NaLA Blog & Latest News

U.S. Court of Appeals Announces Decision on FCC 2017 Lifeline Order

The FCC 2017 Lifeline Order, which sought to ban resellers from serving Lifeline-eligible consumers and change the access to Lifeline service for low-income consumers living on Tribal lands, was vacated and remanded by the U.S. Court of Appeals. Chairman David Dorwart released the following press release on behalf of NaLA regarding the court’s ruling.

NaLA Press Release on Ruling on 2017 Lifeline Order

KENNETT SQUARE, Pa., Feb 1, 2019 — The National Lifeline Association is pleased that today’s decision by the U.S. Court of Appeals for the D.C. Circuit vacates and remands the FCC’s 2017 Order that would have eliminated wireless resellers from the Tribal Lifeline program and restricted that program to rural Tribal lands.  The Court’s decision will allow wireless resellers to continue to provide Lifeline service to two-thirds of all participants in the Tribal Lifeline program. 

NaLA looks forward to engaging with the FCC and all stakeholders going forward to ensure that the goal of preserving affordability for eligible program participants remains the primary goal of the program.  The Lifeline program faces incredible challenges in 2019.  Our hope is that this decision will provide the impetus for the Commission and all stakeholders to engage in a transparent and constructive manner so that Lifeline meets its full potential to bridge the affordability aspect of the digital divide.

NaLA would like to acknowledge and thank those who led our team that made today’s victory for Tribal Lifeline subscribers possible.  These individuals include our attorneys, John Heitmann and Jameson Dempsey of Kelley Drye, and Kim Lehrman and Jose Cortes on NaLA’s regulatory affairs committee.  We also want to extend our thanks to the Tribes and the team who represented the Tribes, as their participation in the appeal process was essential to the result achieved today.

–David Dorwart, Chair, National Lifeline Association

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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Lee SchaferU.S. Court of Appeals Announces Decision on FCC 2017 Lifeline Order
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TracFone Files Second Emergency Petition on National Verifier

November 30, 2018 – TracFone Wireless filed an emergency petition on the National Verifier, urging the FCC to direct the USAC to implement fifteen specific modifications of the National Verifier and its associated processes. This petition follows an earlier filing from TracFone in August 2108, which raised many similar concerns about aspects of the (then soft-launched) Lifeline Eligibility National Verifier.

Initial Emergency Petition on the National Verifier

The National Verifier, which has since hard launched in six states, was created to assist the Lifeline eligibility process for Lifeline Providers (also referred to as “ETCs”), who are typically wireless resellers that provide Lifeline service to qualifying low-income Americans.

During the beginning stages of the implementation of the National Verifier, TracFone requested a delay to the hard launch. Furthermore, they identified areas for improvement that would ultimately benefit the consumer and support the goals of the program to bridge the digital divide facing low-income consumers in America who are in dire need of access to telephony and broadband services. This consumer group includes veterans, disabled, and retired individuals living at or below 135% the federal poverty guidelines.

TracFone, FCC Discuss Lifeline Enrollment Concerns in National Verifier

On November 29, 2018, TracFone spoke with FCC Chairman Pai’s advisor to discuss its concerns regarding the National Verifier implementation. One of the main concerns was that the National Verifier would no longer accept SNAP (Supplemental Nutrition Assistance Program) benefit cards and most Medicaid cards as documentation for enrollment in Lifeline-qualifying programs.

TracFone’s latest petition raises concerns about the continued implementation of the National Verifier without consideration of the prior requests. In the petition, TracFone states:

“Each of the modifications will maximize the efficiency and effectiveness of the National Verifier, and importantly, allow the USAC to at all times retain full control of the ultimate Lifeline eligibility determination.”

TracFone Files Second Emergency Petition

Within the petition were requests for fifteen specific modifications of the National Verifier, including simplifying the paper application, allowing service providers to check applicant verification using APIs, and suspending new requirements of additional proof that are burdensome to eligible participants. TracFone asked the FCC to initiate a new rulemaking which would, among other things, explore other methods by which current low-income program participation and invalid addresses could be verified more efficiently. TracFone additionally asserted that implementation of the USAC’s changed policy regarding additional proof would preclude many Lifeline-eligible, low-income households from demonstrating their eligibility.

Additionally, TracFone’s petition conveys the seriousness of the challenges presented by the implementation of the National Verifier. It is essential that the USAC address the shortcomings associated with the National Verifier while providing a more effective and simplified enrollment process to better serve eligible Lifeline customers.

Read the November 30 TracFone Filing Here.

 

 

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Chelsea BoylanTracFone Files Second Emergency Petition on National Verifier
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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.

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Lee SchaferNaLA Develops and Promotes Self Regulation in Lifeline Industry
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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.

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Lee SchaferNational Lifeline Association Welcomes Ali Badran As New Board Member
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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.”

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Lee SchaferLifeline Minimum Service Standards Increase Effective December 1, 2018
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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.”

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

 

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Lee Schafer1.3 Million Veterans Lifeline Service Could be Affected by FCC Proposed Changes
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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.

 

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Lee SchaferNaLA’s 2017 FCC Proposal Appeal Lands in DC for Oral Argument
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National Lifeline Association Chairman Issues Statement Regarding FCC Enforcement Action Against American Broadband

David B. Dorwart, Chairman of NaLA, issues a statement regarding the FCC allegations of Lifeline rule violations and Notice of Apparent Liability against American Broadband


The allegations of Lifeline rule violations, including agent fraud and carrier misconduct, included in today’s FCC Notice of Apparent Liability against American Broadband, if proven to be true require nothing short of our absolute condemnation. We understand that the FCC has a process which will allow American Broadband to defend itself against these very serious and disconcerting allegations.

NaLA Remains Committed to Program Integrity

In the meantime, NaLA and its stakeholder members will continue the good work they do every day in bringing the Lifeline program to eligible subscribers. NaLA and its wireless reseller carriers work hard every day to ensure that only eligible subscribers get Lifeline benefits and that only eligible subscribers retain them. Today’s news will serve as a reminder to all Lifeline stakeholders just how important it is to achieve and maintain compliance in every facet of the good work that we do in ensuring Lifeline eligible low-income Americans are able to access this benefit that ensures essential voice and broadband connectivity.

NaLA Press Release on FCC Enforcement Action

The official press release can be reviewed here.

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Jordan AxtNational Lifeline Association Chairman Issues Statement Regarding FCC Enforcement Action Against American Broadband
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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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