Wednesday, August 05, 2009

Lifeline Awareness Week Coming in September; Will it Make a Difference?

The week of September 14th through September 20th will be "National Lifeline Awareness Week," coordinated by the FCC Federal/State Working Group on Lifeline and Link-Up (of which PULP is one of two consumer advocate members), along with the National Association of Regulatory Utility Commissioners the National Association of State Utility Consumer Advocates. Whether the effort will help stem the tide of systematic neglect which has limited effectiveness of the Lifeline Program in New York State remains to be seen.

According to materials being drafted for the special week, the purpose of Lifeline Awareness Week is to ensure that eligible low income households are aware of the Lifeline and Link-Up programs and to help them afford basic local telephone service in their homes through assistance from these programs. Proclamations from governors are expected, as are media campaigns sponsored by the state utility commissions, and possibly outreach efforts by the Lifeline telephone service providers themselves. Reports of parades in major cities and leafleting dropped from bi-wing aircraft may be premature.

The New York State Public Service Commission (“PSC”) has taken a vocal, lead role in the Lifeline Awareness Week preparations. This is to its credit at the national level, but the PSC's past performance leaves much to be desired. Back in 2007, for example, an estimated quarter of a million dollars was spent on a Lifeline awareness marketing campaign by the PSC, with flyers and handbills distributed around the state, even as the number of Lifeline customers actually continued its precipitous decline. Also, while there is an automatic enrollment program in place that should easily make discounted telephone service available to more than one million New York households, fewer than one-third of readily identifiable eligible customers are getting the reduced price service. With automatic enrollment, names of people on public assistance are shared by the state Office of Temporary and Disability Assistance (“OTDA”) with Verizon, to be cross-matched with its Lifeline enrollment list. Many people on public assistance who approach PULP for help, for example with electric or gas bills, have never even heard of Lifeline discount telephone service and they are not receiving the benefit which should be reaching them efficiently without the added expense of individual signup and application.

There may be various reasons for the failure of automatic enrollment to automatically enroll eligible Lifeline customers, such as poor cross-matching records and the fact that Verizon has lost upwards of half its access lines in the past dozen years so there are less potential Lifeline customers to reach by working through a single company, but the bottom line is that it does not work. With over 1.2 million households in New York State on Food Stamps and barely 300,000 Lifeline customers around the state, the system is not working. Irrefutably . . . not . . . working.

The drop in Lifeline customers from over 750,000 in 1996 to where we are today is costing New Yorkers hundreds of millions of dollars in federal Universal Service Fund dollars collected from New York phone customers and paid to the Universal Service Administrative Company only to be disbursed to benefit customers in other states that do a better job than New York of enrolling their eligible Lifeline customers. California, with roughly the same number of Food Stamp recipients as New York, has seven times the number of customers benefiting from Lifeline telephone assistance. In contrast to California, one can look but cannot find a clear policy statement from the New York PSC to the effect that every person eligible for Lifeline rate assistance should be getting it.

While PULP is wholeheartedly in favor of conducting a National Lifeline Awareness Week – and is the state’s most vocal Lifeline proponent – we have absolutely no expectations that the number of Lifeline customers will increase as a result. Rather, the focus on writing speeches for governors and individual signups unnecessarily suggests that the problem is with those eligible who need more exhortation, and it may divert attention and resources from actions which may actually improve Lifeline subscribership, such as
  • fixing automatic enrollment,
  • breaking down policy barriers that inhibit the provision of the assistance to those whose phone service is provided by a cable company,
  • eliminating tariff barriers which bar Lifeline to customers whose local phone service is included in a bundled package of local and long distance service
The automatic matching mechanism needs to be examined and improved and more entities need to be included other than Verizon if we are truly to bring Lifeline to all who are eligible. The appropriate agencies (PSC, OTDA) need to become “aware” of Lifeline and the burden should be on the Lifeline providers to improve their notification to customers of the availability of the discounted service. Making the general public “aware” of Lifeline and placing the onus on a million of them to sign up one by one, only to learn that there are policy or tariff barriers to their receiving the benefit when they try to apply, is perhaps the most inefficient mechanism to make this work. Indeed, those who respond to the next PR blitz only to bump into the same old barriers are likely to tell their friends and families not to bother. More of the same -- "outreach," trumpet blasts, advertising campaings and PSC proclamations -- without new regulatory and policy insight, is likely not to expand Lifeline enrollment to where it should be.

Lou Manuta

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