FCC Planned Lifeline National Verifier Launch in 6 States Concerns Providers, NARUC Official

"Lack of a service provider API renders online enrollment virtually impossible -- shutting off the best way of reaching consumers in rural America," emailed National Lifeline Association counsel John Heitmann of Kelley Drye. "Lack of adequate database access in some states threatens to make it very hard for existing Lifeline subscribers to retain service," he said. "Immediate action is needed" to ensure the NV "helps consumers rather than harms them by making it too difficult for [them] to enroll and stay enrolled in Lifeline," he said, adding Universal Service Administrative Co.'s reverification requirements "place undue burdens on consumers."

The FCC Tuesday announced a hard launch mandating NV use by Nov. 2 in Colorado, Mississippi, Montana, New Mexico, Utah and Wyoming (see 1810020064). It didn't address two popular pending petitions: Q-Link Wireless asked the FCC to ensure the NV implements APIs to allow machine-to-machine communications by Lifeline eligible telecom carriers (ETCs), including when consumers seek to enroll (see 1808130034); and TracFone asked the agency to direct USAC to expedite efforts to obtain automated access to databases, such as Medicaid's, for determining Lifeline eligibility, or postpone the NV's hard launch (see 1808310041 and 1809140018).

“It is unfortunate that the FCC is cutting off online Lifeline signups through carriers for over 2 million low income Americans" in the six states, said Q Link CEO Issa Asad in a statement. He said an API "to allow online enrollment via carriers would be a win-win, policing against fraud, reducing administrative costs, and continuing to allow consumers to signup online with carrier assistance.”

Launching the NV without an interface "seems inefficient and unnecessarily complicates the online application process for qualified applicants," said Paul Kjellander, NARUC telecom committee chair and Idaho Public Utilities Commission president, in a statement. He noted a July NARUC resolution urging the FCC to require appropriate electronic interfaces (see 1807180018). The agency "should make the needed changes before the verifier is rolled out in other states,“ he said.

The top priority is to ensure the NV "is stood up as quickly as" envisioned in 2016 "and is receiving the information it needs to make reliable eligibility decisions," emailed an FCC spokesperson. "When the National Verifier is fully launched, consumers will have many options for verifying their eligibility, including by filing a paper form, through a consumer web portal, or through a provider service portal. Nonetheless, we are open to working with stakeholders to create a secure API in the future so long as doing so would not undermine the integrity of the National Verifier and the Commission’s intent to take the eligibility verification process out of the hands of carriers.” The FCC says carrier oversight of eligibility encouraged abuses. USAC didn't comment.

"USTelecom supports the launch of the Lifeline National Verifier program because it will speed access to consumers for vital broadband service, while reducing unnecessary administrative burdens that have challenged the program in the past," emailed the group. It opposed TracFone's petition.

Some officials in the six states spoke positively about a current soft launch that allowed but didn't require NV use. "I have heard of no problems during the soft roll-out and USAC has been very responsive to all questions our staff had," emailed Montana Public Service Commissioner Travis Kavulla. "We are not aware of any significant issues in Colorado with the soft launch ... and look forward to the hard launch," emailed Terry Bote, Colorado PUC spokesman.

Nebraska PSC Commissioner Crystal Rhoades urged the FCC to resolve the concerns raised by Q Link and TracFone, by "work around" solutions if necessary. "In 3 out of the 6 states" participating in the NV soft launch, "the state databases did not include Medicaid recipients," which is a big problem because "Medicaid recipients account for 29% of all Lifeline enrollment," said her letter, posted in docket 17-287 Tuesday.

A two-step verification process and the lack of an API creates headaches for consumers, said Judson Hill, adviser to TruConnect and Sage Telecom. "The subscriber must learn and self-navigate the eligibility verification process without agent assistance before then repeating the same process with a carrier who must collect the same information and again verify eligibility before they enroll the subscriber," said his filing posted Friday on a meeting with aides to Chairman Ajit Pai and Commissioner Brendan Carr. "Many otherwise eligible people may now find the new verification process too challenging and not enroll."

"Not having an API is nuts, but it sure is an effective way to slow down ETCs and consumers, and shift money to other USF programs," said Danielle Frappier of Davis Wright, who represents some Lifeline providers. Delays in implementing national eligibility and accountability databases show "the complexities in verifying consumers’ eligibility for Lifeline, and underscore that those complexities are much more difficult than the political rhetoric surrounding the program would suggest," she told us.