All posts tagged: National Verifier

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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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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Congresswomen Eshoo and Clarke Oppose FCC Lifeline Changes

On Wednesday, March 21st Congresswomen Eshoo and Clarke Oppose FCC Lifeline Changes in a letter to FCC to Chairman, Ajit Pai, encouraging him to protect the Lifeline Program.

Eshoo and Clarke Oppose FCC Lifeline Changes After a Recent Committee Vote

Congresswomen Anna G. Eshoo and Yvette D. Clarke composed a letter following a recent meeting where the FCC voted 3 to 2 on party lines to proceed with a new proposal that will make it harder for eligible households to attain Lifeline’s services. The FCC’s plan includes establishing caps on the Lifeline program, requiring co-pays from participants, and negating 4 out of 5 of the current providers of Lifeline services. The letter encourages the Chairman to protect the Lifeline program, because without it, Americans who participate in the program will not be able to do things like schedule medical appointments, help their children complete their homework, keep in contact with the government, or keep in touch with their family. “The program helps Americans-including disproportionate numbers of veterans and people of color-help themselves.”

Congresswomen Suggest National Verifier as an Alternative Solution to Proposed Lifeline Changes

Eshoo and Clarke expressed in their letter that they understand the Chairman is aiming to restrain fraud and abuse, “experts have repeatedly testified that the sorts of measures you are proposing do not have a successful track record.” Instead, the two give another solution to the Chairman’s concerns of fraud and abuse, which is rolling out the National Verifier. In the letter they share that, “The Government Accountability Office has testified that the National Verifier will resolve most issues that may remain with the program without the same brutal side effects” as removing almost 8 million participants from the program.

The congresswomen were not alone in their opposition to recent FCC changes to Lifeline. The letter opposing FCC changes to Lifeline was signed by 60 House members, who all concluded that the proposal is “untimely, counterproductive, and undermines [their] shared goal of connecting everyone.”

 

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admin1Congresswomen Eshoo and Clarke Oppose FCC Lifeline Changes
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CTIA Opposes FCC Lifeline Changes Banning Wireless Resellers

February 21, 2018 –  CTIA, an wireless connectivity advocacy organization, voices their opposition to the recent FCC proposals on the Lifeline Program, which provides essential communication services to qualifying low-income American families. CTIA’s filed their comments to the FCC in response to the FCC’s 2017 Notice of Proposed Rulemaking (NPRM) and Notice of Inquiry (NOI), and more specifically comments on concerns over the proposed elimination of wireless resellers from the Lifeline Program, which would ban non-facilities-based providers from serving as Lifeline Providers.

CTIA on Elimination of Wireless Resellers from Lifeline Program

CTIA’s belief that the Commission’s proposal elimination of wireless resellers from Lifeline would negatively impact competition and harm low-income consumers supports the integrity of the Lifeline program and urges the FCC to reconsider these key issues. CTIA expressed that while it supports the FCC’s commitment ensure the integrity of the Lifeline Program. However, in the letter they stated that “expeditious implementation of the National Lifeline Eligibility Verifier (National Verifier or Verifier) is the most important thing the Commission can do to limit waste, fraud, and abuse in the Lifeline program. Accordingly, the Commission should remain focused on implementing the National Verifier before considering any further large-scale program reforms” and that the organization “strongly encourages the Commission not to adopt the proposal in the NPRM/NOI to exclude non-facilities-based providers from the Lifeline program.”

CTIA to FCC on “Exhibit A” Lifeline Economic Study

Also referenced in the letter from CTIA was the “Exhibit A” Declaration by Dr. John Mayo, an recently conducted economic study which also supports of not excluding resellers (non-facilities-based providers) from Lifeline. This study provides evidence that the NPRM’s proposal to limit Lifeline facilities-based carriers is inconsistent with economic basis of Lifeline and doesn’t support the goal of universal connectivity.  CTIA concludes “Ultimately, Dr. Mayo’s analysis shows that the data on network investment do not support limiting subsidies to facilities-based providers and excluding non-facilities based providers in order to further incent deployment.  In light of the economic evidence, the Commission should conclude that, in order to avoid undermining investment in broadband networks, it must continue to allow non-facilities based providers to participate in Lifeline.”

Read Complete Filing of CTIA Comments to FCC

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/03/180221-CTIA-Lifeline-Comments.pdf”]

 

 

 

About CTIA:

CTIA® represents the U.S. wireless communications industry and the companies throughout the mobile ecosystem that enable Americans to lead a 21st century connected life. The association’s members include wireless carriers, device manufacturers, suppliers as well as apps and content companies. CTIA vigorously advocates at all levels of government for policies that foster continued wireless innovation and investment. The association also coordinates the industry’s voluntary best practices, hosts educational events that promote the wireless industry and co-produces the industry’s leading wireless tradeshow. CTIA was founded in 1984 and is based in Washington, D.C.

About NaLA:

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential components 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 our mission to “support providers, distributors, participants, and supporters of lifeline through education, cooperation, and advocacy.”

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Lee SchaferCTIA Opposes FCC Lifeline Changes Banning Wireless Resellers
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Sprint Opposes Lifeline Wireless Reseller Ban

February 20, 2018 — Sprint expresses concerns with the FCC’s recent proposals concerning a Lifeline wireless reseller ban, which would prohibit wireless resellers from serving low income households as Service Providers through the Lifeline Program. The Notice on Proposed Rulemaking (NPRM), an initiative from the FCC’s November 2017 Open Meeting that included various Lifeline Program initiatives, such as banning wireless resellers from providing Lifeline service.

Sprint says Lifeline Wireless Reseller Ban Could Affect 6.1 Million

Sprint, a facilities-based provider, has echoed the concerns of various non-facilities-based providers on the recent FCC proposals found in the NPRM. They oppose the Lifeline wireless reseller ban that the FCC is pursuing, and state that the “elimination of resellers from the Lifeline program would be disruptive to current and potential Lifeline customers. The majority of Lifeline customers obtain service from resellers, which had an estimated 6.1 million customers as of December 2017.”

Consequences of FCC Lifeline Wireless Reseller Ban

The letter from Sprint highlights many concerns for Lifeline Participants that rely on the program to assist them in accessing essential communication services. They noted that the Lifeline wireless reseller ban would result in a “a sharp reduction in the number of wireless service providers offering Lifeline service; in some areas, there may remain only a single facilities-based wireless Lifeline service provider, and in other areas, there may be no facilities-based wireless Lifeline service provider at all.” Sprint adds that “users [Lifeline Participants] will not realize they need to obtain service from a facilities-based carrier, some will not know how to transfer their service, some will not provide required documentation in a timely manner. Some customers will successfully transfer to a facilities-based carrier, but some will lose service altogether.”

The forced exit of wireless resellers as Lifeline service providers from the Lifeline market is disruptive of consumer access to emergency services, or other resources necessary for employment, health care, or childcare.

Read Sprint’s Letter to FCC

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/02/Sprint-LL-comments.pdf”]

Postponing of Lifeline Program Eligibility Verifier (National Verifier)

In addition to concerns about the ban of wireless resellers in Lifeline, Sprint also asserts in the letter to the FCC that the National Verifier is a crucial part of reducing waste, fraud, and abuse within the program – and should be the most important focus of the Commission at this time.

The recent postponing of the National Verifier launch has created concern that the Commission’s actions do not support it’s stated goals about strengthening the Lifeline Program eligibility verification processes.

“Getting the deployment timeline back on track is the surest way for the Commission to advance the common goal of ensuring Lifeline program integrity,” Sprint states in their letter to the FCC. Sprint, TracFone and other Telecommunication companies are in agreement that efforts are best focused on the National Verifier, prior to making any drastic changes to the program, which helps nearly 11 million low-income Americans access phone and internet services.

 

About NaLA:

The National Lifeline Association is the only industry trade group specifically focused on the Lifeline segment of telecommunications. We support the 4 essential components 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 our mission to “support providers, distributors, participants, and supporters of lifeline through education, cooperation, and advocacy.”

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Lee SchaferSprint Opposes Lifeline Wireless Reseller Ban
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Dems Request GAO Review of FCC on Lifeline National Verifier

Jan. 25, 2018 — A letter from a number of members from the U.S. House Energy & Commerce aasked the Government Accountability Office (GAO)  to review the FCC’s efforts to deploy the Lifeline Program National Verifier — an initiative that aims to verify subscriber information for Lifeline Program participants and ultimately increase the integrity of the Lifeline Program.

House Dems Ask GAO to Review FCC Progress on Lifeline Program National Verifier

In November, the FCC adopted the Lifeline reform revamp and FCC chairman Ajit Pai revoked the most recent round of certifications to new applicants until the FCC addressed the verification issue, but the letter from House members expresses concern that the FCC is not doing all it can to launch the Lifeline Program National Verifier in a timely fashion. In their letter to the GAO, they called for prioritization of the Lifeline Program National Verifier and requested answers to a number of questions, including whether the FCC has a strategic plan for implementing the program on time and what steps it has taken to implement that.

Representatives who signed the letter included Bobby Rush, Frank Pallone, Anna Eshoo, Mike Doyle, G.K Butterfield, Doris Matsui, Jerry McNerney and Evette Clarke.

Source Ref.:  B&C News, House Dems Seek GAO Review of Lifeline Verifier  By John Eggerton

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Lee SchaferDems Request GAO Review of FCC on Lifeline National Verifier
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FCC Postpones National Verifier Launch for Lifeline Program

DEC 1, 2017 —  A newly released FCC Public Notice (WC Docket No. 11-42) announces the FCC Postpones National Verifier for Lifeline Program, which aims to verify subscriber information for Lifeline Program participants.

Updated National Verifier Launch

Up until this point, the National Verifier had been on schedule to launch in six states beginning this month. The initiative, born out of the 2016 Lifeline Modernization Order, is now set to launch in early 2018. Once fully implemented, the National Verifier initiative is the next step toward increasing the integrity of the Lifeline Program, which provides low-income American families access to essential communication services.

The FCC decision to Postpone the National Verifier Launch for Lifeline Program is mainly related to requirements of the Federal Information Security Management Act of 2002 (FISMA), an act created to ensure data security within the federal government.

The Wireline Competition Bueau (WCB) stated in the FCC Public Notice that “to fulfill this responsibility and protect the security of Lifeline applicants’ personal information, we expect that a postponement until early 2018 will provide USAC with sufficient time to complete all FISMA requirements prior to the initial launch of the National Verifier.”

Read the Dec 1 FCC Public Notice on National Verifier Launch Date

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2017/12/FCC-Public-Notice-December-1-2017-Wireline-Competition-Bureau-DA-17-1167A1.pdf”]

More on the National Verifier Launch Timeline

USAC will host a webinar on Monday, December 4 at 1 PM ET to discuss the National Verifier launch timeline and answer questions. Register Here.

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Lee SchaferFCC Postpones National Verifier Launch for Lifeline Program
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