All posts tagged: Lifeline Program
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/
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.
2019 NaLA Annual Conference Presentations
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.
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.”
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.”
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
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.
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.
FCC 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:
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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. -
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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Minimum Service Standard Proposal by FCC Threatens Low Income Access to Wireless Connectivity
- FCC Must Act Now to Prevent Disruption in Lifeline Service for Millions of Low-Income Americans and Hundreds of Thousands of Veterans
- Lifeline Service Extended by FCC, Providing Critical Connections During COVID-19 Crisis