All posts tagged: Lifeline Program

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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Lifeline Minimum Service Standards Increase Effective December 1, 2018

December 1, 2018 – New Lifeline minimum service standards are in effect today, as stated in the FCC’s 2016 Lifeline Modernization Order. The Order (FCC 16-38) aimed to modernize Lifeline to support broadband and establish an automatic update to the Lifeline minimum service standard for mobile voice service through November 30, 2018.

Newly Effective Lifeline Minimum Service Standards

The new standards, effective December 1, 2018 are as follows:

  • Mobile broadband (data): 2 GB/month of 3G mobile technology
  • Mobile voice: 1,000 minutes per month
  • Fixed (home) broadband: 18/2 Mbps –*There is an exception if the service provider does not offer any generally available residential fixed broadband packages at the subscriber’s residence that meet this standard (in this case, the service provider can receive support for the highest-performing, fixed broadband residential offering of at least 4 Mbps/1Mbps)
  • Fixed (home) broadband: 1,000 GB of usage per month
  • Fixed (home) voice: No minimum service standard

How Will the Lifeline Minimum Service Standards Affect Lifeline Participants?

The increase in minimum standards for data has increased from 1GB/month to 2GB/month, while voice users see an increase in the minimum from 500 to 1,000 minutes. The doubling of these standards is a step towards the future for low income Americans who participate in the program. 

The 2016 Order, which initiated the gradual service standard increases, was created with the intent to phase-out voice-only subsidy in an effort to increase focus on providing broadband, on which Americans are becoming increasingly reliant.

2019 Lifeline Budget Determination

In addition to the changes in minimum service standards, the 2016 Lifeline Order adopted an initial budget of $2.25 billion for the calendar year beginning January 1, 2017. The Order stated that the budget amount would be indexed to inflation in accordance with the Consumer Price Index for all items from the Department of Labor, Bureau of Labor Statistics in subsequent years.

In accordance with this formula for determination, the Wireline Competition Bureau announced via the July 2018 FCC Public Notice that “the indexed budget for federal universal service support for the Lifeline program for the calendar year beginning […] January 1, 2019, will be $2,327,114,250.”

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Lee SchaferLifeline Minimum Service Standards Increase Effective December 1, 2018
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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 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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NaLA Files Comment on TracFone Emergency Petition Requesting National Verifier Delay

September 12, 2018 – The National Lifeline Association (NaLA) filed comments supporting the recent TracFone emergency petition requesting alterations to the Lifeline National Verifier by the Universal Service Administrative Company (USAC), administrator of the Lifeline Program.

TracFone Emergency Petition Requests FCC Delay USAC National Verifier Launch

The emergency petition from TracFone urges the Federal Communications Commission (FCC) to delay USAC from further implementation of the National Verifier.

TracFone has concerns that the National Verifier, which has already launched in six states, is not integrated to all of the necessary state databases that would allow it to effectively function in determining Lifeline eligibility.

The petition requests that USAC ensure, prior to launching the National Verifier in additional states, that the National Verifier access key databases (particularly the Medicaid Enrollment Databases) and also accept eligibility proof from select third parties.

TracFone reports that the requested alterations will improve the efficiency of the automated and manual eligibility processes, which ultimately support the National Verifier.

NaLA Files Comments Supporting TracFone Emergency Petition to Delay Lifeline National Verifier

NaLA recently filed comments echoing the TracFone petition concerns regarding the launch of the National Verifier.

While the support for the National Verifier has been consistently unanimous, the success of the National Verifier in confirming subscriber eligibility is based on participation in qualifying federal programs, particularly the Medicaid enrollment database.

Medicaid participants account for 29 percent of Lifeline enrollments and the USAC’s launch strategy has resulted in leaving some of the subscribers who need Lifeline the most — especially those enrolled in Medicaid and dependent on Lifeline services  — at risk for losing phone service, not just to connect to society but also to manage their care” – National Lifeline Association

USAC also refused to accept evidence of eligibility for the manual verification process through third-party sources such as Managed Care Organization (MCO). USAC not allowing proof of eligibility through MCO will interfere with the efforts to enroll eligible subscribers in the Lifeline program.

To provide an enrollment process that better serves eligible consumers, NaLA suggests, “directing USAC to accept proof of eligibility from MCOs […] will make the National Verifier more efficient and effective for USAC, consumers and service providers.”

Read NaLA’s Comments On TracFone’s Emergency Petition

NaLA Comments on TracFone Emergency Petition

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Lee SchaferNaLA Files Comment on TracFone Emergency Petition Requesting National Verifier Delay
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How the Lifeline Program Helps Sarah Victory Continue Her Journey in Being a Super Mom

“I am thankful enough to have an affordable phone service,”  44- year-old Sarah Victory from Coweta, Oklahoma says in a relieving tone. Sarah works from 3 pm to 11 pm as a Certified Nursing Assistant. She also takes care of her three children (one is her 3-year old autistic son)  and is the emotional support for her husband, who suffers from depression. Sarah happily says that at her workplace the patients label her “the best one” and it’s most likely due to her dedication at work and home. Being a family woman and the go-to-person can be overwhelming, but Sarah says that it’s her job as a mother and wife. Her day-to-day routine varies, but the one thing that is consistent is her consumer relationship with the Lifeline program.

With so many responsibilities, bills, and other family financial commitments, Sarah is happy that the Lifeline program is effective and efficient. Being enrolled in the Lifeline program has allowed Sarah to connect with her children, husband, and doctors. “Because I can’t afford normal service, being in the Lifeline program allows me to talk to my doctor and my child’s doctor,” she says. The convenience and affordability of her Lifeline phone service not only makes her life easy even when everything else is hectic, but it allows her to stay connected with the important aspects of her life. Because she has to keep a closer eye on her son’s health, being able to contact his doctor is important. If it were not for the Lifeline Program how else would Sarah keep up with her autistic son’s health? As a busy mother, wife, and employee, the victory is more than her last name; it’s in her Lifeline phone service.

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admin1How the Lifeline Program Helps Sarah Victory Continue Her Journey in Being a Super Mom
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