New Lifeline Recordkeeping Requirements Effective Today

JSI Webinar on New Recordkeeping Rules, Feb. 25

The new Lifeline requirements were finally published in the Federal Register today. As suspected, the snow in Washington, D.C., in the last few weeks pushed back publication. The FCC has opted not to give additional time for Eligible Telecommunications Carriers (ETCs) to implement the recordkeeping requirement. Beginning today, you must retain not only a Lifeline customer’s proof of eligibility, but also any documentation required to reconcile an NLAD dispute in addition to the certification form.

The revised resale rule and the new snapshot rule’s effective dates will be August 15, 2016. More information about these rules can be found in our Jan. 27 Lifeline-related e-Lert.

JSI Webinar on Recordkeeping
To help JSI clients best comply with the new recordkeeping rule, JSI will host a webinar on Thursday, February 25 at 2 p.m. to go over the specific requirement and to provide best practices. This webinar, “Lifeline Recordkeeping: Protecting Your Customers (and Yourself),” is a continuation of our October 2015 webinar and will review Lifeline recordkeeping in general, with an emphasis on the new changes. We’ll talk about the new requirements, as well as ways to protect the information you are now required to collect and store.

The Lifeline Reform webinar is $249 for the first five connections ($50 for each additional connection from the same company). Lifeline Compliance Service subscribers will receive this webinar for free as part of their annual subscription. You’ll be sent the login information and slides shortly before the webinar begins on February 25.

Updating Materials and Procedures
JSI reminds clients that they need to update their materials for 2016 and review their company’s procedures.

Companies must update their websites, marketing materials and forms to reflect the 2016 Lifeline income guidelines. Generally, customers with incomes at or below 135 percent of the Federal Poverty Guidelines are eligible for Lifeline, but check your state’s rules as well because some use an income threshold greater than 135 percent.

Companies also must ensure that they have the proper policies and procedures in place for checking Lifeline applicants’ eligibility and to comply with the new recordkeeping requirement. Clients should revise their procedures to update the recordkeeping requirement.

If you have questions about Lifeline, please contact Tanea Foglia in JSI’s Maryland office at 301-459-7590 or Lisa McLaughlin in JSI’s Texas Office at 512-338-0473.