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WCB Takes Additional Steps To Eliminate Duplicative Lifeline Claims

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Released: August 25, 2014
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PUBLIC NOTICE

Federal Communications Commission

News Media Information 202 / 418-0500

445 12th St., S.W.

Internet: http://www.fcc.gov

Washington, D.C. 20554

TTY: 1-888-835-5322

DA 14-1234

Released: August 25, 2014

WIRELINE COMPETITION BUREAU TAKES ADDITIONAL STEPS TO ELIMINATE

DUPLICATIVE CLAIMS FOR LIFELINE SUPPORT

WC Docket No. 11-42

By this Public Notice, the Wireline Competition Bureau (Bureau) announces the process for

resolving inter-company household duplicate subscribers found during the National Lifeline

Accountability Database (NLAD) loading process.1 Additional information about this process is

available on the website of the Universal Service Administrative Company (USAC), administrator of the

federal universal service fund (Fund).2

In the Lifeline Reform Order, the Commission codified the rule that subscribers may only have

one Lifeline-supported service per household, and it established the NLAD to detect and prevent

duplicative support in the Lifeline program.3 The Commission directed the Bureau and USAC to work

with eligible telecommunications carriers (ETCs) to implement a process for resolving duplicative

support provided by multiple ETCs to the same household (inter-company household duplicates).4

In September 2013, the Bureau directed USAC to develop a process to eliminate inter-company

household duplicates prior to the deployment of the NLAD.5 Pursuant to that directive, USAC worked

with select ETCs in Michigan to test a process that resolved inter-company household duplicates.6

Similar to the in-depth data validations (IDV) process,7 USAC first mailed letters to subscribers who were

1 See Lifeline and Link Up Reform and Modernization et al., WC Docket No. 11-42 et al., Report and Order and

Further Notice of Proposed Rulemaking, 27 FCC Rcd 6656, 6747-49, paras. 210-16 (2012) (Lifeline Reform Order).

2 See USAC, Duplicate Resolution, http://www.usac.org/li/tools/nlad/nlad-duplicate-resolution.aspx (last visited

Aug. 25, 2014).

3 See Lifeline Reform Order, 27 FCC Rcd at 6687, para. 69, 6734, para. 179; 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).

4 See Lifeline Reform Order, 27 FCC Rcd at 6747, para. 211.

5 See Letter from Julie A. Veach, Chief, Wireline Competition Bureau, FCC, to D. Scott Barash, Acting CEO,

USAC, WC Docket No. 11-42, 28 FCC Rcd 13003 (Wireline Comp. Bur. 2013) (September Guidance Letter).

6 Nexus, AT&T, TracFone and Virgin Mobile participated in this initiative.

7 In June 2011, the Bureau directed USAC to conduct state-specific IDVs to detect and eliminate duplicative

Lifeline support. See Letter from Sharon E. Gillett, Chief, Wireline Competition Bureau, FCC, to D. Scott Barash,

Acting CEO, USAC, WC Docket. No. 11-42 et al., 26 FCC Rcd 16457 (Wireline Comp. Bur. 2011); Letter from

Sharon E. Gillett, Chief, Wireline Competition Bureau, FCC, to D. Scott Barash, Acting CEO, USAC, WC Docket

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living at an address where another Lifeline subscriber also resided and directed all subscribers at the

address to complete a one-per-household worksheet (household worksheet).8 The Bureau tested two

options for subscribers to respond to the USAC letter. Subscribers could provide responses to their ETC

or directly to USAC.9 USAC resolved the inter-company household duplicates as directed in the

September Guidance Letter.10

Consistent with the Lifeline Reform Order, and as part of our continuing effort to resolve

duplicative claims for Lifeline support, we now approve the following process summarized in this Public

Notice and detailed on USAC’s website to resolve inter-company household duplicates identified during

the NLAD loading process.11

USAC will provide each ETC with a list of its subscribers with inter-company household

duplicates.

ETCs must communicate with their subscribers, informing them of the one per household

obligation, explain the eligibility requirements for qualifying as a household, and attempt

to obtain a household worksheet from those subscribers who meet those requirements. 12

The ETCs’ communications with the subscriber must meet the requirements of the

Lifeline Reform Order. USAC has posted a template subscriber letter and household

worksheet on its website that meets these requirements.13

Those subscribers who do not complete a valid household worksheet and return the

worksheet to their ETC must be de-enrolled from the Lifeline program and the NLAD by

their ETC, as contemplated by sections 54.405 and 54.410 of the Commission’s rules.14

Nos. 11-42, 03-109, CC Docket No. 96-45, 26 FCC Rcd 8588 (Wireline Comp. Bur. 2011) (June Guidance Letter).

The IDV process saved the Lifeline program more than $269 million.

8 See Lifeline Reform Order, 27 FCC Rcd at 6747, para. 211; see also June Guidance Letter, 26 FCC Rcd at 8591.

9 See September Guidance Letter, 28 FCC Rcd at 13004.

10 See id. at 13005-08 (describing various scenarios that could result after the USAC letter was mailed to

subscribers).

11 In the Lifeline Reform Order, the Commission directed USAC to develop and implement a process subject to

Bureau approval for resolving inter-company duplicates once the NLAD was populated. See Lifeline Reform Order,

27 FCC Rcd at 6749, para. 215. Such process would take effect immediately upon Bureau approval. See id.

12 We direct ETCs, rather than USAC, to communicate with Lifeline subscribers because subscribers are more likely

to respond to inquiries made by their own service provider. Having the ETCs, and not USAC, reach out to

subscribers is also consistent with the proposals of several ETCs. Indeed, some ETCs have already reached out to

obtain household worksheets from subscribers identified as residing at the same address during the NLAD loading

process. See, e.g., Letter from Tiffany West Smink, Century Link, WC Docket No. 11-42 (June 30, 2014). See also

Letter from John J. Heitmann, Counsel to Telrite Corporation, i-wireless LLC, Boomerang Wireless, LLC, Global

Connection Inc. of America and Blue Jay Wireless, LLC, WC Docket No. 11-42 (Dec. 5, 2013); Letter from John J.

Heitmann and Danielle Frappier, to Marlene Dortch, Secretary, FCC, WC Docket No. 11-42 (May 9, 2014).

Recognizing that the goal behind Lifeline is to give some of the neediest members of our society affordable access

to vital communications services, we expect that ETCs will not count their outreach efforts to resolve the household

duplicate issue, in the form of minutes/texts to subscribers, against the minutes currently allotted to their subscribers.

13 ETCs are not required to use the specific template subscriber letter and household worksheet posted on USAC’s

website. However, all subscriber communications sent by ETCs to resolve inter-company household duplicates

must convey to the subscriber, in substance, the information contained in the template letter and provide the

necessary guidance for the subscriber to determine if they are a separate household from any others receiving a

Lifeline-supported service at that address. The specific requirements for communication and the template letter and

worksheet can be found on USAC’s website. See USAC, Duplicate Resolution,

http://www.usac.org/li/tools/nlad/nlad-duplicate-resolution.aspx (last visited Aug. 25, 2014).

14 See 47 C.F.R. §§ 54.405(e)(2), 54.410(d)(3)(vi).

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This process will be performed under the following timeline:

ETCs have from the release date of this Public Notice until December 23, 2014, to obtain a valid

household worksheet from any subscribers identified by USAC as inter-company duplicates.

ETCs MUST de-enroll any subscriber who fails to provide a valid household worksheet by

December 30, 2014.

ETCs MUST update the NLAD regarding the status of all subscribers on their USAC-provided

list by December 31, 2014 (i.e., ETCs must enter de-enrollment dates into the NLAD for those

subscribers who fail to provide a valid household worksheet and also check the Independent

Economic Household (IEH) flag for those subscribers who do provide a valid household

worksheet).

USAC must de-enroll by January 1, 2015 any subscriber listed in the NLAD as an inter-

company household duplicate who has not been de-enrolled or who has not been enrolled into the

NLAD using the IEH flag.

This timeline is consistent with the timeline for the recertification requirements for the Lifeline

program.15 This will be efficient for ETCs and minimize subscriber confusion.

For further information, please contact Anita Patankar-Stoll, Telecommunications Access Policy

Division, Wireline Competition Bureau at (202) 418-7400 or TTY (202) 418-0484.

– FCC –

15 See 47 C.F.R. § 54.410(f).

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