Lifeline Advocacy

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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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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NaLA Supports National Lifeline Awareness Week With Informational and Social Media Campaigns

NaLA Supports National Lifeline Awareness Week With Informational and Social Media Campaigns

Many eligible households who are not enrolled in the Lifeline program struggle to afford essential telephone service that allows them to reach emergency services, medical personnel, government services, schools, and potential employers. In fact, only 33% of those who are eligible for the Lifeline program are currently enrolled. Additionally, 46% of active Lifeline consumers are retired, disabled or unable to work, and rely on Lifeline for phone and broadband services every day. By raising awareness of the Lifeline program, NaLA seeks to educate those who may have been unaware of the availability of Lifeline and encourage those who are eligible to participate to enroll.

Now, more than ever, it is imperative to highlight the effect of Lifeline on the lives of low-income Americans. In 2017, the FCC proposed devastating changes to the Lifeline program which would significantly cut access to essential phone and broadband services for an estimated 8 million people, which is roughly 70% of Lifeline recipients currently enrolled in the program. The potential cutback of this program would have a profoundly negative impact not only on eligible seniors, the disabled and low-income consumers, but also the 28% of Lifeline consumers who are unemployed and actively looking for work.

“There is much work to be done when an estimated 67% of eligible consumers are not taking advantage of the Lifeline Program.”

“National Lifeline Awareness Week is important to NaLA because, at our core, we believe that every American should have access to essential communication services. There is much work to be done when an estimated 67% of eligible consumers are not taking advantage of the Lifeline Program,” says David B. Dorwart, Chairman of NaLA. “We are also excited to share the personal story of a current Lifeline consumer who expressed how profoundly Lifeline impacts her life. It is important for people to understand how the proposed FCC program changes could negatively impact vulnerable individuals,” he adds.

Because Lifeline affects millions of consumers every day, our service provider members and field agent members have partnered with us to generate informational and awareness campaigns in support of National Lifeline Awareness Week all across the country. Along with its service provider members, field agent members, and other advocates, NaLA continues to pursue changes that result in greater efficiency, accountability, and overall integrity in the Lifeline program. NaLA thoroughly believes in the importance of National Lifeline Awareness Week and applauds the organizations and regulatory bodies that support Lifeline and raise awareness during this week.

Read the original press release here.

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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 MajkszakStay Granted for FCC Tribal Lifeline Rules to Bar Wireless Resellers and Lower Subsidies for Tribal Consumers of Lifeline Program
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NARUC Discusses Lifeline NPRM’s Proposal

On May 18, 2018, National Association of Regulatory Utility Commissioners (NARUC) met separately with Commissioner Carr’s chief of staff and Chairman Pai’s legal advisor. NARUC expressed their support for the Lifeline Notice of Proposed Rulemaking (NPRM) proposal of respecting the state’s role in program administration regarding eliminating ETCs and suggesting cooperative federalism between the Commission and the states.

However, NARUC does not agree with the Lifeline NPRM proposal for eliminating non-facilities-based resellers. Lifeline NPRM said, “To advance our policy of focusing Lifeline support to encourage investment in voice- and broadband-capable networks, we propose limiting Lifeline support to broadband service provided over facilities-based broadband networks that also support voice service.” NARUC commented on Lifeline NPRM’s reasoning behind supporting facilities-based carriers because they feel it “might spur additional investment in infrastructure.”

NARUC’s stance is that non-facilities-based carriers should continue because, not only do they currently serve 75 percent of eligible users, they could also disrupt service to millions of eligible users.

 

 

 

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admin1NARUC Discusses Lifeline NPRM’s Proposal
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NPRM Comments Responding to FCC Lifeline Rulings

March 23, 2018 – Over 23 groups filed comments on the FCC Notice of Proposed Rulemaking (NPRM). The NPRM comments filed were in response to the recent FCC Lifeline Proposals for the Lifeline Program. As the battle to protect the Lifeline Program continues, carriers and telecom companies were among the several who expressed their opinions on the FCC’s proposed rulings regarding the banning of wireless resellers from Lifeline and the effect of this ban on efforts to bridge the digital divide.

US Telecom and Comcast Support FCC Reseller Ban

Companies like US Telecom and Comcast support the Commission on updating the Lifeline program. “Multiple parties agreed with US Telecom that an appropriately structured audit framework will better target waste, fraud, and abuse in the program and would also utilize administrative resources more efficiently and effectively than in prior years,” US Telecom stated in their reply comment.

Those who oppose, believe that the implementation of the National Verifier is a much more effective focus for the Commission, and one that will not negatively impact low income Americans.

Other NPRM Comments Raise Concern on Negative Impact of Reseller Ban

While Comcast and US Telecom side with the Commission’s plan to update the Lifeline program, other carriers and companies, such as AARP,  NACUA, and Greenlining Institute, echo comments like those filed by Sprint and TracFone, opposing Chairman Pai’s NRPM/NOI proposals for the Lifeline program.

These carries and companies agreed that the change will negatively affect the customers, and seem to oppose the true essence of the Lifeline Program, which is to provide affordable services for low income American families.

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State and Local Opposition to FCC Lifeline  

Other groups remain on the same page with protecting the consumers from being forgotten through the implementation of a reseller ban in Lifeline. City of Boston, Massachusetts, City of Los Angeles, California, City of Portland, Oregon and the Texas Coalition of Cities for Utility Issues all agree that the Lifeline Program should remain affordable.

“The cities agree with numerous commenters that Lifeline has always been, and must remain, an affordability program, not an infrastructure subsidy”, and that “the Commission should not utilize the Lifeline program to achieve a goal for which it is not designed.”

Other opposition to the NPRM and NOI include FCC Commissioner Clyburn, as well as members of Congress.

Filed Replies Totaling 23 NPRM Comments, Includes Pa. PUC

In total, 23 reply comments were submitted, and 9 groups fully opposed the reseller ban. Others either support the ban or have requests, like the Pa. PUC, who opposes the proposal, but stated that  “ as long as consumers meet the Lifeline eligibility criteria and there is sufficient universal service funding for Lifeline, they should continue to receive Lifeline services, including access to the federal subsidy, without limitation as to the duration or current level of the benefit.”

Check out the reply comments here:

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/04/032318lifelinereply.pdf”]

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admin1NPRM Comments Responding to FCC Lifeline Rulings
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AARP, NASCUA & Greenlining Institute File Comments Opposing FCC Lifeline NRPM

AARP, NASCUA, and other groups join the list of organizations filing replies to the FCC Lifeline NRPM. The Notice of Proposed Rulemaking and Notice of Inquiry (NOI) propose changes to the Lifeline Program, such as barring wireless resellers from operating as Lifeline Service Providers.

AARP and NASCUA Oppose FCC Lifeline NRPM

The AARP was among those who filed comment on the FCC Lifeline NPRM, expressing concern for the consumers and the marketplace. “If implemented, this change would dramatically alter the current marketplace and significantly reduce consumer choice,” their comment stated.

AARP pointed out that ”numerous commenters are similarly critical of the 2017 NPRM proposal to ban resellers from participation in the Lifeline program,” including NASCUA who argued in their NPRM comments that the proposed ban on resellers is not the ideal solution to any waste, fraud, or abuse that exists in the program due to its potential harm to consumers, calling the ban “an unreasonably blunt tool”.

Comments Filed by the Greenlining Institute Opposing FCC Lifeline NRPM

The Greenlining Institute, an organization that advocates for racial and economic justice, also expressed concerned about the reseller ban’s affect on low-income American consumers. They stated, “This proposal will cause irreparable harm to the program and low-income households, particularly households of color. Approximately 70% of current Lifeline participants will need to find a new provider if the Commission adopts this proposal. However, for many of those potentially affected, they may not be able to even find a facilities-based provider (FBP) willing to offer Lifeline service.”

Additional Comments Filed on FCC Lifeline NRPM

Some of the other organizations who also filed comments include Sprint, TracFone, Verizon, CTIA, the Texas Coalition of Cities for Utility Issues, FCC Commissioner Clyburn, members of Congress, the City of Boston, as well as several other state and local entities.

 

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admin1AARP, NASCUA & Greenlining Institute File Comments Opposing FCC Lifeline NRPM
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