USAC recently delayed the full implementation timeframe for its new Lifeline Representative Accountability Database (RAD) from the end of 2019 to “TBD.” As noted in our June 25, 2019, e-Lert, the RAD is a registration system that validates the identity of service provider representatives performing transactions in the National Lifeline Accountability Database (NLAD) and the National Verifier (NV).

RAD’s implementation Phase 1 began June 25 with service provider representatives self-registering for their Representative IDs. Phase 2 testing has been on-going in the pre-production environment to link the Representative IDs to existing and new user accounts in the NLAD and NV, as well as testing for different transactions and errors in both systems. USAC has updated the timelines on its website for Phase 3 full implementation in which the Representative ID must be included with all transactions. Originally, Phase 3 full implementation was scheduled for 4th Quarter 2019. Now USAC’s website shows that Phase 3 is “TBD”.

This change may be good news for the rural providers as JSI is hearing that the FCC may be working on changes to RAD requirements to distinguish direct employees of Eligible Telecommunications Carrier (ETC) service providers from third-party sales agents that work with mobile providers. These third-party sales agents typically receive incentives for signing up Lifeline customers. RAD was developed because the FCC was concerned this incentive structure increased potential fraud and abuse of the Lifeline program.

Several rural service providers and various trade associations have expressed major concerns with RAD and have met with the FCC over the past few weeks to express these concerns. Below are some of these concerns:

  • RAD registration does not distinguish between direct employees of the ETC and third-party sales agents who typically receive incentives to enroll Lifeline customers;
  • Anyone working with Lifeline and working in NLAD or the NV systems must provide highly-sensitive personally identifiable information (PII) for an ETC to be compliant and for the individual to access NLAD or the National Verifier systems;
  • Union contracts may not permit members to require employees to submit PII to the RAD to receive a Representative ID as a condition of employment;
  • Concerns with the storage and safeguard of individuals’ PII;
  • Ability to deactivate his/her registration and have PII removed from USAC’s systems once the employee no longer requires access to NLAD/NV or when the person leaves the company; and
  • Noted procedural irregularities that have not been corrected, such as the lack of approval under the Paperwork Reduction Act (PRA) for information collection and use of information in the RAD.

Stay tuned and be on the lookout for notices from USAC that may provide more details on upcoming changes to the RAD implementation process. In the meantime, JSI recommends that clients may want to wait before having representatives register in RAD. If you have questions regarding the information in this update or any questions about Lifeline, please contact Lans Chase at 770-569-2105 in JSI’s Georgia office or Lisa McLaughlin in JSI’s Texas office at 512-338-0473.