WCB Takes Additional Steps To Eliminate Duplicative Lifeline Claims
Federal Communications Commission
News Media Information 202 / 418-0500
445 12th St., S.W.
Washington, D.C. 20554
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
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
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
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).
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
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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