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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.

12/19/2018 Chelsea Boylan FCC, Member News, USAC No comments

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

10/01/2018 Lee Schafer Member News No comments

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.”

08/31/2018 admin1 FCC, Lifeline Advocacy, USAC No comments

FCC Public Notice Announces Universal Lifeline Forms

February 20, 2018 — FCC Public Notice DA 18-161 announces the implementation of Universal Lifeline forms to be used during program eligibility determination. The Wireline Competition Bureau (WCB) provided guidance for use of these Universal Lifeline forms, which will be a requirement for Lifeline service providers starting July 1, 2018.

New Universal Lifeline Forms

The FCC asserts that “Implementing universal forms will foster greater consistency in the Lifeline eligibility determination and recertification processes, thereby aiding in program administration and reducing improper payments due to errors in application and recertification forms.” Lifeline Program application and recertification forms are a large part of the documentation process related to consumer-eligibility for the Lifeline Program, which provides qualifying low-income Americans with wireless telecommunications.

The WCB collaborated with the Universal Service Administrative Company (USAC), the organization that administers Lifeline Program funds, to develop simple, user-friendly forms to improve the ease of processes related to eligibility-verification for the Lifeline Program. The universal forms include FCC Form 5629 (Lifeline Application Form), FCC Form 5630 (Lifeline Annual Recertification Form), and FCC Form 5631(Lifeline One-Per-Household Worksheet). These are available on the Lifeline Program Form page.

In addition to the future implementation of the National Verifier, these forms are an important step toward streamlining eligibility and recertification processes that lessen the margin of error during the Lifeline application process.

Read FCC Public Notice DA 18-161 here:

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2018/02/FCC-Public-Notice-NaLA-Blog-2222018.pdf”]

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 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.”

NaLA’s Vision:

“In America, every person should have access to essential communication services.”

02/22/2018 Lee Schafer FCC, Lifeline News, Member News, USAC No comments

FCC Seeks to Impose Cap on Lifeline Program

October 26, 2017 — Washington D.C. Recent FCC proposals seek to impose caps on Lifeline Program funds.

Universal Service Funds & FCC Proposal for Cap on Lifeline Program

The rulings would seek to impose a $2 Billion cap on the Lifeline Program, whose funds are administered by the Universal Service Administrative Company and account for around 18% of the Universal Service Funds (USF), according to USAC’s 2016 Annual report. The USF also provides funding to additional programs, such as High Cost, Rural Health Care, and Schools and Libraries programs.

“The idea of a USF Lifeline cap has been a contentious one at the FCC. Democratic commissioners traditionally have opposed a cap, perhaps because a cap in the low $2 billion-range would cover only half of eligible recipients, according to government estimates,” writes Joan Engebretson, Executive Editor of Telecompetitor.

Limit Universal Service Funds for Lifeline Program to Facilities-based Providers

In addition to capping the funds to the program, these rulings seek to limit funds to facilities-based providers. Currently, most Lifeline Program participants receive service through re-sellers. This proposal will have the most impact on the continuation of Lifeline Program and its ability to effectively provide support to the low-income families to whom it provides service.

“By requiring participating carriers to be facilities-based, the proposed Lifeline item would reinstate by rule a statutory requirement from which it has granted forbearance definitively. More importantly, the FCC’s proposed decision would force about 70% of the approximately 10 million Lifeline subscribers to find a new service provider,” states John Heitmann, of Kelley Drye & Warren LLP.

“Many of these 7 million Lifeline eligible subscribers will find that they have few, if any choices – forcing them to pay more for less, purchase a new phone, or lose service. Nearly all affected Lifeline subscribers would be forced to find alternative service offerings for the no-cost to consumer services they typically have access to today. No wireline service provider offers no-cost to consumer Lifeline services. With no competition from wireless resellers, Lifeline service offerings are likely to stagnate, become more costly and lack in innovation. Wireless – and wireless ETCs – lose under the FCC’s proposal. But the biggest losers will be Lifeline-eligible, low-income consumers across rural America and especially those in urban America. The FCC’s proposal for Lifeline is so skewed and disruptive that it is almost certain to threaten the very fabric of bipartisan support that has underpinned the Universal Service Fund for decades.”

10/28/2017 Lee Schafer Member News No comments

National Verifier Update

<H2>National Verifier Initial Launch States & Eligibility Verification Data Sources</H2>

USAC announced the initial group of states that will roll into the National Verifier and the automated eligibility verification data sources that the National Verifier will use for each state. The initial launch states are:

Colorado (automated data sources: SNAP, Medicaid, Federal Public Housing)
Mississippi (automated data sources: SNAP, Federal Public Housing)
Montana (automated data sources: Federal Public Housing)
New Mexico (automated data sources: SNAP, Medicaid, Federal Public Housing)
Utah (automated data sources: SNAP, Medicaid, Federal Public Housing)
Wyoming (automated data sources: Federal Public Housing)

IN THIS ISSUE

NV Initial Launch States

Website Update

NLAD Instructional Videos

ZIP Code Requests

Lifeline Claims System

Reverification Elections

FCC Form 497 Reminder

Lifeline Program Webinar

If one of the automated data sources can’t verify the subscriber’s eligibility, the National Verifier will prompt the subscriber to submit documentation via the web portal (or via mail) to the Lifeline Support Center, which will conduct a manual review of their eligibility documentation. Visit our website to learn more about the National Verifier.

Service providers that do business in the initial launch states received an email from USAC last month with an invitation to a check-in call, and sign-up links for training/on boarding sessions. If you are a service provider in the initial launch states and have not heard from USAC, please contact us immediately at [email protected] to receive future communications.

Website Update: Eligibility Verification Process by State

USAC updated the Verification Process by State web page in the Verify Subscriber Eligibility section of the website to include additional information.

For each state with a state-specific process, the page included (1) the state’s process for eligibility verification, (2) date sources available to service providers, and (3) whether the state’s system/process complies with the streamlined federal eligibility criteria effective December 2, 2016.

NV Reverification Elections Due Nov. 1

Service providers in the National Verifier’s initial launch states – Colorado, Mississippi, Montana, New Mexico, Utah, and Wyoming – are required to provide eligibility documentation for subscribers who do not pass the automated eligibility check when their records are uploaded into the National Verifier. Those service providers have the option to elect USAC to collect the eligibility documentation on their behalf.

Elections are due on Novemeber 1, 2017. Contacts in the initial launch states will receive a separate email with information on how to elect USAC. For questions about the election process, please email [email protected].

USAC-elected reverification requires close coordination between USAC and the service provider throughout the process. To prepare for the USAC-elected process, make sure the contact information for each consumer record is up-to-date in NLAD.

09/13/2017 Lee Schafer Lifeline News, Member News, USAC No comments

FCC Releases Order on Reconsideration for Lifeline Broadband Providers (LBPs)

New FCC Chairman Pai released an Order on Reconsideration for LBP designations on Friday, allowing the FCC to reconsider the Lifeline Broadband Provider (LBP) designations for nine new Lifeline broadband providers.

Recently effective changes per the 2016 Lifeline Modernization Order included the extension of the Lifeline Program to include broadband services. Inclusion of Lifeline-supported broadband allows qualifying low-income consumers to apply the $9.25 per month subsidy to stand-alone mobile or fixed broadband service as well as bundled voice and data service packages, rather than voice services alone.

Effects on Lifeline Broadband Designation

Several carriers had petitioned for designation as Lifeline Broadband Providers (LBPs) and nine were approved by the Wireline Competition Bureau in orders released in December and January.

According to the recent Order on Reconsideration for Lifeline Broadband Providers (LBPs), the FCC will “set aside the orders designating AR Designs, Boomerang, FreedomPop, Kajeet, KonaTel, Liberty, Northland Cable, Spot On, and WIN as LBPs […] and return those providers’ petitions for designation as an LBP to their status as petitions pending.”

“We find that reconsidering the above-listed petitions for designation as an LBP would promote program integrity by providing the Bureau with additional time to consider measures that might be necessary to prevent further waste, fraud, and abuse in the Lifeline program,” the bureau said.

Regarding the order, USAC commended the FCC’s “commitment to universal service and the integrity of the Lifeline Program”, adding that “reconsiderations […] are common during administration changes.”

How will this affect Lifeline ETCs with Voice Designations?

Lifeline ETCs with voice designations are still authorized to provide Lifeline-supported broadband, while Lifeline subscribers of the affected LBPs will be allowed to select a new service provider. The order has laid out an approach to ensure the effect on consumers is minimized.

02/07/2017 Jordan Axt FCC, Lifeline News, USAC No comments

USAC Submits 2017 National Verifier Plan for Lifeline Program to FCC

Updates to the November 2016 Draft of the National Verifier Plan have been submitted to the FCC and the January 2017 National Verifier Plan is available to review.

The rollout of this plan estimates that the system, which will replace annual Lifeline recertification and the FCC Form 497, will begin implementation on December 31 of this year and be effective in all states and territories by December 31, 2019 pending FCC approval.

The 2017 National Verifier Plan includes updates that have been made based on input from entities within the Lifeline Industry. Upon release of the November 2016 Plan’s draft, USAC opened the floor to concerns and comments that aided them in making revisions, reflected in the recently submitted version seen below. If you are interested in submitting feedback about the 2017 National Verifier Plan, you can send your comments via email to: [email protected].

Please note that all pages marked with “Updated” in the top right corner represent updated slides from the 2016 draft of the plan.

Read More: http://www.lifelinenationalverifier.org/
Source: https://www.nalalifeline.org/wp-content/uploads/2017/01/National-Verifier-Plan-2017.pdf

01/20/2017 Jordan Axt FCC, Lifeline News, Member News No comments

Benefit Port Freeze, Lifeline Modernization Order

The pending changes within Lifeline per the Modernization order will go effect in on December 2. Yesterday, NLAD released a new version (2.8.11) into the pre-production environment that includes the 12 month or 60 day Port Freeze Restriction, which will go live when the order takes effect next month. USAC confirms the intentions of the upcoming changes regarding the Lifeline Benefit Port Freeze within the details of the new changes to the Program Requirement, stating “Lifeline customers will be required to remain with their service provider for a minimum period before they can transfer their benefit to another provider […] and allows Lifeline carriers to invest in high-quality, low-cost service offerings for Lifeline consumers.”

This is an important step – the need for such regulation changes is largely tied to the integrity of the Lifeline Program itself. While the freedom for a Lifeline-eligible consumer to choose their service provider, the Port Freeze will further assure that the ETCs who service their need are protected from unnecessary waste due to Program abuse, allowing the Program to become of better assistance to those for whom the Program was designed to assist during difficult financial times.

port-freeze

Included in the upcoming changes will be the ability to submit requests for Port Freeze Exceptions. Exceptions are allowed, pending the new Provider’s confirmation that one of the following exception qualifications are met:

Current service provider ceases operations, or fails to provide service
Current service provider is found to be in violation of Lifeline Program rules, and the violation impacts the customer for which exception is sought
Customer changes their residential address
Late fees imposed by current service provider meet or exceed the month end-user charge for supported service

Requests for exception are reviewed on a case-by-case basis by USAC. Additional details provided by USAC on the Lifeline Benefit Port Freeze note that “If any of these [above] situations apply, Lifeline customers may cancel their service and enroll in a new Lifeline-supported service with another provider. In these circumstances, the subscriber is not required to re-verify their eligibility until the end of the original 12 month or 60 day period. The providers shall contact USAC to facilitate sharing eligibility information.”

Further details and answers to FAQs bout the Benefit Port Freeze can be found on the USAC website.

11/04/2016 Lee Schafer Lifeline News, Member News, USAC No comments

Lifeline Broadband Provider (LBP) Designation, Minimum Service Standards

On September 30, 2016, the FCC released a Public Notice (DA 16-118) that offers additional guidance from the Wireline Competition Bureau to entities seeking Lifeline Broadband Provider (LBP) designations for the Lifeline program. Included in the notice are minimum service standards for Lifeline-supported Broadband Internet Access Service (BIAS), and guidelines that will be applicable to LBPs and eligible telecommunications carriers (ETCs) seeking Lifeline reimbursement.

Read the PDF of the FCC Notice (DA 16-118) on LBP Minimum Service Standards:

[pdf-embedder url=”https://www.nalalifeline.org/wp-content/uploads/2016/10/DA-16-1118A1.pdf”]

Source: http://transition.fcc.gov/Daily_Releases/Daily_Business/2016/db0930/DA-16-1118A1.pdf

10/01/2016 Lee Schafer FCC, Lifeline News, USAC No comments