(The following is reposted from our September 14, 2012, USTelecom Broadband Connections newsletter)
Based on a resolution adopted by the National Association of Regulatory Utility Commissioners in 2009, the FCC, the National Association of State Utility Consumer Advocates and NARUC have designated the week following Labor Day as “National Telephone Discount Lifeline Awareness Week.” Better known as “Lifeline Awareness Week,” in 2012 the week falls on September 10th through 16th. The outreach effort is especially important this year, as it focuses on educating current subscribers and potential applicants about the recently-adopted rules governing eligibility criteria and non-duplication of assistance.
Recent Lifeline Changes
Eligible telecommunications carriers, including USTelecom members, have had to digest and cope with significant changes in the FCC’s universal service low-income programs this year. Many of those changes have dealt with eligibility, certification and recertification and implementation by Lifeline providers. Lifeline providers have had to address internal operational issues and relationships with states involved in Lifeline programs, as well as developing new processes and materials to help educate current and prospective Lifeline subscribers about the new rules and procedures.
FCC Outreach Materials
The FCC has a page with quick links to Lifeline outreach materials along with selected FCC releases on Lifeline reform. The FCC also has a Lifeline consumer outreach page containing more helpful information to enhance consumer understanding of and participation in the federal Lifeline program, including an explanation of the income qualifications and list of programs that allow Lifeline eligibility.
Useful Information for Consumers
Consumers may find the information contained at Lifeline Program FAQs particularly useful. The document covers eligibility standards, and includes a click-through to a Lifeline Eligibility Pre-Screening Tool on the USAC website. Another page provides contact information for ETCs by state. The FAQs address several important issues concerning eligibility determinations, including a list of acceptable documentation to demonstrate eligibility, the need to reconfirm eligibility each year, and the definition of a household.
Review Lifeline PSAs
Another helpful page covers the FCC’s Lifeline public service announcements. The site provides the text of the announcements and includes downloadable MP3 files that can be used by providers. Federal government documents and other federal government media are not subject to copyright, so the announcements may be used without compensation or the need to seek permission from the agency. The PSAs include 15, 30 and 60 second announcements on eligibility and duplication, in both English and Spanish. A Lifeline poster directed at consumers is also available. Finally, the FCC provides an explanation of the special rules and benefits applying to tribal lands.
USTelecom Lifeline Advocacy
USTelecom has been very active on Lifeline issues this year. While the basic policy thrust of the Low-Income Fund Order released by the FCC on February 6 was consistent with USTelecom advocacy, the Order raised many issues about implementing the new policies and procedures. Many of those implementation issues concerned communicating with current or potential Lifeline subscribers, particularly with respect to determination of eligibility and certification.
USTelecom Files Multiple Petitions and Comments
On March 9th, USTelecom, joined by other associations, filed a Petition for Waiver and Clarification concerning the timing of implementing the April 2012 Lifeline disbursement based on the new level of $9.25 per subscriber. In response to that filing, the FCC’s Wireline Competition Bureau delayed the date for several months for those companies needing more time.
On April 2, USTelecom filed a comprehensive Petition for Reconsideration and Clarification covering 14 key issues, addressing new rules and procedures that could result in unnecessary burdens on Lifeline providers and could cause confusion among both providers and current and potential Lifeline subscribers. The same day, USTelecom filed comments on the Further Notice of Proposed Rulemaking that accompanied the Lifeline reform order.
On April 25, USTelecom filed a Petition for Waiver raising concerns about the timing for implementing the requirement that ETCs must certify that new Lifeline subscribers meet the new eligibility requirements. This requirement is problematic for ETCs in those states that either enroll subscribers in the Lifeline program or determine Lifeline eligibility for all or some subscribers in their respective jurisdictions. This waiver request was granted May 31st. Currently, some states have resolved the problem, but the waiver is still needed and in place in California, Colorado, the District of Columbia, Florida, Idaho, Nebraska, Oregon, Tennessee, U.S. Virgin Islands, Utah, and Vermont.
More recently, USTelecom filed comments on a petition filed by TracFone concerning adding another program to the list for determining Lifeline eligibility. USTelecom took no position on the additional program, but requested that the FCC limit changes to Lifeline eligibility requirements to once per year on the same date. USTelecom also said any change should be in conjunction with the determination of the new income requirement based on federal poverty guidelines.
The Lifeline program is large and continues to grow, and various implementation issues raised by USTelecom have not yet been resolved. The Commission has also not yet adopted an order in response to the issues raised in the further notice, most prominent of which is extension of Lifeline support to broadband services. USTelecom will continue to represent the industry on these important issues to advocate for an efficient and effective Lifeline program.