Deadline Approaches for Companies to Elect to Have USAC Conduct 2017 Lifeline Recertification
New rules from the Lifeline Modernization Order require eligible telecommunication carriers (ETCs) to conduct Lifeline recertification on a 12-month rolling basis based on the anniversary date of each subscriber’s service initiation date. The rules regarding rolling recertification become effective January 1, 2017, however, no re-certifications are required in 2017 for anniversary dates that fall from January through June 2017. Beginning with anniversary dates on July 1, 2017, service providers must recertify customers according to their anniversary date. In order to be in compliance, service providers should plan to initiate rolling recertification well in advance of the customer’s anniversary date because customers have 60 days to respond and providers must de-enroll non-responding customers by their anniversary date. Therefore, JSI recommends that companies begin the rolling recertification process at least 90 days prior to the customer’s anniversary date.
ETCs have the option to elect to have the Universal Service Administrative Company (USAC) conduct their 2017 Lifeline recertifications and have until December 15, 2016, to notify USAC about their choice. Companies may have USAC conduct its rolling recertification by completing the recertification election spreadsheet and sending the completed spreadsheet to USAC via email. This applies both to companies that did not elect to have USAC conduct their 2016 annual recertification and ETCs that want to revoke their election made in 2016. Please note that ETCs in states that manage Lifeline recertification (e.g., Texas) may not use USAC. Companies can limit the study area codes (SACs) for which USAC performs the recertification process.
When considering whether to have USAC to conduct Lifeline rolling recertification, remember that recertification prior to January 1, 2017, was done on an annual basis, but may now have to be conducted on a monthly basis. As a result, the rolling recertification process may be more labor intensive and more difficult to manage internally.
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