Broad Support for Using Lifeline Requirements in Emergency Broadband Fund

“Adopt flexible rules” and “avoid unnecessarily complicated requirements that would slow implementation,” Verizon told Wireline Bureau staff and an aide to Democratic Commissioner Geoffrey Starks. It suggested Universal Service Administrative Co. modify its national verifier consumer portal to let applicants specify whether they’re applying for Lifeline services, the emergency broadband program or both, and automatically qualify all existing Lifeline customers rather than require them to reapply for the emergency benefit. Leverage E-rate program data to confirm eligibility, GCI recommended. Also identify schools where all students are eligible for free or reduced meals, and preload those schools into the national verifier, GCI said.

Require participating carriers to provide “adequate information,” including monthly broadband rates, to the states where they provide services, NARUC said: Lifeline broadband standards could work here. Implement the program “in a way that does not lose the advantage of state involvement,” because states are a “watchdog to catch bad actors,” the California Public Utilities Commission urged. Cherokee Nation asked that its citizens be automatically enrolled based on data acquired by the tribe when providing services and not need to apply for Lifeline and emergency broadband services twice. The Navajo Nation Telecommunications Regulatory Commission warned use of the NV and other Lifeline certification requirements will “spell disaster,” because the FCC has “already admitted that the National Verifier cannot work during the time of a pandemic.”

Consider allowing noneligible telecom carriers to opt into the program without additional requirements, said several providers. The National Lifeline Association suggested ETCs enrolled in Lifeline are “automatically qualified” to participate in the new program. Give non-ETCs access to the national verifier and other databases integral to program participation, Comcast asked. “Avoid applying burdensome Lifeline rules” and adopt an expedited process for verifying providers’ eligibility, NCTA said. Charter endorsed NCTA’s comments and emphasized that non-ETCs should be allowed to access the verifier: Otherwise, "their customers will not be able to receive the benefit.”

Integrate non-ETCs “on the same timeline as other providers,” suggest ACA Connects. Providers are watching to see whether Lifeline providers get a “head start” and “consuming the program’s limited funds,” ACA wrote. Incompas agreed and urged the commission to begin educating non-ETCs now about how to use the NV and Lifeline claims system.

T-Mobile disagreed, saying the commission should generally avoid applying Lifeline rules to the new program because of the “tremendous burdens” associated with it. Instead, it said to follow the Lifeline payment quality assurance program without Lifeline audit rules. Require non-ETCs get approval before they can participate and establish an expedited, seven-day approval process, AT&T urged.

Several advocacy groups asked the FCC to engage in cross-agency collaboration to enroll eligible households. Alternatives for determining eligibility could include those eligible for Medicaid, the supplemental nutrition assistance program and federal public housing assistance, said the Benton Institute for Broadband & Society. Work with the Agriculture and Education departments for data matching to verify eligibility, Public Knowledge urged: “Data matching will relieve consumers of the burden of uploading documentation they may not have easy access to, through a portal they may not understand.” Altice supported cross-agency collaboration for alternative means for verifying program participants’ eligibility, including provider verification of Pell Grants and other federal assistance.