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Lifeline Household Duplicates Pilot Program Guidance Letter

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Released: September 11, 2013
Federal Communications Commission
Washington, D.C. 20554
September 11, 2013
D. Scott Barash
DA 13-1881
Acting Chief Executive Officer
Universal Service Administrative Company
2000 L St., N.W., Suite 200
Washington, DC 20036
Dear Mr. Barash:
In June 2011, the Federal Communications Commission (Commission) and the Wireline Competition
Bureau (Bureau) directed the Universal Service Administrative Company (USAC) to conduct state-
specific in-depth data validations (IDVs) to detect and eliminate duplicative Lifeline support.1 To date,
the IDV process has focused on detecting and eliminating duplicative Lifeline support to individuals and
has saved the program more than $200 million. In January 2012, the Commission codified the rule that
subscribers may only have one Lifeline supported service per household2 and directed the Bureau and
USAC to work with ETCs to facilitate a process for resolving duplicative support being provided by
multiple ETCs to the same household (inter-company household duplicates).3 This letter directs USAC to
develop a pilot to test and develop a permanent process to eliminate inter-company household duplicates
prior to the deployment of the National Lifeline Accountability Database (Database). The results of the
pilot will be used to help design a process for scrubbing inter-company household duplicates from ETCs’
subscriber rolls prior to loading subscriber information into the Database.4
Consistent with the Lifeline Reform Order, we direct USAC to work with select ETCs in Michigan to
determine the best process for resolving inter-company household duplicates.5 In particular, USAC shall
trial two options for collecting and reviewing subscriber responses, testing the same number of addresses
and subscribers with each option.6 Under both options, consistent with the existing IDV process, USAC
shall mail a letter notifying each duplicative subscriber that the subscriber has been identified as someone

1 See Lifeline and Link Up Reform and Modernization et al., Report and Order and Further Notice of Proposed
Rulemaking, WC Docket Nos. 11-42 et al., CC Docket. No. 96-45, 27 FCC Rcd 6656 (2012) (Lifeline Reform Order
or Order); Letter from Sharon E. Gillett, Federal Communications Commission, to D. Scott Barash, Universal
Service Administrative Company (USAC), WC Docket. No. 11-42 et al., DA 11-1986 (2011) (December Guidance
Letter
); Letter from Sharon E. Gillett, Chief, Wireline Competition Bureau, Federal Communications Commission,
to D. Scott Barash, Universal Service Administrative Company (USAC), WC Docket Nos. 11-42, 03-109, CC
Docket No. 96-45, DA 11-1082 (Wireline Comp. Bur. Jun. 21, 2011) (June Guidance Letter).
2 See id. at 6687, para. 69; 47 C.F.R. § 54.409(c). A household is defined as “any individual or group of individuals
who are living at the same address as one economic unit.” 47 C.F.R. § 54.400(h).
3 See Lifeline Reform Order, 27 FCC Rcd at 6747, para. 211.
4 ETC subscriber lists must be “scrubbed” of individual and household duplicates prior to loading the subscriber lists
into the database. See id. at 6748-49, paras. 214-16.
5 Michigan was selected for the pilot because USAC has recently completed an IDV in that state and Nexus, AT&T,
TracFone and Virgin Mobile, all Lifeline providers, offer service in Michigan and have volunteered to participate in
the pilot.
6 USAC will trial the two options below with 500 addresses and 1000 subscribers each.

living at an address where another Lifeline subscriber resides and shall require each such subscriber to
complete a one-per-household worksheet (Worksheet).7 Under the first option, subscribers will provide
completed worksheets and responses to their ETC; under the second option, subscribers will provide
responses to USAC using an Integrated Voice Response system.8 USAC will resolve the inter-company
household duplicates according to the scenarios in the attached Appendix (“Process to Resolve Inter-
Company Household Duplicates”). We direct USAC to report the results to the Bureau.
Option 1: Subscribers Provide Information Directly to ETCs
Under this option, the USAC notification letter directs subscribers to submit the completed Worksheet to
the ETC, via a method (e.g., U.S. Mail address) chosen by the ETC. Subscribers will have 35 days to
provide a response to the ETC. After the end of the 35-day response period, the ETC will provide USAC
with a list indicating whether each subscriber resides in a single household, multiple households, or did
not respond to the letter. USAC will resolve the duplicates based on the results of the subscriber
responses.
Option 2: Require Subscribers to Contact USAC Call Center
Under this option, the USAC notification letter directs subscribers to call into a USAC Interactive Voice
Response (IVR) system within 35 days. The IVR system will ask the subscriber to respond to a series of
questions in order to determine whether there is a single or multiple households at the address. The IVR
system questions correspond to the questions on the Worksheet. USAC will also place a call no later than
10 days from the end of the 35-day period to remind subscribers that have not yet responded that they
must call the USAC number. USAC will resolve the duplicates based on the results of the subscriber
responses.
If you have any questions regarding this letter, please let me know.
Sincerely,
Julie A. Veach
Chief
Wireline Competition Bureau

7 See Lifeline Reform Order, 27 FCC Rcd at 6747, para. 211. The letter will notify each subscriber that he or she
must respond to the letter by 35 days after the date of the letter. See June Guidance Letter at 4.
8 See Attachment A for Option 1 letter from consumers to ETC; Attachment B for Option 2 letter from consumers
from USAC.
2

APPENDIX

Process To Resolve Inter-Company Household Duplicates

9
Outcome 1: None of the subscribers residing at the same address responds to the letter from USAC. (See
chart below)
USAC Response: Randomly select one ETC to be the Lifeline Service Provider for that household
address. After the Lifeline Service provider is selected, the ETCs not selected as the Lifeline Service
Provider would de-enroll their subscribers. For example, USAC would instruct ETC A and ETC C to de-
enroll their subscribers. (See chart below)

Name

Address

Telephone Number

ETC

Response

Allocation

James Smith
123 Main
202-999-9999
A
No
De-enroll
Street
response
Jane Doe
123 Main
202-777-7777
B
No
Lifeline Service
Street
response
Provider
Suzy Jones
123 Main
202-888-8888
C
No
De-enroll
Street
response
Outcome 2: One of the subscribers residing at the same address responds that there is a single household
at the address; other subscribers residing at the same address do not respond.
USAC Action: Direct the ETCs serving the subscribers who did not respond to de-enroll those
subscribers. (See chart below)

Name

Address

Telephone Number

ETC

Response

Allocation

James Smith
123 Main
202-999-9999
A
Single
Lifeline Service
Street
Household
Provider
Jane Doe
123 Main
202-777-7777
B
No
De-enroll
Street
response
Suzy Jones
123 Main
202-888-8888
C
No
De-enroll
Street
response

9 The Bureau and USAC worked with ETCs to develop these scenarios consistent with the Commission’s directive
in the Lifeline Reform Order to work with ETCs to facilitate a process for resolving duplicative support being
provided by multiple ETCs to the same household. See supra note 3.
3

Outcome 3: One of the subscribers residing at the same address responds that there are multiple
households at the address; other subscribers at the same address do not respond.
USAC Response: Do not instruct any of the ETCs to de-enroll any of these subscribers. (See chart
below)

Name

Address

Telephone

ETC Response

Allocation

Number

James
123 Main
202-999-9999
A
Multiple
Continue
Smith
Street
Households
Enrollment
Jane Doe
123 Main
202-777-7777
B
No response
Continue
Street
Enrollment
Suzy Jones
123 Main
202-888-8888
C
No response
Continue
Street
Enrollment
Outcome 4: Two or more subscribers residing at the same address respond that there are multiple
households at the address.
USAC Response: Do not instruct any of the ETCs to de-enroll any of these subscribers.

Name

Address

Telephone

ETC Response

Allocation

Number

James
123 Main
202-999-9999
A
Multiple
Continue
Smith
Street
Households
Enrollment
Jane Doe
123 Main
202-777-7777
B
Multiple
Continue
Street
Households
Enrollment
Suzy Jones
123 Main
202-888-8888
C
No response
Continue
Street
Enrollment
4

Outcome 5: All subscribers residing at the same address respond that there is a single household at the
address.
USAC Response: USAC sends a second letter to the subscribers at the address explaining that two or
more individuals at this address have responded that they are part of a “single household” and the
household is entitled to a single benefit. The letter will state that a member of the household must call in
to the given telephone number and make a selection within 15 days of the letter or the household will be
randomly assigned ETC [A] and the services of ETCs [B and C] will be automatically discontinued. The
household will be assigned the ETC of the first subscriber that calls in. USAC will direct the non-
selected ETCs to de-enroll their subscribers. (See chart below.)

Name

Address

Telephone

ETC

Response

Allocation

Number

James Smith 123 Main Street
202-999-9999
A
Single
Lifeline
Household
Service
Provider
Jane Doe
123 Main Street
202-777-7777
B
Single
De-enroll
Household
Suzy Jones
123 Main Street
202-888-8888
C
Single
De-enroll
Household
Outcome 6: Two or more subscribers residing at the same address respond that there is a single
household at the address; other subscribers at the same address do not respond.
USAC Response: Similar to Outcome 5 above; USAC sends a second letter to subscribers at the address
who responded that they are a “single household” explaining that two or more individuals at this address
have responded that they are part of a single household. The letter will state that a member of the
household must call in to the given telephone number and make a selection within 15 days of the letter or
the household will be assigned ETC [A] and the services of ETCs [B and C] will be automatically
discontinued. The household will be assigned the ETC of the first subscriber that calls in. USAC will
direct the non-selected ETCs to de-enroll their customers. (See chart below.)

Name

Address

Telephone

ETC

Response

Allocation

Number

James Smith 123 Main Street
202-999-9999
A
Single
Lifeline
Household
Service
Provider
Jane Doe
123 Main Street
202-777-7777
B
Single
De-enroll
Household
Suzy Jones
123 Main Street
202-888-8888
C
No Response
De-enroll
Outcome 7: One of the subscribers residing at the same address responds that there is a single household
at the address; another subscriber responds that there are multiple households at the address.
5

USAC Response: Do not instruct any of the ETCs to de-enroll any of these Lifeline subscribers.

Name

Address

Telephone

ETC

Response

Allocation

Number

James Smith 123 Main Street
202-999-9999
A
Single
Continue
Household
Enrollment
Jane Doe
123 Main Street
202-777-7777
B
Multiple
Continue
Households
Enrollment
Suzy Jones
123 Main Street
202-888-8888
C
No response
Continue
Enrollment
For All Outcomes:
All ETCs will continue to provide Lifeline-supported service to subscribers until notified by USAC,
pursuant to section 54.405 of the Commission’s rules, as amended, to de-enroll certain subscribers, and
shall be reimbursed for the Lifeline benefits provided to subscribers up until the date of de-enrollment,
subject to normal adjustments, recoveries for bad, uncorrected data, intra-company, and other reporting
requirements. USAC shall recover support for any subscriber for which subscriber data cannot be
substantiated by the ETC.
6

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