8 11, 2021

FCC Pauses Elimination of Lifeline Support for Voice-Only Service

2021-11-08T14:14:30-05:00November 8, 2021|e-Lerts|

On Friday, November 5, 2021, the FCC paused for one year its plan to eliminate Lifeline support for eligible customers that subscribe to voice-only service. The current $5.25 per month of support will remain in effect for all eligible voice-only customers until December 1, 2022. During that time, the FCC will evaluate whether the changed circumstances warrant longer-term modifications of the Lifeline program.

Lifeline support for voice-only service originally was scheduled to end on December 1, 2021. Companies should make sure that their billing systems are updated to ensure the continued Lifeline support to eligible voice-only customers.

Please contact Liz Kayser at 512-338-0473 or Lans Chase at 770-569-2105 if you have any Lifeline-related questions or need assistance.

21 10, 2021

Lifeline Support for Voice-Only Service Ends December 1

2021-11-02T12:56:53-04:00October 21, 2021|e-Lerts|

In its effort to transition Lifeline support for eligible subscribers from voice to broadband services, the FCC has been phasing down support for voice-only Lifeline services. The current $5.25 per month of support is scheduled to end on December 1, 2021, unless the eligible Lifeline subscribers are in census blocks where there is only one Lifeline provider. Companies not in one of the exempt census blocks should make sure to notify their voice-only Lifeline customers of the upcoming federal support changes as their bills will increase.

Companies also may be required to file revisions to their Lifeline tariffs to reflect this change in support. If a Lifeline customer has since subscribed to a qualifying bundle which includes voice and broadband, the discount can be moved to the broadband portion of the bundle and the customer will be able to receive the $9.25 per month Lifeline discount.

The FCC issued a Public Notice on June 1, 2021, announcing which census blocks USAC has determined meet the criteria to continue receiving the $5.25 Lifeline support for voice-only service. Eligible customers can continue receiving the $5.25 Lifeline support for voice-only service in these identified census blocks.

Please contact Liz Kayser at 512-338-0473 or Lans Chase at 770-569-2105 if you have Lifeline-related questions or need assistance to determine if any census blocks on the FCC’s list are located in your company’s service area.

12 05, 2021

EBBP Officially Launches Today; FCC Issues Warning to Providers

2021-11-02T13:11:58-04:00May 12, 2021|e-Lerts|

Yesterday, the FCC issued an Enforcement Advisory in advance of today’s launch of the Emergency Broadband Benefit Program (EBBP). The advisory reminds providers participating in the EBBP of their obligations to comply with the program’s rules. Providers must ensure that existing Lifeline customers give their informed affirmative consent to participate in the EBBP. Under the EBBP rules, customers can choose not to apply their emergency broadband benefit with their existing Lifeline provider without jeopardizing their Lifeline service.

The FCC has heard that some providers may be linking EBBP enrollment to implementation of technical changes necessary to retain the subscriber’s existing service or automatically enrolling subscribers that provide information needed for another purpose. The FCC warns that these practices may be deceptive and may undermine the integrity of the EBBP and can threaten to put subscribers at risk of losing their existing Lifeline service. The FCC emphasizes that providers must ensure that communications to consumers about the EBBP are clear, accurate, and not misleading as to the nature of the program, the program’s eligibility requirements, and the timing of the program and application process.

The advisory states that at a minimum, providers must make it clear that subscribers:

  1. may continue their existing Lifeline service without enrolling in the EBBP;
  2. may choose to take EBBP benefits from a service provider other than their existing Lifeline provider; and
  3. may transfer EBBP benefits to another provider at any time.

The advisory also highlights that “the provider must also retain documentation demonstrating that, having received such disclosures, the household provided affirmative consent to applying their Emergency Broadband Benefit to the service received from the EBB provider. Broadband providers may be required to provide such documentation to demonstrate compliance during an audit, validation, or investigation.”

Further Guidance on EBBP Questions
USAC has clarified a couple of key issues regarding the EBBP process that were causing confusion. First, many companies have asked how to handle partial monthly service under the EBBP. Although the EBBP Order seemed to indicate that using a uniform snapshot would not require a provider to claim a prorated amount when seeking reimbursement, USAC has now said that is not the case.  USAC states that:

“the EBB reimbursement cannot exceed the EBB discount that the provider actually passed through to the consumer for that month. So if the prorated price of the service is less than $50 for that month, then the provider must ensure it is not claiming reimbursement for more than the price of the service in that month.”

Secondly, while the rules are clear that providers cannot disconnect EBBP customers for non-payment, it was not clear if providers could downgrade a customer’s broadband service to a lower-priced plan for non-payment. USAC clarifies that:

“EBB Program rules do not prohibit a provider from downgrading a subscriber’s broadband service if the subscriber falls behind on their portion of the bill for the EBB-supported service. Providers downgrading a customer’s EBB-supported service due to non-payment are urged not to downgrade the EBB-supported service without the subscriber’s knowledge.”

If you have any questions about the EBBP, please contact Lans Chase at 770-569-2105 or John Kuykendall at 301-459-7590. If you would like JSI’s enrollment and customer notice templates, please contact Janee Devis at 301-459-7590.

8 03, 2021

FCC Announces Timeline to Participate in the Emergency Broadband Benefit Program

2021-11-02T13:15:10-04:00March 8, 2021|e-Lerts|

JSI’s March 16th Webinar Will Equip Participants for Implementation

In our March 1st e-Lert, we told you about the FCC’s Report and Order to establish the Emergency Broadband Benefit (EBB) program and its directive to the Wireline Bureau to release multiple Public Notices announcing timelines and other details. The first Public Notice was released late last week and contains two sets of timelines to submit information if your company decides to participate in the program – one for eligible telecommunications carriers (ETCs) and their affiliates that provide service within the same state (together known as Providers) to file an “election” with USAC and the other for non-ETCs to file an application with the FCC for approval to participate in the EBB program.

Most JSI clients fall under the category of Providers and can begin submitting their elections to participate in the program as soon as Thursday, March 11. We explain more about this process below. Entities that are not ETCs or do not have any affiliated ETCs within the state in which they provide service have a filing window that opens Monday, March 8 and closes Monday, March 22. These non-ETC entities will receive automatic program approval from the FCC if they meet certain criteria, including if they are affiliated with an ETC that serves in another state. If they don’t meet the criteria for automatic approval, they can file and receive approval under an expedited basis. If your company falls in this non-ETC category, please contact JSI as soon as possible if you would like to know more about this process or would like JSI’s assistance in filing an application with the FCC.

JSI encourages clients to diligently consider participating in the program and urges those that decide to move forward to be prepared to implement the program in a way that minimizes potential problems caused by the program’s limited duration. Our March 16 webinar will review how to participate in the program and how it will be administered, but also will provide recommendations to address issues that could arise for either your existing Lifeline subscribers or new customers that qualify under the additional criteria of the EBB program when the program ends.

Timeline for Providers
Under the Consolidated Appropriations Act, which established the program, Congress determined that existing ETCs don’t need to seek approval to participate in the EBB program, but only need to file an “election” with USAC. ETCs are entities that already are obligated to offer Lifeline services to qualified low-income individuals and include: ILECs, CLECs or wireless carriers that receive “frozen” support, Rural Broadband Experiment and CAF Phase II auction winners, and Rural Digital Opportunity Fund (RDOF) auction winners that have received ETC designation. In the Report and Order, the FCC ruled that affiliates of ETCs also qualify as Providers under the umbrella of the ETC if they provide service within the same state as the ETC.

The FCC announced the March 11 election application start date for Providers, but no deadline was provided. It is possible that one may be announced in a subsequent Public Notice, which will also provide the program’s start date. The program must begin no later than 60 days after the release of the Report and Order, which would be April 26. Given that the filing for Providers is an election open to all ETCs and in-state affiliates and is not a “first come, first served” application process, we urge clients not to rush to submit an election without thoroughly considering the pros and cons associated with implementing the program.

According to the Public Notice, Providers must submit a form to USAC, which USAC will make available “soon” on the link provided at the end of the notice (as of publishing of this e-Lert, the link was not yet available). Providers will then email that form to EBBElection@usac.org. JSI will be available to assist companies with completing and submitting the form.

Expect to see requests for the following information required by the Report and Order on USAC’s form:

  • The states in which the provider plans to participate in the EBB program;
  • A statement that the provider was a “broadband provider” in each such state as of December 1, 2020;
  • A list of states where the provider is an existing ETC, if any;
  • A list of states where the provider received FCC approval, whether automatic or expedited, to participate, if any;
  • Whether the provider intends to distribute connected devices under the EBB program;
  • A description of the Internet service offerings for which the provider plans to seek reimbursement from the EBB program in each state;
  • Documentation demonstrating the standard rates for those services; and
  • Any other administrative information necessary for USAC to establish participating providers in the EBB program.

Additionally, participants in the EBB Program will need an FRN, SPIN and have registered with the System for Award Management (SAM) in order to receive reimbursement. While registering with SAM is not required at the time of election, the Report and Order “strongly recommends” that Providers start the registration process “immediately” because of the time it may take for the registration to become effective. You can register with the system at https://www.sam.gov/SAM/. JSI is familiar with SAM and its cumbersome process so please let us know if you would like our assistance if you need to register. Providers that have already registered with SAM don’t need to reregister, but should check to see if its SAM registration needs to be renewed.

For more information about the EBB program or how JSI can assist your company in making the election with USAC or filing an application with the FCC, please contact Lans Chase at 770-569-2105 or John Kuykendall at 301-459-7590.

1 03, 2021

FCC Establishes the Emergency Broadband Benefit Program

2021-11-02T13:15:23-04:00March 1, 2021|e-Lerts|

JSI to Hold Webinar on March 16

The FCC late last week adopted a Report and Order to establish the Emergency Broadband Benefit (EBB) Program. The EBB program will provide eligible households with discounts off the cost of broadband service and certain connected devices for the duration of the emergency COVID-19 pandemic (see our Feb. 24th e-Lert). The Report and Order sets forth major aspects of the program, some of which are summarized below, and directs the Wireline Bureau to announce filing deadlines and other details in Public Notices – one of which is due within the next few days – that will provide the initial filing deadlines. The FCC will announce the EBB program’s start date, along with other key dates, this month or next.

JSI will hold a webinar on Tuesday, March 16th at 2 p.m. EDT to provide broadband providers with the information they’ll need to assess whether to participate in the program. We will review the pros and cons associated with being an EBB provider and go through the steps required to participate in the program and receive reimbursement. Registration for this webinar is $249 per company. You can sign up here.

The EBB program was established as part of the Consolidated Appropriations Act of 2021. Congress tasked the FCC to create the $3.2 billion program to provide qualifying low-income households with discounts on their broadband services and equipment. Participating broadband providers will receive reimbursement from the EBB for monthly discounts off the standard rates for an Internet service offering and associated equipment, up to $50.00 per month (up to $75.0 per month on Tribal lands). Providers that supply customers with a connected device will be eligible for a single reimbursement of up to $100.00 for the connected device, if the charge to the eligible household for that device is more than $10.00 but less than $50.00 (a participating provider may receive reimbursement for only one supported device per eligible household).

As for eligibility, the good news is that all eligible telecommunications carriers (ETCs) can elect to participate in the program for itself or any of its affiliates. This means that ILECs, CLECs and wireless carriers that receive “frozen” support, Rural Broadband Experiment and CAF Phase II auction winners, and any Rural Digital Opportunity Fund (RDOF) auction winners that have received ETC designation can participate or designate one or more of their respective affiliates as a participant. Further, ETCs are not required to participate in the program; it will be a voluntary election. Broadband providers that have no affiliated ETCs can also participate in the program under either an automatic or expedited approval process depending upon whether the provider meets certain criteria.

The program will utilize some of the existing mechanisms used by the FCC in its Lifeline program, such as the National Lifeline Eligibility Verifier (National Verifier) and National Lifeline Accountability Database (NLAD) and the Representative Accountability Database (RAD). But the FCC declined to impose Lifeline’s minimum service standards. Accordingly, participants in the EBB program will be able to offer discounts and receive reimbursements for any broadband services they offer, regardless of the speed.

One major issue with the program is that, at this point, it is only temporary and will end within the earlier of six months or until the program’s funds are exhausted. To ensure that households are informed that the benefit will terminate, the Order adopts procedures to notify all stakeholders of the forecasted end of the program, to disburse the remaining funds equally to providers, and to allow for a transition to ending the disbursement to households.

For more information about the EBB program or how JSI can assist your company in making the election, please contact Lans Chase at 770-569-2105 or John Kuykendall at 301-459-7590.

24 02, 2021

FCC Circulates Emergency Broadband Benefit Program Order Before Vote

2021-11-02T13:15:37-04:00February 24, 2021|e-Lerts|

FCC Acting Chairwoman Jessica Rosenworcel circulated a Report and Order this week that proposes to adopt the Emergency Broadband Benefit Program (EBBP). In the Consolidated Appropriations Act of 2021, Congress tasked the FCC to create the $3.2 billion program to provide qualifying low-income households with discounts on internet service, computers, and tablets to provide additional relief to vulnerable Americans during the pandemic. Acting Chairwoman Rosenworcel emphasized that, “from work to healthcare to education, this crisis has made it clear that without an internet connection too many households are locked out of modern life.” The EBBP would help give struggling households a new way to make access to broadband—and the vital healthcare, education, and telework options it facilitates.

The EBBP would provide eligible households with a discount of up to $50 per month ($75 on Tribal lands) off the cost of broadband service and certain connected devices for the duration of the emergency COVID-19 pandemic. The proposed Report and Order also would open the program to all types of broadband providers to be qualified for reimbursement, would require providers to service eligible households in order to be reimbursed, and encourages eligible households to indicate interest in the program. The eligibility criteria for households includes: qualifying for Lifeline; receiving free or reduced-price school lunch or breakfast; experiencing substantial income loss since February 29, 2020; receiving a Federal Pell Grant; or meeting a participating provider’s existing low-income or special COVID relief program.

The EBBP could potentially have a significant impact on rural connectivity and broadband subscription until the COVID-19 pandemic is declared over. Rural broadband providers may want to start determining how many customers could benefit from this program, and how it could also help add subscribers who could otherwise not afford broadband so that no one is left on the wrong side of the digital divide during the pandemic.

JSI will follow up with the details of the EBBP Report and Order once it is released. If you have questions about the EBBP or other COVID-19 relief programs for broadband, please contact John Kuykendall at 301-459-7590.

5 01, 2021

Lifeline Recertification Form 555 Due February 1

2021-11-02T13:19:39-04:00January 5, 2021|e-Lerts|

All eligible telecommunications carriers (ETCs) must submit and certify their FCC Form 555, the annual Lifeline ETC certification form, by February 1, 2021 (January 31st falls on a Sunday this year), via the Universal Service Administrative Company’s (USAC) E-File system.

Although most states had moved to the Lifeline National Verifier by the end of 2019, if an ETC conducted any recertifications, it is still responsible for reporting the results of such recertification on Form 555. Further, because Form 555 contains required certifications of compliance with Lifeline rules, all ETCs must submit the form even if they did not conduct any recertifications in 2020.

JSI is available to assist you with the Form 555 by filing it through E-File or by guiding you through the process, depending on your needs. If you would like JSI to submit the form in E-File, your company officer or general contact will need to create an account to designate someone at JSI as an Authorized Agent through the USAC website. Form 555 must also be filed at the FCC, applicable state commissions and tribal governments where applicable. JSI can also assist you with these filings.

If you have any questions or you would like JSI’s help with this reporting obligation, please contact Lans Chase in JSI’s Georgia office at 770-569-2105 or Terri DeLong or Cindy Neugebauer in JSI’s Texas office at 512-338-0473.

19 11, 2020

Lifeline Reverification & Recertification Waivers Extended through Feb. 2021

2020-11-19T13:52:36-05:00November 19, 2020|e-Lerts|

The FCC has again extended the waivers for Lifeline reverification and recertification and de-enrollment activity, this time until February 28, 2021. This waiver also extends the relaxed usage requirements and general de-enrollment procedures until February 28th. Due to this new extension, recertification for anniversary dates from April 14, 2020, to May 29, 2021, are now on hold. Reverification activity is also on hold.

Due to the pandemic, the FCC made it easier for potential Lifeline subscribers to qualify for Lifeline through income requirements by temporarily waiving the requirement to provide at least three consecutive months of income documentation. USAC also will accept driver’s licenses or state identification cards which expired on or after March 1, 2020, to complete a Lifeline application.

The FCC also streamlined Lifeline enrollment for qualifying customers who reside on rural tribal areas (See JSI’s April 6 and May 4 e-Lerts for more information).

If you have any questions about the recertification, reverification, de-enrollment, income-related qualification or tribal Lifeline, please contact Lans Chase in JSI’s Georgia office at 770-569-2105.

17 09, 2020

Lifeline Minimum Service Standards Set to Change Dec. 1

2021-01-05T15:18:20-05:00September 17, 2020|e-Lerts|

Voice-only discount also changes Dec. 1

JSI clients are reminded of the annual updates to the Lifeline minimum service standards, which become effective December 1, 2020. The new minimum service standards for fixed (home) service providers will be:

  • Fixed voice: No minimum service standard
  • Fixed broadband speed: Increases to 25/3 Mbps (Exception: If the service provider does not offer any generally available residential fixed broadband packages at the subscriber’s residence that meet the 25/3 Mbps standard, it can still receive support for the highest-performing generally available fixed broadband offering of at least 4 /1 Mbps.)
  • Fixed broadband usage: 1024 GB of usage per month

JSI emphasizes that in cases where a Lifeline-supported service will no longer meet the standard (or fall under the exception) on December 1, affected customers must be notified at least one month in advance. The customer notification should inform the customer that their service no longer qualifies for Lifeline and offer the option to (1) switch to a Lifeline-supported plan, or (2) be de-enrolled from Lifeline and pay the full price for their current plan. Please contact JSI if you would like to discuss or need clarification as to when customer notification is required.

Lifeline Voice Discount Phase Down
Pursuant to the FCC’s 2016 Lifeline Modernization Order, the current Federal Lifeline discount of $7.25 for voice service continues phasing down to $5.25 effective December 1, 2020. The phase down of the Lifeline discount will only affect Lifeline customers with voice-only service or a bundle that includes broadband service that does not meet the minimum service standard.

Companies will be required to lower the Lifeline discount currently given to voice customers from $7.25 to $5.25. Companies also may be required to file revisions to their Lifeline tariffs to reflect this change. If a Lifeline customer has since subscribed to a qualifying bundle which includes voice and broadband, the discount can be moved to the broadband portion of the bundle and the customer will not see a change to the Lifeline discount.

If you have any questions about the new minimum service standards or the Lifeline voice discount phase down, please contact Lans Chase in JSI’s Georgia office at 770-569-2105.

19 08, 2020

Lifeline Reverification & Recertification Waivers Extended to Nov. 30

2021-01-05T15:19:15-05:00August 19, 2020|e-Lerts|

The FCC has again extended the waivers for Lifeline reverification and recertification and de-enrollment activity, this time until November 30, 2020. This waiver also extends the relaxed usage requirements and general de-enrollment procedures until November 30th. Due to this new extension, recertification for anniversary dates from April 14, 2020, to February 28, 2021 are now on hold.

Due to the pandemic, the FCC made it easier for potential Lifeline subscribers to qualify for Lifeline through income requirements by temporarily waiving the requirement to provide at least three consecutive months of income documentation. USAC also will accept driver’s licenses or state identification cards which expired on or after March 1, 2020, to complete a Lifeline application.

The FCC also streamlined Lifeline enrollment for qualifying customers who reside on rural tribal areas. (See JSI’s April 6 and May 4 e-Lerts for more information.)

If you have any questions about the recertification, reverification, de-enrollment, income-related qualification or tribal Lifeline, please contact Lans Chase in JSI’s Georgia office at 770-569-2105.

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