Lee Schafer

NaLA Develops and Promotes Self Regulation in Lifeline Industry

The mission of the National Lifeline Association (NaLA) is to support the Lifeline Industry through “education, cooperation, and advocacy.” To further this goal, NaLA focuses on developing and implementing new self regulation processes. These processes strengthen the effectiveness of the Lifeline Program and bridge the digital divide for low-income Americans.

Self Regulation in Lifeline Industry

In the past three years, NaLA has grown from approximately 80 to more than 3,000 members. Represented within its member base are a variety of industry professionals, including Lifeline Providers (ETCs), Distributors, Agents, and other advocates.

Typically, Lifeline Providers, Distributors, and Agents approach self regulation individually. However, NaLA recognizes the benefit of resources that standardize Lifeline training and education. This realization led to development of a program for Lifeline Agent training, which launched in Spring 2018.

Launching the Agent Certification Program

The launch of the Agent Certification Program was a major milestone for NaLA. The training programwhich provides education on industry standards, regulatory compliance and industry-specific best practicesoffers Lifeline Providers (ETCs) a high quality resource for training their distributing agents.

The Agent Certification Program is already being utilized by nearly one dozen Lifeline Providers nationwide, and is in the process of expanding to include additional resources for internal compliance.

Recent Developments in Self Regulation of Lifeline

NaLA continues to build on these resources to assure the continued availability of the Lifeline Program, which is a critical tool in providing low-income Americans access to essential communication services.

In addition to providing training and education, the Agent Certification Program also establishes accountability between Agents and their Lifeline ETC partners. This accountability assists in promoting program integrity.

Future of Self Regulation of Lifeline

NaLA views the integrity of the Lifeline Program as a top priority, and continues to lead the industry with initiatives that support the Program’s success.

Through future developments in self regulation, NaLA is confident that the industry will be successful in realizing the vision for every American to have access to essential communication services.

No comments
Lee SchaferNaLA Develops and Promotes Self Regulation in Lifeline Industry
read more

National Lifeline Association Welcomes Ali Badran As New Board Member

The National Lifeline Association (NaLA) is pleased to announce the appointment of Ali Badran, CEO of MoreAble, LLC and Aiobo.com, as the new member of the NaLA Board.

The National Lifeline Association (NaLA) is pleased to announce the appointment of Ali Badran, CEO of MoreAble, LLC and Aiobo.com, as the new member of the NaLA Board.

Mr. Badran brings to the position 15 years of wireless and seven years of Lifeline experience. He represents a collaborative and forward-thinking base of distributors and marketers of the Lifeline program.

Mr. Badran will be working closely with ETCs, community-based organizations, and marketing platforms to improve the Lifeline customer experience. He has a progressive perspective in supporting the interest, integrity and best practices of our rapidly growing Lifeline agent base. It will be his responsibility to continue to build an infrastructure that will support the NaLA Certified Agents within the Lifeline ecosystem.

“As always, there is a great deal of work needed to bring together the largest member group within NaLA,” said David B. Dorwart, Chairman of National Lifeline Association.

The board believes that Ali’s experience and leadership will help strengthen the integrity of the Lifeline program and uphold NaLA’s mission to support the providers, distributors, participants, and supporters of Lifeline through education, cooperation, and advocacy.”

Mr. Badran joins current NaLA Board Members: David B. Dorwart, Board Chairman of NaLA; William Curry, President at Life Wireless; Steve Klein, President at SafetyNet Wireless; David Avila, Associate Vice President at SafeLink Wireless; Kimberly Lehrman, President & Chief Marketing Officer at enTouch Wireless; and Nathan Stierwalt, Chief Sales & Marketing Officer at PWG Network Solutions.

No comments
Lee SchaferNational Lifeline Association Welcomes Ali Badran As New Board Member
read more

Lifeline Minimum Service Standards Increase Effective December 1, 2018

December 1, 2018 – New Lifeline minimum service standards are in effect today, as stated in the FCC’s 2016 Lifeline Modernization Order. The Order (FCC 16-38) aimed to modernize Lifeline to support broadband and establish an automatic update to the Lifeline minimum service standard for mobile voice service through November 30, 2018.

Newly Effective Lifeline Minimum Service Standards

The new standards, effective December 1, 2018 are as follows:

  • Mobile broadband (data): 2 GB/month of 3G mobile technology
  • Mobile voice: 1,000 minutes per month
  • Fixed (home) broadband: 18/2 Mbps –*There is an exception if the service provider does not offer any generally available residential fixed broadband packages at the subscriber’s residence that meet this standard (in this case, the service provider can receive support for the highest-performing, fixed broadband residential offering of at least 4 Mbps/1Mbps)
  • Fixed (home) broadband: 1,000 GB of usage per month
  • Fixed (home) voice: No minimum service standard

How Will the Lifeline Minimum Service Standards Affect Lifeline Participants?

The increase in minimum standards for data has increased from 1GB/month to 2GB/month, while voice users see an increase in the minimum from 500 to 1,000 minutes. The doubling of these standards is a step towards the future for low income Americans who participate in the program. 

The 2016 Order, which initiated the gradual service standard increases, was created with the intent to phase-out voice-only subsidy in an effort to increase focus on providing broadband, on which Americans are becoming increasingly reliant.

2019 Lifeline Budget Determination

In addition to the changes in minimum service standards, the 2016 Lifeline Order adopted an initial budget of $2.25 billion for the calendar year beginning January 1, 2017. The Order stated that the budget amount would be indexed to inflation in accordance with the Consumer Price Index for all items from the Department of Labor, Bureau of Labor Statistics in subsequent years.

In accordance with this formula for determination, the Wireline Competition Bureau announced via the July 2018 FCC Public Notice that “the indexed budget for federal universal service support for the Lifeline program for the calendar year beginning […] January 1, 2019, will be $2,327,114,250.”

No comments
Lee SchaferLifeline Minimum Service Standards Increase Effective December 1, 2018
read more

NaLA Supports Q Link Waiver Petition Urging FCC to Accept Submissions for Lifeline Eligibility Pending Fully Functional API

Comments Filed November 23 in Support of Q Link National Verifier Waiver Request

Following the November 1 petition by Q Link Wireless, LLC, the National Lifeline Association (NaLA) filed comments supporting the Q Link Waiver Petition, which requests Lifeline eligibility submissions to the National Verifier.

Q Link Waiver Petition to FCC on National Verifier

Q Link initially petitioned for implementation of a service provider application programming interface (API) in the National Verifier in July 2018. The API, which would help millions of low-income Americans, including seniors, veterans, and disabled individuals enroll in Lifeline,  has yet to be implemented by the Universal Service Administrative Company (USAC), the administrator of the Lifeline Program.

As the National Verifier has been launched in over a half-dozen states without any such APIs, Lifeline service providers like Q Link Wireless are seeking other accommodations for Lifeline consumers’ eligibility submissions to the National Verifier.

The Q Link Waiver Petition, filed November 1, requests that service providers be permitted “to submit eligibility documentation to the National Verifier via bulk transfer to facilitate its review of consumer eligibility” in ‘hard-launch’ states.

NaLA Comments on Q Link Waiver Petition

In its comments, the National Lifeline Association (NaLA) agrees with Q Link and other Lifeline providers who recognize the consequences facing low-income consumers regarding timely access to phone and internet service, and concerns with data security and phishing scams.

In support of the Q Link Waiver Petition, NaLA strongly urges the FCC “to allow all ETCs to submit proof of eligibility documentation to the National Verifier in bulk as described in the Q Link Waiver Petition until USAC can implement a service provider API into the National Verifier.”

No comments
Lee SchaferNaLA Supports Q Link Waiver Petition Urging FCC to Accept Submissions for Lifeline Eligibility Pending Fully Functional API
read more

1.3 Million Veterans Lifeline Service Could be Affected by FCC Proposed Changes

The Washington Times published an op-ed regarding how Veterans Lifeline service could be affected by FCC-proposed changes. Lifeline service is offered through the Lifeline Program, which connects low-income Americans to affordable telephony and broadband services for the purposes of health care, education and employment. 

The op-ed echoes TracFoneSprint, AARP and other groups who have stood up against the FCC proposals, and reminds readers that

if the FCC approves these changes, millions of Americans — including hundreds of thousands of veterans — will be left without this most basic daily need: a phone.”

Changes Affect Up to 1.3 Million Veterans’ Lifeline Service

Approximately one tenth of Lifeline participants are U.S. Veterans. These individuals, many of whom are retired or disabled, rely on their Lifeline service to communicate with doctors, employers, and other support resources.  

The proposed FCC changes would ban Wireless Resellers serving over 70% of Lifeline participants, which include veterans among other retired and disabled Americans. Veterans can be a particularly vulnerable demographic when it comes to physical health, mental health, and employment. They are also at increased risk for homelessness and suicide. 


Read the Op-Ed: Sustaining a vital veterans program

More than 1 million veterans rely on the Lifeline program connecting low-income households to essential services like health care, job opportunities and public safety. Also relied upon by seniors, the disabled, and many other Americans, the Lifeline program, started under President Ronald Reagan, gives low-income families discounts on phone and Internet services.

Unfortunately, proposed changes from the Federal Communications Commission (FCC) threaten to undermine this vital program and hurt those who depend on it most.

Click here to read the full article

 

No comments
Lee Schafer1.3 Million Veterans Lifeline Service Could be Affected by FCC Proposed Changes
read more

NaLA’s 2017 FCC Proposal Appeal Lands in DC for Oral Argument

On October 25, 2018, oral argument was held before the U.S. Court of Appeals for the District of Columbia Circuit in the National Lifeline Association’s appeal of the FCC’s December 2017 proposal to ban resellers from the Tribal Lifeline program and to limit the program to rural areas.

NaLA’s Case for Appealing the 2017 FCC Proposal

The representative for NaLA opened by addressing the failure of the Commission to consider the impact of its Tribal Facilities Requirement and Tribal Rural Limitation on the primary goals of the Tribal Lifeline program, which are affordability and increased subscribership. Additionally, he asserted that “[b]ecause the Commission failed to account for a lack of affordable service options or even alternative service providers for many Tribal Lifeline customers, it failed to consider important aspects of the problem before it.”

Tribal Counsel Weighs in on 2017 FCC Proposal

Counsel for the Tribes also presented their concerns, arguing that the Order’s Tribal Facilities Requirement undermined the FCC’s goal of spurring investment because it would result in fewer service providers offering service and fewer people having access to Lifeline service. Counsel for the Commission argued that the FCC was entitled to deference, but came under sharp questioning from the three judge panel. Judge Rogers commented that the agency had “no backup” for its assertion that facilities-based providers would step in to replace resellers if they were banned.

 

No comments
Lee SchaferNaLA’s 2017 FCC Proposal Appeal Lands in DC for Oral Argument
read more

NaLA Comments on FCC Connected Care Pilot Program Notice of Inquiry

The National Lifeline Association (NaLA) filed a response to a recent Notice of Inquiry (NOI) regarding the Connected Care Pilot Program, a Federal Communications Commission (FCC) telehealth program that seeks to assist low-income Americans.

comments-fcc-connected-care-pilot-program-NOIFCC Promoting Telehealth for Low-Income Consumers

The Connected Care Pilot Program is part of an FCC telehealth initiative and would seek “to improve health outcomes among low-income Americans through the use of expanded access to telehealth services.” The $100 million FCC proposal for a Connected Care Pilot Program received unanimous approval in August 2018.

In the NOI, the FCC acknowledges an increasing reliance on broadband-enabled telehealth services when providing high quality health care. The pilot would improve healthcare for low-income consumers by bringing connected care resources to low-income Americans with a wide range of health challenges, including cancer treatment, pediatric heart disease, high risk pregnancies, stroke treatment, and diabetes management.

FCC Seeks Comment on Connected Care Pilot Program NOI

In response to the NOI, NaLA expressed concerns in a September 10, 2018 filing. As an organization that has long viewed Lifeline as a tool to increase access to healthcare for low-income consumers, NaLA supports the purpose of the Connected Care Pilot Program, but expressed two main concerns:

  1. Telehealth services provided by the program would not be offered to all low-income Americans who need them.  

    The NOI seeks comment on “limiting the participating health care providers’ use of the pilot program funding to Medicaid-eligible patients, as well as veterans who qualify based on income for cost-free health care benefits through the Department of Veterans Affairs (VA).”

    NaLA believes strongly that this limitation would lead to many exclusions of the low-income demographic for whom the program was designed to serve.

     

  2. The Commission would restrict provider participation to “Facilities-based” ETCs (providers).

    This restriction would further limit accessibility for low-income consumers who are in need of telehealth services by limiting the number of providers. The NOI suggests that such an approach would be consistent with the Lifeline program, proposing “that participants should be facilities-based … given that one of the goals of the pilot is to increase broadband deployment in unserved and underserved areas.”

    NaLA opposes this point, noting that nearly 70 percent of low-income consumers within the Lifeline program are served by non-facilities based ETCs (wireless resellers). Additionally, NaLA adds that resellers “have a unique expertise in locating, enrolling and serving the same communities that the Connected Care Pilot Program seeks to serve, i.e., low-income consumers and veterans”.

In conclusion, NaLA respectfully requested that the Commission design any Connected Care Pilot Program consistent with these comments to most effectively and efficiently meet the program goals.

View Full Response to the Connected Care Pilot Program NOI

 

Read NaLA’s September 10 Comments to the FCC Notice of Inquiry here.

No comments
Lee SchaferNaLA Comments on FCC Connected Care Pilot Program Notice of Inquiry
read more

NaLA Files Comment on TracFone Emergency Petition Requesting National Verifier Delay

September 12, 2018 – The National Lifeline Association (NaLA) filed comments supporting the recent TracFone emergency petition requesting alterations to the Lifeline National Verifier by the Universal Service Administrative Company (USAC), administrator of the Lifeline Program.

TracFone Emergency Petition Requests FCC Delay USAC National Verifier Launch

The emergency petition from TracFone urges the Federal Communications Commission (FCC) to delay USAC from further implementation of the National Verifier.

TracFone has concerns that the National Verifier, which has already launched in six states, is not integrated to all of the necessary state databases that would allow it to effectively function in determining Lifeline eligibility.

The petition requests that USAC ensure, prior to launching the National Verifier in additional states, that the National Verifier access key databases (particularly the Medicaid Enrollment Databases) and also accept eligibility proof from select third parties.

TracFone reports that the requested alterations will improve the efficiency of the automated and manual eligibility processes, which ultimately support the National Verifier.

NaLA Files Comments Supporting TracFone Emergency Petition to Delay Lifeline National Verifier

NaLA recently filed comments echoing the TracFone petition concerns regarding the launch of the National Verifier.

While the support for the National Verifier has been consistently unanimous, the success of the National Verifier in confirming subscriber eligibility is based on participation in qualifying federal programs, particularly the Medicaid enrollment database.

Medicaid participants account for 29 percent of Lifeline enrollments and the USAC’s launch strategy has resulted in leaving some of the subscribers who need Lifeline the most — especially those enrolled in Medicaid and dependent on Lifeline services  — at risk for losing phone service, not just to connect to society but also to manage their care” – National Lifeline Association

USAC also refused to accept evidence of eligibility for the manual verification process through third-party sources such as Managed Care Organization (MCO). USAC not allowing proof of eligibility through MCO will interfere with the efforts to enroll eligible subscribers in the Lifeline program.

To provide an enrollment process that better serves eligible consumers, NaLA suggests, “directing USAC to accept proof of eligibility from MCOs […] will make the National Verifier more efficient and effective for USAC, consumers and service providers.”

Read NaLA’s Comments On TracFone’s Emergency Petition

NaLA Comments on TracFone Emergency Petition

No comments
Lee SchaferNaLA Files Comment on TracFone Emergency Petition Requesting National Verifier Delay
read more

CTIA Opposes FCC Lifeline Changes Banning Wireless Resellers

February 21, 2018 –  CTIA, an wireless connectivity advocacy organization, voices their opposition to the recent FCC proposals on the Lifeline Program, which provides essential communication services to qualifying low-income American families. CTIA’s filed their comments to the FCC in response to the FCC’s 2017 Notice of Proposed Rulemaking (NPRM) and Notice of Inquiry (NOI), and more specifically comments on concerns over the proposed elimination of wireless resellers from the Lifeline Program, which would ban non-facilities-based providers from serving as Lifeline Providers.

CTIA on Elimination of Wireless Resellers from Lifeline Program

CTIA’s belief that the Commission’s proposal elimination of wireless resellers from Lifeline would negatively impact competition and harm low-income consumers supports the integrity of the Lifeline program and urges the FCC to reconsider these key issues. CTIA expressed that while it supports the FCC’s commitment ensure the integrity of the Lifeline Program. However, in the letter they stated that “expeditious implementation of the National Lifeline Eligibility Verifier (National Verifier or Verifier) is the most important thing the Commission can do to limit waste, fraud, and abuse in the Lifeline program. Accordingly, the Commission should remain focused on implementing the National Verifier before considering any further large-scale program reforms” and that the organization “strongly encourages the Commission not to adopt the proposal in the NPRM/NOI to exclude non-facilities-based providers from the Lifeline program.”

CTIA to FCC on “Exhibit A” Lifeline Economic Study

Also referenced in the letter from CTIA was the “Exhibit A” Declaration by Dr. John Mayo, an recently conducted economic study which also supports of not excluding resellers (non-facilities-based providers) from Lifeline. This study provides evidence that the NPRM’s proposal to limit Lifeline facilities-based carriers is inconsistent with economic basis of Lifeline and doesn’t support the goal of universal connectivity.  CTIA concludes “Ultimately, Dr. Mayo’s analysis shows that the data on network investment do not support limiting subsidies to facilities-based providers and excluding non-facilities based providers in order to further incent deployment.  In light of the economic evidence, the Commission should conclude that, in order to avoid undermining investment in broadband networks, it must continue to allow non-facilities based providers to participate in Lifeline.”

Read Complete Filing of CTIA Comments to FCC

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/03/180221-CTIA-Lifeline-Comments.pdf”]

 

 

 

About CTIA:

CTIA® represents the U.S. wireless communications industry and the companies throughout the mobile ecosystem that enable Americans to lead a 21st century connected life. The association’s members include wireless carriers, device manufacturers, suppliers as well as apps and content companies. CTIA vigorously advocates at all levels of government for policies that foster continued wireless innovation and investment. The association also coordinates the industry’s voluntary best practices, hosts educational events that promote the wireless industry and co-produces the industry’s leading wireless tradeshow. CTIA was founded in 1984 and is based in Washington, D.C.

About NaLA:

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential components of Lifeline: ETCs & Providers, Distributors, Lifeline Supporters & Participants, and Government & Regulatory Bodies. We are passionate about the continuity and advancement of the Lifeline program and we drive this vision through our mission to “support providers, distributors, participants, and supporters of lifeline through education, cooperation, and advocacy.”

No comments
Lee SchaferCTIA Opposes FCC Lifeline Changes Banning Wireless Resellers
read more

Sprint Opposes Lifeline Wireless Reseller Ban

February 20, 2018 — Sprint expresses concerns with the FCC’s recent proposals concerning a Lifeline wireless reseller ban, which would prohibit wireless resellers from serving low income households as Service Providers through the Lifeline Program. The Notice on Proposed Rulemaking (NPRM), an initiative from the FCC’s November 2017 Open Meeting that included various Lifeline Program initiatives, such as banning wireless resellers from providing Lifeline service.

Sprint says Lifeline Wireless Reseller Ban Could Affect 6.1 Million

Sprint, a facilities-based provider, has echoed the concerns of various non-facilities-based providers on the recent FCC proposals found in the NPRM. They oppose the Lifeline wireless reseller ban that the FCC is pursuing, and state that the “elimination of resellers from the Lifeline program would be disruptive to current and potential Lifeline customers. The majority of Lifeline customers obtain service from resellers, which had an estimated 6.1 million customers as of December 2017.”

Consequences of FCC Lifeline Wireless Reseller Ban

The letter from Sprint highlights many concerns for Lifeline Participants that rely on the program to assist them in accessing essential communication services. They noted that the Lifeline wireless reseller ban would result in a “a sharp reduction in the number of wireless service providers offering Lifeline service; in some areas, there may remain only a single facilities-based wireless Lifeline service provider, and in other areas, there may be no facilities-based wireless Lifeline service provider at all.” Sprint adds that “users [Lifeline Participants] will not realize they need to obtain service from a facilities-based carrier, some will not know how to transfer their service, some will not provide required documentation in a timely manner. Some customers will successfully transfer to a facilities-based carrier, but some will lose service altogether.”

The forced exit of wireless resellers as Lifeline service providers from the Lifeline market is disruptive of consumer access to emergency services, or other resources necessary for employment, health care, or childcare.

Read Sprint’s Letter to FCC

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/02/Sprint-LL-comments.pdf”]

Postponing of Lifeline Program Eligibility Verifier (National Verifier)

In addition to concerns about the ban of wireless resellers in Lifeline, Sprint also asserts in the letter to the FCC that the National Verifier is a crucial part of reducing waste, fraud, and abuse within the program – and should be the most important focus of the Commission at this time.

The recent postponing of the National Verifier launch has created concern that the Commission’s actions do not support it’s stated goals about strengthening the Lifeline Program eligibility verification processes.

“Getting the deployment timeline back on track is the surest way for the Commission to advance the common goal of ensuring Lifeline program integrity,” Sprint states in their letter to the FCC. Sprint, TracFone and other Telecommunication companies are in agreement that efforts are best focused on the National Verifier, prior to making any drastic changes to the program, which helps nearly 11 million low-income Americans access phone and internet services.

 

About NaLA:

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential components of Lifeline: ETCs & Providers, Distributors, Lifeline Supporters & Participants, and Government & Regulatory Bodies. We are passionate about the continuity and advancement of the Lifeline program and we drive this vision through our mission to “support providers, distributors, participants, and supporters of lifeline through education, cooperation, and advocacy.”

No comments
Lee SchaferSprint Opposes Lifeline Wireless Reseller Ban
read more