FCC, USAC Urged to Encourage Lifeline Participation, Not Create New Barriers to Adoption

"Excessive claims of waste, fraud and abuse in the Lifeline program should not be used to police low-income consumers," the National Hispanic Media Coalition said. Some FCC Lifeline program proposals "unfairly target Lifeline recipients instead of bad actor providers," National Urban League said.

The agency should honor its mandate to advance access for Lifeline's intended users, and any new rules should avoid undermining "the preservations and advancements of access to services or their affordability for all low-income consumers," CTIA said. It wants the FCC to "assess the effects of recent reforms," including the national verifier (NV) for eligibility, "before determining whether additional reforms are necessary."

Proposed integrity requirements "would impose additional burdens and costs on [eligible telecommunications carriers] with little to no concomitant benefit to the program," the National Lifeline Association (NaLA) said. Lifeline providers should no longer collect and record the type of proof an applicant uses to demonstrate eligibility now that the NV does so, it said.

USTelecom "has concerns about the number of touchpoints for the gathering of consumer data that could potentially put low income individuals at risk for identity theft due to the sensitive nature of the personal information that is already gathered by state agencies, carriers and [Universal Service Administrative Co.] personnel and maintained for Lifeline eligibility and audit purposes," the group said. USTelecom also called "impractical at best" a proposal to require Lifeline subscribers to contact USAC periodically to verify provider claims that they're using their service on an ongoing basis.

"Surveillance systems established to defend against fraud in government benefit programs have instead become instruments to exert control over economically disadvantaged individuals," the Electronic Privacy Information Center said.

Residents of tribal lands "tend to have a distrust of government institutions and would be reluctant to make contact by phone," Smith Bagley said. The same distrust of government "should also rule out the proposed approach of requiring subscribers to use an app that requires them to confirm continued usage," it said.

The risk of a subscriber abandoning Lifeline service without notifying its ETC is lower among those making regular payments than those with prepaid accounts, GCI Communications said.

'Skin in the Game'

Stakeholders overwhelming opposed requiring ETCs to charge at least a small equipment fee rather than offer free handsets to new subscribers. "This is the latest incarnation of the 'skin in the game' proposals, which mistakenly assume that subscribers only value their Lifeline service to the extent they must pay something to receive it," NaLA said. Such a requirement would make service unaffordable and inaccessible for many, it added.

"Even with a $9.25 monthly service subsidy, the prospect of having to pay out of pocket several hundreds of dollars or more for a [broadband internet access service]-capable smartphone is an entry barrier that makes broadband service an unaffordable luxury to many low-income households," Tracfone Wireless said. Smartphone acquisition costs are lower for providers than consumers because they buy in bulk, it added.

Proposed handset fees "are another unjustified part of a larger war on the poor by the current administration," Free Press said in its comments. A mandatory handset fee "is contrary to the central purpose of universal service," it said.

The FCC "must not adopt reforms that discourage participation" in the Lifeline program, New America's Open Technology Institute said in joint comments with Public Knowledge. A proposal to ask potential subscribers "a litany of questions regarding their financial priorities" should be rejected, they said, because such questions are both intrusive to applicants and unnecessary to administering the program.

"Step back from these proposals and instead allow the Lifeline program some breathing room to settle into the recent dramatic changes to the Lifeline program," the National Consumer Law Center said in joint comments with other low-income consumer advocates.

Since 2017, FCC policies "have strangled Lifeline broadband, once a promising and serious strategy to support low income Internet access, in its cradle," the National Digital Inclusion Alliance said.

NTCA responded to an FCC inquiry on whether the Lifeline program should treat fixed and mobile broadband services differently. It said the FCC should adopt Lifeline goals "of a broadband connection that meets every low-income consumer's individual needs." For example, where "a mobile broadband service is not sufficient to meet a low-income consumer's needs for accessing telemedicine, educational opportunities, or for remote work, the commission should not settle for 'good enough' and declare victory," NTCA said.

Replies are due to the FCC Feb. 25.