SSN Requirements Hurt Low-Income Populations, CPUC Told

“The SSN requirement adversely impacts vulnerable populations, including migrant families who choose not to enroll in social benefits programs because they fear that supplying a SSN will lead to immigration consequences,” the CPUC’s independent Public Advocates Office commented in docket R.20-02-008. It’s also an obstacle “for people who are unhoused and people recently released from incarceration who face barriers in retrieving their SSN,” said PAO. Applicants should be able to enter “0000” if they lack an SSN, as they do with the affordable connectivity program (ACP), said PAO. Longer term, the commission should adopt the California food stamp program’s approach of asking customers to provide a valid reason for not applying with an SSN, it said. The LifeLine program should accept all government ID documents as well as city ID cards, individual taxpayer identification numbers and consular identification cards, PAO said.

“Otherwise-eligible Californians cannot access essential communications services through California LifeLine because of its SSN requirement,” The Utility Reform Network and the Greenlining Institute said in joint comments. The CPUC can’t depend on ACP to meet those Californians’ needs because the program is winding down, but ACP “is a valuable model for providing program access to consumers without SSNs.”

Industry pointed out that the FCC hasn’t answered a 2015 CPUC petition seeking a waiver for Californians of the federal Lifeline program’s SSN requirement (see 1510190051). Without a waiver, low-income service providers could receive state but not federal reimbursement for a low-income service’s costs. California LifeLine’s minimum service standards assume that the customer receives state and federal program assistance, the National Lifeline Association commented: The CPUC can’t force California LifeLine providers to offer the same service level without the $9.25 federal portion of the subsidy. So, the state agency should require California LifeLine to replace the lost federal support, NaLA said. T-Mobile’s Assurance Wireless, AT&T and Cox agreed in separate comments.

Assurance asked if the CPUC would mandate all LifeLine providers verify and possibly enroll applicants without an SSN, or if that would be optional. “If the Commission is envisioning a mandatory shift in which LifeLine providers will be required to enroll applicants without a valid SSN, Assurance cautions the Commission to reconsider its approach.” Non-SSN forms of identification are less accurate and take more time to verify, it warned. “If LifeLine providers are not allowed to obtain SSNs from applicants, there could be a dramatic increase in fraudulent activity.” The CPUC should give liability waivers to companies and "hold them harmless from all fines and penalties” arising from a requirement to enroll LifeLine applicants without SSNs, Assurance said.

Requiring SSNs is “an important program integrity measure” that should continue, though NaLA acknowledged there are people without SSNs who are eligible for other California assistance programs and need help affording communications. The CPUC should “ensure that applications that do not collect an SSN are the exception rather than the rule and obtain an alternative form of identity verification that is processed by the LifeLine Administrator.” That’s how it works with ACP, NaLA said. Give providers a “safe harbor” for customers without SSNs who later are determined ineligible, it added.

A group of advocates for low-income individuals supported supplementing California LifeLine to cover the federal portion. Also, the CPUC should expand the list of accepted ID documents, said Neighborhood Legal Services of Los Angeles County, the Legal Aid Association of California, Homeless Action Center and Maternal and Child Health Access.

But small rural local exchange carriers “are skeptical that now is the right time to move forward with this proposal,” commented CalTel and other small telcos. They noted that the CPUC’s 2015 waiver petition at the FCC is pending, ACP could soon run out of funding and federal Lifeline support for voice might end. Also, the CPUC has low-income pilot programs pending and is considering changing LifeLine's support amounts (see 2401250051). If the CPUC continues, “it should ensure that it is done in a clear, orderly, and targeted manner to avoid customer confusion and minimize impacts on the LifeLine fund,” the RLEC group said.