Be Aware of Lifeline Changes

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The federal Lifeline program continues to evolve. The Federal Communications Commission’s (FCC) 2016 Modernization Order, released December 1, 2016, ushers in changes that will become effective over the next five years. These changes have been established to continue helping all Americans get and stay digitally connected, while also relieving some of the burden on carriers providing this service. Here are some of the changes:

  • Eligibility streamlining – The number of benefit programs subscribers may use to qualify for Lifeline has changed.
  • The National Lifeline Eligibility Verifier (National Verifier) and rolling recertification – Once the National Verifier has been established to verify Lifeline recipients, all subscribers must be recertified from the subscriber’s enrollment date. For subscribers enrolled prior to January 1, 2017, rolling recertification requirements will begin July 1, 2017.
  • Broadband and minimum standards – The FCC established initial minimum standards for Lifeline-supported fixed and mobile broadband and mobile voiced services.
  • Hotspot functionality – A phase-in process requires mobile broadband Lifeline providers to offer devices with hotspot functionality to help households connect to the internet.
  • Benefit port freeze – Subject to exceptions, Lifeline providers may not receive reimbursement for service provided to a subscriber who used the Lifeline benefit to enroll in a qualifying Lifeline-supported broadband offering with another Lifeline provider within the designated voice or broadband port freeze window.
  • Lifeline broadband provider – Creates a streamlined, nationwide Lifeline Broadband Provider designation to increase competitive entry by broadband providers, including cable operators and internet service providers.
  • Aggregation projects – In conjunction with the National Verifier, aggregation projects will allow community-based organizations, housing associations and institutions the opportunity to coordinate the aggregation of Lifeline benefits.
  • Usage requirements – Texts will now qualify as usage of a subscriber’s Lifeline service.
  • Non-usage – The non-usage period—primarily applying to prepaid wireless carriers—has been shortened from 60 to 30 days.

The remainder of this article will highlight three of the changes likely to have day-to-day effects.

Eligibility Streamlining

On December 2, 2016, only subscribers or households that qualify for and receive one of these benefits will be eligible for enrollment in Lifeline:

  • Supplemental Nutrition Assistance Program
  • Medicaid
  • Supplemental Security Income
  • Federal Public Housing Assistance
  • Income-based eligibility (at or below 135 percent of the federal poverty guidelines)
  • The Veterans Pension or Survivors Pension benefit

In addition, subscribers at or below 135 percent of the federal poverty guidelines and those who qualified through any of the tribal criteria will continue to be eligible for a Lifeline program benefit. The eligibility changes were made in an effort to increase efficiency and improve the program for subscribers, carriers and other participants.

The FCC eliminated Low Income Home Energy Assistance Program, National School Lunch Program and Temporary Assistance for Needy Families from the default federal assistance eligibility for Lifeline. The FCC also removed state-specified Lifeline eligibility criteria for Lifeline support to permit efficient comprehensive administration of the program.

Some states, including Wisconsin, successfully petitioned the FCC to retain their own lists of state-eligible programs for a limited time.

National Verifier System

Universal Service Administrative Company (USAC) was directed by the FCC to develop a system that could manage the Lifeline subscriber’s verification nationally and to determine all subscriber eligibility in the future. The creation of a National Verifier is to reduce the administrative burden and cost to carriers and determine support, while also facilitating subscriber choice and making enrollment easier. In addition, this process should reduce waste, fraud and abuse. The National Verifier will accept verification information from Lifeline subscribers by phone, email or U.S. Postal Service. Today, this program is offered to eligible telecommunications carriers (ETC) at no cost.

The key functions of the National Verifier include:

  • Determining subscriber eligibility
  • Populating the Lifeline Eligibility Database
  • Allowing access to service providers, subscribers, states and state administrators
  • Calculating support payments

USAC also will partner with states and state administrators, which already have their own eligibility determination databases, to develop and implement the National Verifier in the most effective and efficient manner possible.

Rolling Recertification

All subscribers must be recertified by the subscriber’s anniversary date beginning January 1, 2017. For subscribers enrolled prior to January 1, 2017, the rolling recertification requirements begin July 1, 2017. Subscribers with anniversary dates of January through June don’t need to recertify until 2018. If you aren’t using USAC to verify your Lifeline customers, it’s your responsibility to complete your subscriber’s verification by their anniversary date. Providers should have started the verification process for customers with a July 1 anniversary date on April 27. The same lead time will apply for recertifying Lifeline subscribers with anniversary dates in each subsequent month. Providers in many states will see a benefit of participating in USAC’s National Verifier service, which did not include a charge at the time of this article.

Broadband & Minimum Standards

The Modernization Order outlines changes to Lifeline needed to bridge today’s digital divide. The inclusion of broadband is intended to help connect all Americans to the internet. Beginning December 2, 2016, Lifeline subscribers had the choice (where applicable) of applying their benefit to one of three service offerings:

  • Fixed or mobile broadband
  • Fixed or mobile voice-only (to be phased out by the end of 2021, with the exception of certain areas)
  • Bundles of fixed or mobile voice and broadband

However, subscribers only are allowed one Lifeline benefit per household.

Minimum Service Standards

The minimum standards are to ensure that supported services keep pace with the changing digital ecosystem. These standards will gradually increase through the next five years. The FCC will publish notices on or before July 31 of each year of the minimum standards for the next 12 months.

Some key changes and dates for minimum service standards:

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In the event a fixed broadband provider hasn’t deployed facilities in a service territory capable of meeting the minimum standards in effect for the period, it may receive support for fixed 4/1 Mbps broadband service provided it:

  • Doesn’t offer any generally available residential fixed broadband product that meets the 10/1 Mbps standard
  • Offers a 4/1 or better residential service on a generally available basis

Support Levels Phasedown Schedule

Support for both mobile and fixed voice-only service will gradually decrease through the next five years.

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This phases out the voice-only subsidy beginning in December 2019 and eliminates it by December 2021, except in areas where there’s only one Lifeline provider.

Lifeline benefits only are available to subscribers receiving Lifeline services from a provider that’s an ETC or broadband provider designated by the FCC as a Lifeline Broadband Provider. Eligible subscribers may elect to have their subsidy applied to fixed or wireless standalone telephone, standalone broadband or a bundle including both telephone and broadband. However, a household is limited to one discount for the single option it receives. Lastly, there also are port freeze limitations. With limited exceptions, Lifeline subscribers can’t move their benefit to another provider until their port freeze window has expired.

If you have any questions regarding Lifeline services, contact your BKD advisor.

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