FCC

Minimum Service Standard Proposal by FCC Threatens Low Income Access to Wireless Connectivity

FCC Releases Statement on Plans for December 2020 Minimum Service Standard Increase

Last week, Federal Communications Commission Chairman Ajit Pai released a statement regarding changes to minimum service standards within the Lifeline program. “Starting Dec. 1, Lifeline’s mobile carriers will have to offer 4.5 GB of data each month, up from 3 GB,” Chairman Pai stated. The increase in monthly data stems from the recent COVID-19 pandemic, making access to viable service more significant than ever. 

Proposed Minimum Service Standard Increase Will Impact Consumer Access to Wireless Services

This new proposal has caused a great deal of controversy among organizations that strive to assist low-income customers with wireless, wireline, and broadband service through the Lifeline Program. The problem here lies with the fact that the program runs on a subsidy amount of $9.25 each month to help aid its customers. “Plans including that much data cost $25 to $40 per month,” said lawyer John J. Heitmann, who represents the National Lifeline Association (NaLA). 

Many nonprofit organizations are facing this exact same issue right now trying to balance the consumers’ need for more internet access with the available funding. Heitmann also stated,

“There is simply no evidence in the docket to suggest that a 50% increase in the required mobile broadband data – with no corresponding increase in subsidy support – can be provided without forcing a copay on consumers.” 

In August, NaLA conducted a survey of 7,706 Lifeline subscribers asking whether they could afford a copay to remain connected to the service. The results showed that 85% of the subscribers said they could not afford a copay, and one in 10 of the customers also reported they are currently unemployed.

Digital Divide at Risk of Widening due to Proposed FCC Changes

The issue now remains with how Lifeline and other organizations that also assist low-income consumers will continue to provide the best possible service with a lack of government funding. The inability to provide reliable, affordable service poses a bigger issue in regard to the digital divide. In an interview with the Herald-Tribune Heitmann stated,

“There are two aspects of the digital divide. One is where there aren’t any high-speed networks. The other is where we have high-speed networks but people just can’t afford the services over them. And it’s the latter problem that’s the bigger problem in the United States. And it’s been made bigger by COVID.”

For years these organizations have strived to meet consumers’ needs. With these new challenges arising due to COVID-19, Lifeline and these other organizations could be facing a major financial crisis down the line with the lack of proper funding.

For more information, visit https://www.heraldtribune.com/story/news/local/2020/09/28/fccs-lifeline-program-free-phone-and-internet-confronts-crisis/5762068002/

 

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Lee SchaferMinimum Service Standard Proposal by FCC Threatens Low Income Access to Wireless Connectivity
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FCC Must Act Now to Prevent Disruption in Lifeline Service for Millions of Low-Income Americans and Hundreds of Thousands of Veterans

KENNETT SQUARE, PA. (PRWEB) OCTOBER 1, 2020

Members of the National Lifeline Association (NaLA) urge the Federal Communications Commission (FCC) to prevent the disruption of essential Lifeline-supported service for low-income Americans, particularly low-income veterans. Unless the FCC acts now to prevent untenable increases in mobile broadband service levels without any increase in support amounts, most Lifeline users will be forced to switch from fully-supported “free” service offerings to service that requires a co-pay which more than 80% of subscribers say they cannot pay. Unless the FCC acts to reverse course, millions of low-income veterans and other Americans will lose Lifeline-supported access to the mobile voice and broadband services they need to stay in contact with employers, teachers, and loved ones during ongoing challenges associated with the COVID-19 pandemic.

Earlier this year, the FCC announced new Minimum Service Standards for mobile broadband services and a reduction in support for voice service provided through the Lifeline Program. This action was taken without increasing the subsidy for low-income Americans and without any study to determine the affordability of such services.

Read the entire NaLA press release here.

About the National Lifeline Association (NaLA)

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the four essential components of Lifeline: ETCs & Providers, Distributors, Lifeline Participants & Supporters, 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.”

For more information on NaLA, visit https://www.nalalifeline.org.

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Lee SchaferFCC Must Act Now to Prevent Disruption in Lifeline Service for Millions of Low-Income Americans and Hundreds of Thousands of Veterans
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Lifeline Service Extended by FCC, Providing Critical Connections During COVID-19 Crisis

The National Lifeline Association (NALA) applauds a recent announcement by the Federal Communications Commission (FCC) that it will continue to suspend involuntary disconnections from the Lifeline program and that it will accept unemployment insurance as proof of income eligibility through June 30, 2020. The FCC’s decision was made to ensure that millions of Americans continue to have access to essential Lifeline-supported mobile voice and broadband service during the unprecedented government-directed stay at home orders established to stop the spread of the COVID-19 virus across the country.

“The FCC did the right thing in extending this waiver and ensuring that Americans who are now practicing social distancing have access to essential voice and mobile broadband services that connect them to the outside world,” said David B. Dorwart, Chairman of the NaLA Board. “For Americans who cannot afford these services, the Lifeline program is now an actual lifeline. With stay-at-home orders still in place in many states, and staggered re-openings in others, millions of Americans need Lifeline-supported service to communicate with healthcare providers, employers, and their children’s teachers. Without Lifeline-supported service, this period of isolation would be even more debilitating. We will continue to work with lawmakers and regulators to ensure those who need Lifeline-supported service will have access to it during this pandemic and economic crisis.”

Since the outset of the COVID-19 crisis, Lifeline service providers have seen an increase of up to 20% in voice minutes used and up to a 40% increase in data usage, according to a recent survey conducted by the National Lifeline Association.

Mr. Dorwart continued, “Now more than ever, it is clear that mobile voice and broadband services are essential services for low-income Americans. What was once a luxury is now a requirement to function and stay engaged. As this pandemic and economic crisis continues, regulators must continue to evaluate this program to ensure that those who need it have access to it and the crucial connections it provides.”

Any low-income consumers who are experiencing difficulty getting or staying connected during the COVID-19 pandemic can find more information about Lifeline eligibility and how to apply in their state here: https://www.lifelinesupport.org/

About the National Lifeline Association (NaLA):

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the four essential components of Lifeline: ETCs & Providers, Distributors, Lifeline Participants & Supporters, 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.”
For more information on NaLA, visit https://www.nalalifeline.org.

 

Read full NaLA press release here.

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Chelsea BoylanLifeline Service Extended by FCC, Providing Critical Connections During COVID-19 Crisis
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FCC Supports Lifeline Participants with COVID-19 Order

FCC releases COVID-19 Order placing a 60 day waiver on recertification and reverification. The FCC delays launch of RAD Database 60 days beyond target date.

FCC Issues Lifeline Order

FCC Issues COVID-19 coronavirus Order Supporting Lifeline Participants and Providers

In response to the COVID-19 public health emergency, the FCC (Federal Communications Commission) is taking action to ensure Lifeline participants continue to have access to communications services during this critical time. The FCC noted in its COVID-19 Order that there has been a dramatic disruption in American’s lives that discourage person-to-person contact, forcing consumers to turn to telemedicine, telework, online learning, and overall social distancing.

The FCC stated that they believed that the coronavirus pandemic and community efforts to slow its spread makes requiring Lifeline subscribers to recertify and reverify an unreasonable burden at this time. The FCC went on to adjust the launch date of its Representative Accountability Database 60 days beyond its initial launch date of March 26th, 2020. They believe this will allow ETCs and Lifeline Providers to prioritize assisting eligible consumers to get connected and stay connected to voice and broadband services during this unprecedented time of need.

In the COVID-19 Order, the FCC announced 3 temporary changes to the Lifeline program:

Recertification – Waived 60 Days

Effective March 17th, 2020, recertification is on hold for the anniversary dates between April 14th, 2020 and August 14th, 2020. Subscribers with these anniversary dates will receive a new notice from USAC to recertify their eligibility after the waiver period ends on May 18th, 2020.

Recertification will remain as planned for subscribers with anniversary dates outside the window listed above.

Reverification – Waived 60 Days

All new reverification activity is on hold for 60 days from today through May 18th, 2020.

USAC will not conduct any de-enrollments for subscribers with documentation deadlines falling on or before May 18th, 2020. Any impacted subscribers will receive a new opportunity to provide necessary eligibility documentation after the end of the waiver period.

USAC will not open any new reverification documentation requests until after Monday, May 18th, 2020.

Beginning Tuesday, May 19, 2020, USAC will continue reverification activities as normal.

Representative Accountability Database – Delayed Implementation

To reduce the burden on Lifeline providers, full implementation of the Representative Accountability Database (RAD) will be delayed until Monday, May 25th, 2020.

When launched, RAD will function as communicated prior to this waiver. Please continue to encourage your enrollment representatives to register for a Representative ID and link IDs to the respective NLAD sub-accounts, API IDs, and/or SPINs as batch users. RAD will be mandatory on Monday, May 25, 2020.

The FCC and USAC made additional statements that noted they are working hard to make sure the Lifeline Support Team functions as normally as possible, but they continue to monitor the situation.

The full detail of the FCC Order can be found here: https://docs.fcc.gov/public/attachments/DA-20-285A1.pdf

For questions about the Lifeline Program, call (800)-234-9473 or email [email protected]

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Jordan AxtFCC Supports Lifeline Participants with COVID-19 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 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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