FCC Orders Review of Lifeline Programs; NY May Need to Improve

In an Order released on May 4th, 2010 the FCC directed the Federal-State Joint Board on Universal Service to review the federal eligibility, verification, and outreach rules for the Lifeline and Link-Up phone service affordability programs. Specifically, the Joint Board was asked to recommend any changes to the Lifeline and Link-Up programs that may be necessary, “given significant technological and marketplace changes since the current rules were adopted.” They were asked to consider:

(1) The combination of federal and state rules that govern which customers are eligible to receive discounts through the Lifeline and Link-Up programs. Currently there are different criteria in each state, depending on whether the state has implemented its own Lifeline program. The FCC questioned whether there should be automatic enrollment in each state and whether the existing income eligibility criteria (135% of the federal poverty guidelines) continues to make sense. Additionally, the Joint Board was asked to examine the verification process currently employed by the providers to discern whether improvements are needed or whether there should be uniformity among the states.

(2) Best practices among states for effective and efficient verification of customer eligibility, both at initial customer sign-up and periodically thereafter. The FCC is seeking information on best practices at the state level, specifically related to consumer eligibility. The Joint Board was asked whether any of these best practices should be applicable at the federal level. In addition, the Joint Board was asked to report on whether any states support broadband services through their low income programs. Further, the Joint Board was asked to investigate whether there have been issues with applicants making duplicate claims for Lifeline support (that is, receiving Lifeline simultaneously from a landline provider and a wireless provider).

(3) The appropriateness of various outreach and enrollment programs. Currently, there are no specific national guidelines for the types of outreach required by the Lifeline providers to promote customer awareness of the service. The Joint Board was directed to examine whether there should be specific, enforceable outreach requirements for all Lifeline providers.

(4) The potential expansion of the low income program to include broadband, as recommended in the National Broadband Plan. Finally, the Joint Board was requested to examine how its responses would be impacted by the expansion of the Lifeline program to broadband.

The Joint Board’s Recommended Decision on these issues is due within six months.

PULP welcomes this examination by the FCC. As we have reported on numerous occasions, the number of Lifeline customers in New York State served by local exchange carriers is less than half its peak in 1996 and too many eligible New Yorkers are not even familiar with Lifeline’s existence.

See Lifeline Awareness Week Begins Monday – Is There Anything for New York to Celebrate?, and Low-Income Telephone Lifeline Assistance Reaches Fewer than 300,000 New Yorkers, Lowest in 20 Years.

Meanwhile, TracFone wireless has single-handedly matched the Lifeline customer total in New York served by the regulated carriers -- all in about a year of offering the service -- but has fought to be removed from some of the Eligible Telecommunications Carrier obligations it agreed to back in 2008.

However, the state Office of Temporary and Disability Assistance reports that there are over 1.3 million households in New York receiving Food Stamps , meaning that merely half of the Lifeline eligible households are enrolled in the service. Will the Joint Board’s recommendations spur the state to do more than maintain the status quo? PULP remains cautiously optimistic.

In addition, PULP has advocated for the expansion of the Lifeline program to include broadband access. This is one of the key elements of our pending application for a broadband stimulus grant, arguing that unless accessing the service is affordable for all, the millions spent on deployment may go to waste. Expanding Lifeline without eliminating the current support for voice service while not overburdening the fund will be a difficult balance to strike, but one essential to achieve.

Lou Manuta