Clients Should Be Preparing Now to Launch Efforts in April
JSI clients that perform their own Lifeline customer recertifications are urged to begin preparing for the first monthly rolling recertification process, that start with the July 1, 2017, customer anniversaries. The new rules became effective January 1, 2017, and now require carriers to complete recertification each month to verify customer eligibility for anniversary dates of July 1 or later. We recommend that service providers plan to start the process at least 90 days (April 2 for those with July 1 recertifications) and no less than 65 days (April 27) before the anniversary date. This should allow for all recertification activities to be completed by the subscriber’s anniversary date, including de-enrollment from the Lifeline program. During its webinar last week, the Universal Service Administrative Company (USAC) characterized rolling recertification as the most important change in the 2016 Lifeline Modernization Order.
Before contacting customers directly, carriers should first attempt to verify their eligibility through their state’s eligibility database, if available. If eligibility can’t be verified through a state database, the service provider then should contact the customer directly.
Customer notification must be in writing, separate from the monthly bill, and request that the customer confirm their continued eligibility as part of a qualifying program or based on their income. Customers have a strict 60-day response period, including the first and last day. The company can follow up with the customer within the 60-day period. Customers who do not respond during this period are no longer eligible for the Lifeline benefit.
Failed and non-responsive customers must be de-enrolled from Lifeline within five business days after the subscriber’s 60-day response period. Deadlines must be strictly adhered to and the process must be completed by the customer’s anniversary date in order for the company to remain compliant. Customers may be recertified in batches as long as each of the recertification activities in the process is completed for all customers in the batch (e.g., all customers with July anniversary dates must be completed by July 1). USAC recommends batch recertification be made in one- or two-month batches.
JSI has a number of Lifeline-related resources available for clients, including customer contact letter templates and recertification forms. If you’d like any of these resources or to discuss rolling recertification further with one of JSI’s Lifeline team members, pleases contact a member of our team by clicking the button below.