NaLA Blog & Latest News

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.

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Lee SchaferNaLA Comments on FCC Connected Care Pilot Program Notice of Inquiry
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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

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Lee SchaferNaLA Files Comment on TracFone Emergency Petition Requesting National Verifier Delay
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How the Lifeline Program Helps Sarah Victory Continue Her Journey in Being a Super Mom

“I am thankful enough to have an affordable phone service,”  44- year-old Sarah Victory from Coweta, Oklahoma says in a relieving tone. Sarah works from 3 pm to 11 pm as a Certified Nursing Assistant. She also takes care of her three children (one is her 3-year old autistic son)  and is the emotional support for her husband, who suffers from depression. Sarah happily says that at her workplace the patients label her “the best one” and it’s most likely due to her dedication at work and home. Being a family woman and the go-to-person can be overwhelming, but Sarah says that it’s her job as a mother and wife. Her day-to-day routine varies, but the one thing that is consistent is her consumer relationship with the Lifeline program.

With so many responsibilities, bills, and other family financial commitments, Sarah is happy that the Lifeline program is effective and efficient. Being enrolled in the Lifeline program has allowed Sarah to connect with her children, husband, and doctors. “Because I can’t afford normal service, being in the Lifeline program allows me to talk to my doctor and my child’s doctor,” she says. The convenience and affordability of her Lifeline phone service not only makes her life easy even when everything else is hectic, but it allows her to stay connected with the important aspects of her life. Because she has to keep a closer eye on her son’s health, being able to contact his doctor is important. If it were not for the Lifeline Program how else would Sarah keep up with her autistic son’s health? As a busy mother, wife, and employee, the victory is more than her last name; it’s in her Lifeline phone service.

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NaLA Supports National Lifeline Awareness Week With Informational and Social Media Campaigns

NaLA Supports National Lifeline Awareness Week With Informational and Social Media Campaigns

Many eligible households who are not enrolled in the Lifeline program struggle to afford essential telephone service that allows them to reach emergency services, medical personnel, government services, schools, and potential employers. In fact, only 33% of those who are eligible for the Lifeline program are currently enrolled. Additionally, 46% of active Lifeline consumers are retired, disabled or unable to work, and rely on Lifeline for phone and broadband services every day. By raising awareness of the Lifeline program, NaLA seeks to educate those who may have been unaware of the availability of Lifeline and encourage those who are eligible to participate to enroll.

Now, more than ever, it is imperative to highlight the effect of Lifeline on the lives of low-income Americans. In 2017, the FCC proposed devastating changes to the Lifeline program which would significantly cut access to essential phone and broadband services for an estimated 8 million people, which is roughly 70% of Lifeline recipients currently enrolled in the program. The potential cutback of this program would have a profoundly negative impact not only on eligible seniors, the disabled and low-income consumers, but also the 28% of Lifeline consumers who are unemployed and actively looking for work.

“There is much work to be done when an estimated 67% of eligible consumers are not taking advantage of the Lifeline Program.”

“National Lifeline Awareness Week is important to NaLA because, at our core, we believe that every American should have access to essential communication services. There is much work to be done when an estimated 67% of eligible consumers are not taking advantage of the Lifeline Program,” says David B. Dorwart, Chairman of NaLA. “We are also excited to share the personal story of a current Lifeline consumer who expressed how profoundly Lifeline impacts her life. It is important for people to understand how the proposed FCC program changes could negatively impact vulnerable individuals,” he adds.

Because Lifeline affects millions of consumers every day, our service provider members and field agent members have partnered with us to generate informational and awareness campaigns in support of National Lifeline Awareness Week all across the country. Along with its service provider members, field agent members, and other advocates, NaLA continues to pursue changes that result in greater efficiency, accountability, and overall integrity in the Lifeline program. NaLA thoroughly believes in the importance of National Lifeline Awareness Week and applauds the organizations and regulatory bodies that support Lifeline and raise awareness during this week.

Read the original press release here.

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National Lifeline Association Comments In Support of Q Link’s Emergency Petition for API Interfaces

The National Lifeline Association (NaLA) commented on Q Link’s emergency petition for an order directing the Universal Service Administrative Company (USAC) to provide API Interfaces for the National Verifier.

Q Link defends the need for APIs because they are critical for the Lifeline consumer enrollment process. The use of APIs would make the application process for consumers much easier. A Q Link statement explains, “Without APIs, there would be no way for a consumer to benefit from carrier assistance when navigating the eligibility verification process online, or to complete both eligibility verification and service enrollment as part of a continuous online transaction.” Q Link also asserts that the APIs would decrease the USAC/NV’s administrative costs. “Restoring APIs to permit machine-to-machine information transfers between ETCs and the National Verifier will cut USAC’s costs to deploy and operate the National Verifier, and thus reduce the burden on ratepayers and the USF,” they state.

The National Lifeline Association (NaLA) comments on Q Link’s emergency petition

NaLA filed comments agreeing with Q Link’s emergency petition. NaLA agrees that the National Verifier without APIs would have a very negative impact on Lifeline consumers and Lifeline service business models.

NaLA understands that machine-to-machine interfaces are essential to the accessibility for low-income consumers. “Without a service provider API, consumers will be forced to go to an online portal to demonstrate eligibility, and then separately go to a Lifeline service provider to enroll for Lifeline service. This more difficult two-step process will disconnect millions of Americans from the enrollment process and expose others to data security risks, including phishing scams as described in the Q Link Petition,” NaLA explains in their comments. APIs are the connection between consumers and mobile wireless broadband and phone services. Millions of low-income Americans, including seniors, veterans, and disabled Americans could be denied access to data and phone services without the implementation of service provider APIs.

Implementing APIs is what NaLA refers to as a “common-sense” solution to create an effective and efficient National Verifier enrollment process. A NaLA statement explains, “A service provider API is simple, secure and cost-effective. And, a service provider API does not introduce any new security risks or Federal Information Security Management Act (FISMA) compliance concerns because the National Lifeline Accountability Database (NLAD), which has been used by service providers for more than four years and will be integrated with the National Verifier, already includes service provider APIs.”

The National Verifier cannot wholly serve Lifeline consumers and the Lifeline program without implementing APIs. That is why “NaLA respectfully urges the Commission to grant the Q Link Petition and direct USAC to implement a service provider API into the National Verifier.”

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Stay Granted for FCC Tribal Lifeline Rules to Bar Wireless Resellers and Lower Subsidies for Tribal Consumers of Lifeline Program

The U.S. Court of Appeals granted National Lifeline Association (NaLA) and Tribal petitioners a stay of new FCC Tribal Lifeline rules that would have barred wireless resellers from providing Tribal Lifeline and would also limit the Tribal Lifeline program to rural Tribal areas.

The Court stated that the FCC’s plan does not consider the harm it can cause to Lifeline businesses and customers. It is estimated that 70% of eligible consumers receive their Lifeline service from wireless resellers. The Court added that these actions would “result in a major reduction, or outright elimination, of critical telecommunications services” for Lifeline consumers and “substantial, unrecoverable losses” for Lifeline providers. Many Tribal consumers do not have an alternate option to obtain Lifeline phone or internet services if a wireless reseller ban were to be implemented. In addition, the FCC “identified no evidence of fraud or misuse of funds in the aspects of the program at issue here,” the Court wrote.

The judges also rejected the FCC’s claim that reducing subsidies would cause carriers to build their own networks in Tribal areas. They said the Commission failed to show any historical evidence that reducing subsidies would lead to more infrastructure investment. This argument was the justification for the new FCC Tribal Lifeline Rules that would eliminate wireless resellers from providing services on Tribal lands. The judges stated that the record suggested just the opposite.

In reaching its decision, it appears the Court understood that wireless resellers play a critical role in connecting low income consumers to essential communications services through the Lifeline program. Disconnecting consumers causes a digital divide.

“NaLA is pleased that the Court heard and agreed with the arguments presented and that the Court took action so the case can be decided without Tribal Lifeline subscribers, or the companies that work to serve them, suffering irreparable harm,” said David B. Dorwart, Board Chairman of NaLA. “In reaching its decision, it appears the Court understood that wireless resellers play a critical role in connecting low income consumers to essential communications services through the Lifeline program. Disconnecting consumers causes a digital divide. It does not put them first, nor does it further the Lifeline program’s core goal of ensuring that our nation’s most vulnerable consumers stay connected by making service affordable. NaLA looks forward to continue working with all stakeholders to preserve and protect the integrity of the Lifeline program so we can strive to meet this important goal.”

As advocates for preserving Lifeline, NaLA is encouraged by the Court’s statement that, “Petitioners have demonstrated a likelihood of success on the merits of their arguments.” The decision to halt the FCC’s move to prevent wireless resellers and lower Lifeline subsidies for Tribal areas is a big win for low-income Tribal consumers.

Read the full court order here: United States Court of Appeals Case #18-1026 Document #1744949 Filed on 08/10/2018

Read the original press release here.

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The National Lifeline Association Agent Certification Program Reaches New Milestone of 2,000 Sales Agents Trained and Certified in Lifeline Compliance

Today, the National Lifeline Association (NaLA) announced reaching a new milestone with the 2,000th Lifeline Agent receiving Lifeline compliance training and certification. The NaLA Agent Certification Program was created and launched by the National Lifeline Association in late April 2018. It provides Lifeline Eligible Telecommunications Carriers (ETCs) with assurance that independent sales agents have been trained, tested, and certified in the rules and regulations of both Federal and State Lifeline programs.

The NaLA Agent Certification program also requires certified agents to retrain, retest, and recertify every 90 days. This ensures that agents regularly maintain knowledge of Lifeline, while also allowing NaLA to quickly disseminate, train, and test agents’ understanding of regulatory and compliance changes.

The NaLA Agent Certification Program provides independent sales agents with critical program information they need to be successful in the communities they serve and fully compliant with the rules and regulations of the State and Federal Lifeline programs. This program was outlined as an important 2018 initiative by the NaLA Board of Directors at the 2017 NaLA Annual Conference held in New Orleans, LA.

“We are especially excited to celebrate this impressive milestone only three months after launching this program,” said David B. Dorwart, Chairman of the National Lifeline Association. “The NaLA Agent Certification Program is critical to the advancement of the Lifeline program. It creates a national standard for agent training and assists ETCs in self-regulating field compliance.”

NaLA’s Agent Certification Program was created by some of the most respected compliance executives in the wireless Lifeline industry. NaLA’s vision is to help ETCs deploy well-trained, compliant, and informed field sales representatives to communities and help consumers who are in need of Lifeline program benefits. Most NaLA ETC members have voluntarily committed to require this certification process for all of their field sales agents as part of a larger commitment to thorough agent training and continuous self-regulation.

Regarding the Agent Certification Program, Kim Lehrman, President of enTouch Wireless and a NaLA Board Member, stated, “Adding an additional layer of certification to internal training programs for ETCs is exciting for our industry. The better agents are educated about Lifeline program fundamentals (i.e. consumer application and recertification) and regulatory compliance information, the more succinctly they can communicate how the program works to our prospects and consumers — ensuring a better consumer experience.”

About The National Lifeline Association:

The National Lifeline Association is a non-profit organization that provides a foundation of support for Lifeline participants, service providers, distributors, government and regulatory bodies, and other advocates of Lifeline.

NaLA members are passionate about supporting their vision, “In America, every person should have access to essential communication services.” With their leadership and direction, NaLA provides and promotes Lifeline education, collaboration, and advocacy across the U.S.

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National Lifeline Association Discusses Lifeline Reform

On May 22, 2018, National Lifeline Association (NaLA) representatives Kim Lehrman, Jose Cortes, Chuck Campbell, John Heitmann and Joshua Guyan met with legal advisors to Chairman Pai and Commissioners Carr, O’Rielly, and Rosenworcel to discuss proposed changes to the Lifeline program. NaLA does not agree with the ban on wireless resellers. They believe the FCC should support affordability and consumer choice, and also expressed support for a budget for the Lifeline Program.

NaLA representatives expressed that resellers are important in the Lifeline program. Getting rid of wireless resellers would:

  • Harm consumers by forcing more than 7 million or roughly 70% of all Lifeline subscribers to find a new Lifeline service provider, leaving some with no wireless or wireline service options.
  • Fail to bolster program integrity or guard against waste, fraud and abuse (adopting conduct-based standards and agent registration would properly focus on bad actors rather than on business models).
  • NOT bridge the digital divide by spurring additional facilities deployment or more affordable services.
  • Upend the states’ role in designating ETCs, as well as the reliance interests of wireless resellers who have willingly sought such designations and landline providers who have been relieved of the obligation to provide Lifeline (based on the presence of, and consumers’ preference for, the mobile voice and broadband services offered by wireless resellers).

NaLA representatives also explained that the FCC should support affordability. “The FCC should freeze or roll-back the minimum service standards and voice support phase-out that threaten to deny consumers access to affordable choices that best meet their needs.” NaLA was endorsed by National Association of Regulatory Utility Commissioners (NARUC) with a $2,258 budget and they expressed the support saying, “The Lifeline program could benefit from a self-enforcing budget mechanism that operates on an annual basis with prospective impact only.”

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