USAC Expects More Lifeline Verifier Database Access as FCC Reviews Issues
Universal Service Administrative Co. is working to enhance its Lifeline national verifier (NV) of consumer eligibility, said Michelle Garber, USAC vice president-Lifeline, noting some changes will take time or could require more FCC direction. She acknowledged the NV's lack of greater access to government databases, particularly in less-populated rural states, increased initial verification failure rates, but said access to a key Medicaid national database is coming. "I don't think it's a question of if that'll happen; it's a question of when," she told us recently. "I feel like it'll happen this year."
Meanwhile, USAC is looking to ensure existing eligible subscribers aren't dropped from Lifeline due to system issues in the NV's rollout. After confusion apparently led some providers to de-enroll subscribers who weren't initially reverified in the first six states, USAC clarified Feb. 13 it would carry out all de-enrollments under the NV (see 1902130052). USAC is also doing additional outreach to consumers with "unresolved errors" and opened a 75-day window for providers to submit further documentation through May 15 in those states, said an advisory. It noted the organization is taking "alternative steps" in subsequently launch states. After further documentation is processed, USAC said it "will de-enroll ineligible consumers."
"We want to make sure they have the opportunity" to confirm eligibility, said Garber of low-income users of the government-subsidized phone and broadband services provided by telcos and wireless carriers. She noted some issues are under FCC review.
Although the National Lifeline Association "is heartened" USAC and the FCC "are considering the alarm bells" rung by providers and state regulators about NV database shortcomings, "we still have not learned of any concrete plan to revisit the cost-benefit determinations" that denied access to certain state databases, emailed counsel John Heitmann of Kelley Drye Wednesday. "Nor have we learned of a commitment to do additional pre-deenrollment [checks] against the national Medicaid database and any new state databases that come online."
"Millions of consumers face potential de-enrollment from Lifeline not because they are ineligible but because USAC has made it too difficult for them to prove they are eligible," said Heitmann. He noted the NV still lacks an application program interface to ease carrier assistance to consumers. Lifeline advocates said a further cloud would be lifted if the FCC abandoned a proposed reseller ban. USAC "absolutely" would recheck consumer eligibility if it gets further database access before de-enrollments, said Garber, deferring to the commission on any basic policy changes.
Lawmakers Watching
Lawmakers we spoke with recently noted the high verification failure rates but said they'll need more definitive information before weighing in.
“Getting accurate information is really important,” said Senate Communications Subcommittee Chairman John Thune, R-S.D. “If we can figure out who actually is benefiting from” Lifeline, that will aid future congressional oversight efforts given Capitol Hill concerns about waste and abuse of program funding.
Lifeline is “set up to help people in need and it's our job to do oversight” of USAC's implementation of fixes to the program, said House Commerce Committee ranking member Greg Walden, R-Ore. Congress needs to continue to “scrutinize” how USAC and the FCC are putting fixes to Lifeline into practice, but the focus should continue to be on ensuring there's no longer “broad-based misuse of the program,” said Sen. Shelley Moore Capito, R-W.Va. “I always worry what's going to happen” with the program “in rural communities.” Others didn't comment.
API
Q Link Wireless has "built industry consensus" to respond to regulators' proposal for a possible API, emailed a company spokesperson Wednesday. "This feedback -- which is within the general construct of the FCC and USAC's API proposal -- makes clear that the API solution must enable consumers to get help from service providers in identifying and uploading the required documentation." In states where the NV has fully launched, "new enrollments have come to a crawl as Q Link and other providers cannot efficiently use it without" an API, with rural consumers "disproportionately affected," said the spokesperson, urging the FCC to grant its interim waiver to better help consumers.
Providers want APIs so they don't have to enter consumer information twice, on their own systems and the NV's, Garber said. Some companies have an all-online process and don't want consumers to have to do such dual entry, she added. CTIA, Sprint, TracFone, the FCC and USAC March 11 discussed a possible API that can enable efficient verification, minimize duplication, reduce burdens and safeguard program integrity (see 1903140065). "Industry is united on API," said Davis Wright's Danielle Frappier, who represents some providers. "Like most things Lifeline, [the NV] turns out to be more complicated than anticipated."
NV use is mandatory in 15 states and one territory where it hard launched: Colorado, Mississippi, Montana, New Mexico, Utah and Wyoming on Nov. 2; Hawaii, Idaho, New Hampshire, North Dakota, South Dakota and Guam on Jan. 15; and Missouri, North Carolina, Pennsylvania and Tennessee March 5. More hard launches are expected after soft launches (where NV use is optional and parties can test systems) Feb. 6 in Alaska, American Samoa, Delaware, the District of Columbia, Maine, the Northern Marianas, Rhode Island and the U.S. Virgin Islands, and March 12 in Indiana, Kentucky and Michigan (NV launches here).
The FCC didn't comment Wednesday.
Database Divide
Sprint urges deferring de-enrollments and further NV hard launches until USAC gets more automated access to Medicaid and Supplemental Nutrition Assistance Program (SNAP) databases, given their importance in determining Lifeline applicant eligibility (see 1903190048). Manual processes are "highly problematic" and could lead to "mass de-enrollment" of "otherwise-eligible" consumers, Sprint told the FCC.
An initial average NV reverification rate of about 70 percent drops to "single digits" in some states where it lacks SNAP and Medicaid database access, including Wyoming and Montana, Garber said. For database access by state and other details, see NV launches here, here, here, here and here. Initial verification of new enrollments also ran at about 70 percent. She said some states weren't willing to share data, and automated connections to others couldn't be justified under federally required cost-benefit analysis. USAC data shows Wyoming and Montana had only 1,538 and 4,726 Lifeline subscribers as of December. Garber said access to the national Medicaid database could cover about 60 percent of eligible consumers in all states, and having SNAP access in a state could add another 15 percent coverage, she said. Some cost-benefit decisions "clearly weren't very popular," she said. "I think the FCC is really thinking about that."
The FCC is "more than happy" to work with rural states seeking automated connections to support the NV, Chairman Ajit Pai said at a news conference Friday. Heitmann said that isn't a concrete plan to revisit cost-benefit determinations. Asked about possibly pausing de-enrollments or NV hard launches, Pai said the goal is for all eligible subscribers to "remain in the program" while guarding against waste, fraud and abuse and ensuring dollars go to needy people (see Notebook at end of 1903150067).
While "100 percent automation" isn't likely, the NV is "still way more automated" than the previous verification processes overseen by states and providers, said Garber. "Some states didn't have anything to check." Near term, she said, USAC is studying ways for consumers to show eligibility by combining use of SNAP cards -- which often lack names or expiration dates -- with other documentation. Once the NV completes the verification and reverification processes this time around, annual consumer recertifications should be easier next time, she said.