Lifeline Advocacy

NaLA Submits Comments to Senate Universal Service Fund Working Group

Senate Universal Service Fund (USF) Working Group sought comments on program effectiveness and necessary reforms

As the only ecosystem-based organization focused on ensuring that low-income Americans have sustainable, affordable access to essential communications services, NaLA has submitted comments to the Senate Universal Service Fund (USF) Working Group focused on ensuring that low-income Americans have sustainably affordable access to essential communications each and every month.

NaLA’s members include service providers, distributors, network access aggregators, compliance and software solutions vendors, device manufacturers, enrollment representatives, program supporters and beneficiaries invested in the future of the Lifeline and ACP programs. NaLA notes that wireless resellers play an important part in ensuring the success of these programs, including by serving over a third of all ACP subscribers.

The USF Working Group is seeking comments on the effectiveness of – and necessary reforms to – the programs funded by the universal service fund, which includes Lifeline.

Some highlights from the comments NaLA submitted:

NaLA submits that with ACP funding set to run out as early as April 2024, appropriated funding will be needed at least until USF reform can be accomplished.
NaLA proposes that either Congress and the FCC consolidate the Lifeline program with the ACP or reform both so that they better serve the goal of making essential communications services sustainably affordable each and every month.
NaLA recommends that any future low-income program should incorporate key program design elements from the ACP, including a robust monthly service and device benefits, technology neutrality, reasonable benefit transfer limits, and a safe harbor and entry requirements that encourage competition that translates into compelling choices and value for eligible consumers.
NaLA maintains that program integrity can be preserved by conforming eligibility requirements and by reliance on the National Verifier which should be subject to continuous improvement and greater transparency.
NaLA submits that the effectiveness of a low-income support program should be measured by whether low-income households have sustainably affordable access to essential communications services. Adoption is a secondary benefit that can be addressed only in part by a low-income affordable connectivity benefit program.

The full comments, including an executive summary, are available here.

08/24/2023 Glen Echo Group Lifeline Advocacy, Lifeline News No comments

NaLA asks the FCC to support survivors of domestic and sexual violence

The Safe Connections Act directs the Commission to designate either the Lifeline program or the Affordable Connectivity Program (ACP) as the vehicle to provide emergency communications services for survivors

On April 12, NaLA submitted comments to the FCC on its Notice of Proposed Rulemaking to implement requirements of the Safe Connections Act. The comments urge the FCC to designate the Lifeline program as the program to provide emergency communications for qualifying survivors suffering from financial hardship because:

Lifeline is a permanent solution reliably funded through the Universal Service Fund (USF);
Lifeline subscribers are automatically eligible for the Affordable Connectivity Program (ACP) as well, meaning survivors can use benefits from both programs;
And unlike the ACP, Lifeline supports voice services, and Lifeline plans generally include bundles of broadband and voice service, providing survivors with the ability to dial 911, shelters and other support services when necessary.

To adequately serve the needs of survivors suffering from financial hardship and all low-income households, and taking lessons from the successful ACP, NaLA also calls for reform of the Lifeline program, particularly in the event that ACP funding is exhausted (which is expected to be early to mid-2024).

NaLA firmly believes that connecting survivors of domestic and sexual violence is a literal lifeline to safety, providing access to information, resources and support they might not otherwise have.

You can read the full comments here, which include details on NaLA’s suggestions for Lifeline reform and other recommendations for supporting survivors of abuse through access to essential communications services.

04/26/2023 Glen Echo Group FCC, Lifeline Advocacy No comments

NaLA releases findings from 2022 Annual Consumer Survey

Results from more than 60,000 respondents indicate that consumers need affordable access to mobile wireless voice and broadband services to participate equally in all facets of daily life

NaLA’s Annual Survey of Lifeline and Affordable Connectivity Program subscribers – conducted between November 21 and December 8, 2022 provides insights into consumer demographics and experiences with FCC internet subsidy programs.

The survey results indicate that low-income consumers use Lifeline and/or ACP service to connect to family and to access other government programs, healthcare, jobs and online education.

2022 Key Takeaways

Consumers want and need mobile wireless: More than half of those surveyed said they would choose to have mobile and fixed broadband service if they could afford both, but 43% said mobile wireless services best meet their household needs. Only 2.5% of those surveyed say fixed broadband alone would suffice.
Voice, text and data are all essential. While nearly 80% of consumers surveyed value access to voice, text and data equally, consumers indicated making and receiving calls as the most important form of communication.
Consumers want choice and control of their benefits. More than 90% of those surveyed prefer having the ability to combine Lifeline and ACP support in order to get more robust benefits. This practice is currently prohibited in the state of California, but it’s clear consumers prefer to have the ability to combine benefits.
Low-income consumers need affordable access to more mobile broadband than they currently use on limited plans and budgets. More than 90% of consumers throttle their data usage over the course of the month because they cannot afford to purchase more on top of their capped plans.
No co-pay plans are essential to keeping low-income Americans connected. Nearly 95% of Lifeline and ACP subscribers say they cannot afford any additional payments toward wireless and broadband services. Lifeline and ACP are essential to keep low-income Americans connected.
Most Lifeline/ACP subscribers lack access to credit and are unbanked. More than half of Lifeline/ACP subscribers surveyed do not have a debit or credit card or a bank account.

“Imagine life without mobile wireless access to the internet in 2022. It’s nearly impossible to conceive of how a family could function. But without programs like Lifeline and ACP, many Americans would not have a phone number or an internet connection and would be cut off from society,” said David B. Dorwart, Chairman of the NaLA Board. “NaLA’s survey shows that the majority of Lifeline and ACP recipients live below the Federal Poverty Guidelines. This means that our programs are working to bring connectivity to those who need help the most. It is crucial that lawmakers continue to support these programs to ensure that all Americans have affordable access to essential communications.”

The full results, including more insights into demographics, are available here. Download the one-pager of these highlights here.

Read the official press release here.

12/14/2022 Glen Echo Group FCC, Lifeline Advocacy, Lifeline News, Press Releases No comments

Listen to NaLA Board Member, Danielle Perry, talk about Lifeline and ACP on “The Divide” Podcast

Danielle Perry, NaLA Board Member and chief compliance officer at TruConnect, joins host Nicole Ferraro on The Divide, a podcast from Light Reading, to talk about how the company is keeping customers connected through the federal government’s Lifeline program and the Affordable Connectivity Program (ACP).

The episode covers discussions about Lifeline and the Affordable Connectivity Program (ACP); Why TruConnect, a mobile virtual network operator (MVNO), is pushing back on the California Public Utilities Commission (CPUC) potential ruling; and the need for consumer advocacy regarding mobile and home connectivity.

Listen to The Divide: TruConnect’s Danielle Perry on the role of MVNOs in keeping people online here.

Read the full transcript of this episode 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 the providers, distributors, participants, and supporters of Lifeline through education, cooperation, and advocacy.”

09/12/2022 Chelsea Boylan Lifeline Advocacy, Member News No comments

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/

10/02/2020 Lee Schafer FCC, Lifeline Advocacy, Lifeline News, Member News No comments

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.

10/01/2020 Lee Schafer FCC, Lifeline Advocacy, Lifeline News, Member News, Press Releases No comments

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 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]

03/17/2020 Jordan Axt FCC, Lifeline Advocacy, Lifeline News, Member News, USAC No comments

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 program—which provides education on industry standards, regulatory compliance and industry-specific best practices—offers 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.

12/11/2018 Lee Schafer Lifeline Advocacy, Lifeline News, Member News No comments

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.”

11/27/2018 Lee Schafer FCC, Lifeline Advocacy, Lifeline News, Member News No comments

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 TracFone, Sprint, 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

11/06/2018 Lee Schafer FCC, Lifeline Advocacy, Lifeline News, Member News No comments