FCC

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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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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admin1National Lifeline Association Comments In Support of Q Link’s Emergency Petition for API Interfaces
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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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Jordan AxtStay Granted for FCC Tribal Lifeline Rules to Bar Wireless Resellers and Lower Subsidies for Tribal Consumers of Lifeline Program
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FCC Lifeline Reform Detrimental to Lifeline Subscribers

On May 22, 2018, National Lifeline Association (NaLA)  met with legal advisors to Chairman Pai and Commissioners Carr, O’Rielly, and Rosenworcel to discuss proposed changes to the Lifeline program. NaLA representatives Kim Lehrman, Jose Cortes, Chuck Campbell, John Heitmann and Joshua Guyan raised concerns regarding the proposed ban on wireless resellers. The proposed FCC changes are contrary to the purpose of the Lifeline Program which is affordable service. NaLA representatives were open to a budget for the Lifeline Program within reason. But the main aim of the organization is to support the low-income consumers that rely on the Program and as such, they maintained that their commitment is to affordability and consumer choice.

Proposed Lifeline Reforms Threaten Service Affordability

Resellers are important to the Lifeline program. They support consumer choice and affordability. The proposed FCC changes will have a negative impact on the industry and the families that it supports. The proposal to remove wireless resellers from the Lifeline space would:

  • harm consumers by forcing more than 7 million (or roughly 70%) of all Lifeline subscribers to find a new Lifeline service provider
  • leave some low-income families without wireless service and with limited service options.
  • be detrimental to the program integrity and efforts to guard against waste, fraud and abuse
  • 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. 

As the preference and demand for mobile voice and broadband services has increased, Wireless resellers have willingly sought ETC designations and relieved landline providers of the obligation to provide Lifeline service. It is not clear why the FCC is taking such actions against a program that has been so helpful to low-income Americans. Among those it helps are seniors and veterans who may be retired, disabled, on fixed income, as well as other Americans who are looking for work.

NaLA Asks FCC to Reconsider Lifeline Reform Plans

NaLA proposes adopting conduct-based standards and agent registration to properly focus on bad actors rather than efforts that will harm consumers. “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.”  The National Association of Regulatory Utility Commissioners (NARUC) has also contributed a budget in support of NaLA’s initiatives in this matter.

About the National Lifeline Association

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential pieces 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 education, cooperation and advocacy.

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admin1FCC Lifeline Reform Detrimental to Lifeline Subscribers
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FCC Commissioner, Mignon Clyburn is Stepping Down After 8 Years

“I’ve done all I can do. And it’s time for me to serve in another way,” Clyburn said during the FCC meeting. After eight-years of fighting for minority communities and low-income families, the Obama nominee will be stepping down from the Federal Communications Commission (FCC) next month.

Clyburn has been an active voice for helping Americans

In 2009, when she was appointed as commissioner by President Barack Obama, the FCC passed their net neutrality rules in 2015. Since then, Clyburn’s loyalty  has focused on being a stern defender of the rules.

Her time with the FCC included protecting the FCC Lifeline Program, and being a supporter of improving inmate calling services.

Clyburn was heavily supported by the public

Besides being the first woman to serve on the FCC, she was also the first woman to chair the agency. Clyburn was included in CNET’s list of notable women in tech, which celebrated International Women’s Day this year. She was commended for making a difference in the field of technology.

After all her accomplishments, Clyburn has made her final decision about the time to leave. Her term  is over at the end of this year, so she would have been leaving at that time anyway. She told Post and Courier that she was indecisive about choosing the perfect time to leave.

“I was not 100 percent sure when I woke up this morning that this was the day,” she said. “But I think it’s the right time for me and it’s a good time to have a reset to allow someone else to come in and pass that baton.”

Though Clyburn’s job required her to be a spearhead and bump heads with opposers, the 56-year-old was not only respected, but well-liked by representatives and colleagues.  

Ajit Pai released a statement on Clyburn’s announcement of stepping down referring to her as “a wonderful colleague and friend.”

“I congratulate Commissioner Clyburn on her distinguished tenure at the FCC. She has been a tremendous leader and a committed public servant throughout her time here. As the first woman to head the agency, she led skillfully through a transition and put her stamp on the Commission, including through her steadfast leadership in telehealth, media diversity, and digital inclusion. I have enjoyed working with her and, even when we have not seen eye-to-eye on policy, I have always held her candor and thoughtfulness in the highest regard.”

 

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admin1FCC Commissioner, Mignon Clyburn is Stepping Down After 8 Years
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