attention of the FCC and USAC. Tanea Foglia was recently on a panel with Ryan Palmer, the FCC’s Telecommunications Access Policy Division Chief, and he expressed great interest in learning how the Lifeline and NLAD reforms were affecting rural carriers, so this is a good time to raise concerns.

Round two of the process will mirror the initial duplicate Track 1 process, in that USAC will send letters to customers directly and give them 30 days to elect which company should retain the Lifeline discount. Any customer who does not respond will be assigned to one of his or her existing companies.

Updated Eligibility Requirements
All companies must update their marketing materials, websites, and forms to reflect the 2015 Lifeline Income Guidelines. Generally, to qualify for Lifeline, a household must participate in needs-based programs or have a total household income of 135% of the federal poverty guidelines; however, some states use 150% or a different variable. Whichever threshold your state uses, be sure that your materials reflect the 2015 income levels.

JSI’s Lifeline Compliance Service clients will receive updated materials and/or instructions this week.

Hold on to Your February 497 Subscriber List
Regardless of when your company will conduct its annual Lifeline recertification in 2015, you must recertify those customers claimed on the February FCC Form 497 who were also customers on December 31, 2014. Be sure to save the subscriber list used to populate the form and note any customers who were added in 2015.

Recordkeeping Reminder
Materials relating to Lifeline must be kept for a minimum of three years. This includes proof of advertising, procedures, subscriber lists, etc. Lifeline certification forms, recertification forms, and other customer-specific information must be kept for as long as the customer has Lifeline, plus three years. Finally, a customer’s proof of eligibility (e.g., tax returns, copies of benefit cards, etc.) should only be retained long enough to verify the customer’s eligibility. Rather than keeping hard copies of documentation, ETCs may elect to keep electronic records.

USAC Announces High Cost and Lifeline Division is Splitting in Two
In a move that should have happened long ago, USAC announced earlier this month that it is splitting High Cost and Lifeline into two separate divisions, and is seeking a new Vice President of Lifeline.

Combined with statements from Commissioners Clyburn and O’Rielly about the need for further Lifeline reform and the role ETCs should play in Lifeline administration, what does this decoupling mean? Perhaps voluntary ETC participation, as mentioned by Commissioner O’Rielly on his blog, is finally coming to fruition. Or, maybe centralized Lifeline enrollment, as mentioned by Commissioner Clyburn at several speaking events, is on the horizon.

While we do not know exactly what this change portends, we do know that rural ETCs should take an active role in conversations about Lifeline reform, as you make up the greatest number of ETCs.

For more information about the changes at USAC, possible Lifeline reforms, or any of the “spring cleaning” items, you can contact Tanea Foglia in JSI’s Maryland office at 301-459-7590.

Source: Source email