NaLA Blog & Latest News

Sprint Supports Q Link’s Petition for Lifeline Enrollment APIs

In July 2018, Q Link Wireless filed an emergency petition to the Federal Communications Commission (FCC) to immediately change how people submit eligibility proof documentation when they enroll in the Lifeline Program with an ETC online. The FCC’s potential changes will make the online eligibility and enrollment process more difficult, discouraging customers who need Lifeline phone and data services.

Online Lifeline Enrollment Using Third-Party Verification

Many eligible consumers like veterans, seniors, and the disabled rely heavily on the online sign-up enrollment process. Because of the new third-party verification systems being implemented, consumers will have to work through a government-run website and then repeat the process to enroll with a specific carrier. This two-step process is unnecessary, and if the consumer needs help with the verification process, he or she would have to find an in-person sales agent.

“The USAC’s proposed change will be unnecessarily difficult and confusing for consumers,” said Issa Asad, founder and CEO of Q Link Wireless in a press release. John T. Nakahata of Harris, Wiltshire & Grannis LLP (counsel for Q Link Wireless) added, “The new eligibility confirmation process will differ significantly for rural consumers compared to urban consumers.” He explained,, “Rural consumers who attempt to enroll online in the Lifeline program must use the National Verifier’s consumer portal. By contrast, someone living in an urban area can more easily get assistance from an in-person agent. This will disproportionately and adversely affect rural Americans eligible to receive Lifeline services.”

Sprint Comments on Q Link Petition for Online Lifeline Enrollment APIs

Sprint Corporation (Sprint) filed comments agreeing that the FCC should grant Q Link’s petition and implement Application Programming Interfaces (APIs) to consolidate the process to a single step. Sprint commented that APIs are essential for online enrollment and it will reduce costs for the Universal Service Administrative Company (USAC) National Verifier (NV).

Sprint says that because applying for Lifeline service in-person is not an option sometimes, APIs are critical for consumers who apply for Lifeline service online. Even with the assistance of a live agent, the process faces an uphill battle for consumers. “Without an API, a live agent cannot forward personal information provided by the consumer to the service provider to the NV, or receive information provided by the consumer to the NV; thus, the end user must enter his personal information twice (once to the NV for purposes of determining his Lifeline eligibility, and once to the ETC for purposes of applying for that ETC’s Lifeline service). This is not a user-friendly process and could discourage eligible low-income Americans from undertaking or completing the process for applying for Lifeline service.”

Cost Benefits of Online Lifeline Enrollment APIs

Not only will the use of API’s simplify the enrollment process for consumers, but it will reduce administrative costs for USAC National Verifier.

“The APIs will allow service providers to assist potential Lifeline customers in real time, including answering ETC-specific questions that USAC or other NV representatives cannot answer, and helping customers to submit a complete and legible application package. APIs will result in substantial savings in administrative and customer care expenses for the NV/USAC,” Sprint states in the filed comments.

Lifeline Providers work closely with potential Lifeline consumers to answer questions and ensure that their application is filled out properly. Lifeline Provider Assurance Wireless denies up to 75% of applications they receive because they were incomplete, incorrect or because the consumer was not eligible for Lifeline services. “Use of APIs will allow ETCs to continue to field many of the consumer inquiries, thereby reducing USAC’s costs of administering the Lifeline program and speeding up the eligibility determinations.”

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admin1Sprint Supports Q Link’s Petition for Lifeline Enrollment APIs
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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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