Industry Insights

New Lifeline Standards for Filing, Reimbursements, Service & Verification

September 2017
Author:  Connie Stufflebeem

Connie Stufflebeem

Managing Consultant

Consulting

1401 50th Street, Suite 350
West Des Moines, IA 50266-5935

Des Moines
515.223.0159

Lifeline service providers will be affected by upcoming changes to Lifeline standards for filing, reimbursements, service and verification. These important changes are effective now through the first part of 2018.

The first changes become effective with the August data month (September 1 snapshot). New reimbursement claims for the Lifeline program can’t exceed a service provider’s subscriber count in the National Lifeline Accountability Database (NLAD). That is, the Universal Service Administrative Company (USAC) will reject any Federal Communications Commission (FCC) Form 497s for which the number of subscribers claimed for reimbursement is greater than the subscriber count in NLAD on the snapshot date. If the form’s rejected, payment may be delayed.

Companies should compare their FCC Form 497s to the NLAD subscriber snapshot before submission and keep NLAD entries up to date, per the requirements.

Also, FCC Form 497 will be retired after the December 2017 data month filing. Starting with the January 2018 data month (February filing period), the E-File system will use the NLAD subscriber snapshot as the default basis for determining support payments to service providers. Under the new process, service providers will download a list of eligible subscribers in E-File, add dollar amounts for claimed subscribers, add reason codes for unclaimed subscribers, upload the report to E-File, then certify and submit.

USAC recommends all companies confirm their FCC Form 497 filer permissions and the certifying company officer’s E-File accounts and review the process for keeping subscriber counts in NLAD up to date.

In accordance with the 2016 Lifeline Modernization Order, the minimum service standards for Lifeline-supported services will increase each year.

Effective December 1, 2017, the updated minimum service standards are:

  • Mobile broadband (data):  1 GB per month of 3G mobile technology
  • Mobile voice:  750 minutes per month
  • Fixed (home) broadband:  15/2 Mbps
    • There’s an exception if the service provider doesn’t 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/1 Mbps.
  • Fixed (home) broadband:  250 GB of usage per month
  • Fixed (home) voice:  No minimum service standard

Service providers must meet the minimum service standard for the service to which the Lifeline support is applied.
If the consumer’s receiving a bundled service, the service providers should apply the Lifeline support to one of the services in the bundle. Only the service the Lifeline support is applied to must meet the minimum standard.

When the National Lifeline Eligibility Verifier (National Verifier) launches in a state, all service providers in that state will be required to use USAC-provided versions of the consumer-facing Lifeline program forms:  the certification (application) form, one-per-household worksheet and recertification form. USAC will release more details about the National Verifier, including the first states to join, technology specifications and training plan. Most training is planned for October and early November. Note that some states may have temporary exemptions to these processes if state-sponsored aid programs are still being used.

If you have any questions regarding Lifeline services, contact your BKD telecommunications regulatory consultant.

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