National Verifier May Be Reducing Lifeline Enrollments in Kentucky, Say LECs

Kentucky Lifeline subscribers may be decreasing partly due to the FCC and Universal Service Administrative Co.’s Lifeline national verifier rollout, said a group of RLECs and CLECs. They commented Wednesday in docket 2016-00059 at the Kentucky Public Service Commission about possible changes to state Lifeline support. Kentucky should expand state Lifeline support to include mobile service, revisiting a 2017 decision to limit it to landline carriers with declining enrollments, wireless companies said.

Since standardized eligibility verification replaced local verification, the carriers “have seen a lower response rate among their Lifeline customers, which has resulted in many customers failing to qualify for Lifeline support,” they said. “Based on feedback provided by potential Lifeline-eligible customers, the Exchange Carriers believe it is possible many Lifeline eligible customers have been intimidated by the enhanced USAC recertification process, including the transition to the Lifeline National Eligibility Verifier, which has led to them failing to submit the required information and losing their Lifeline eligibility.” The primarily online NV “has, anecdotally, proven difficult for the Exchange Carriers to successfully navigate and nearly impossible for potential subscribers to navigate, as it requires such customers to scan and upload documents -- capabilities non-existent to most of these customers,” they said. USAC’s increased effort to ensure eligibility “has led to many Lifeline customers being removed from the program as they were deemed ineligible to participate primarily due to duplicate credits per household, in contravention of the regulations governing the Lifeline program.”

“The soft launch of the National Eligibility Verifier in Kentucky was on March 12, and the hard launch, a little more than a week ago, on June 11," an FCC spokesperson responded. "The system relieves burdens on both Lifeline consumers and providers in Kentucky because it has automated eligibility connections for Medicaid, SNAP, and Federal Public Housing Assistance, which is more than almost any other state where the verifier has launched. Given that improper payments in the program are still high, it’s critical that we move ahead in Kentucky and other states with this system to reduce waste, fraud, and abuse in the program while we work to improve it as needed." USAC didn’t comment.

The landline subscriber decline “reflects an overall nationwide trend in favor of wireless communications services over landline, and a nationwide decline in the Lifeline program due to regulatory restrictions and neglect,” said Telrite and Stand Up Wireless. Consumers “view the portability and convenience of wireless service not as a luxury, but as a necessity," commented TruConnect. Limiting support to landline violates Section 254(f) of the Communications Act … because such a restriction would be inconsistent with the federal universal service program which allows wireless and wireline carriers to participate,” TracFone said.

The RLECs and CLECs cited “ongoing demand for landline-only services among certain groups of customers, despite prevailing national or even state trends.” If the PSC determines Kentucky USF should continue to support only voice, landline carriers don't object to expanding the fund to wireless voice, but don’t want expansion to “undermine a broader concern for helping offset the eventual elimination of federal Lifeline assistance for the primarily elderly and rural Kentuckians who receive voice-only services,” they said. Unless the PSC increases support, in two years “the only support for these voice-only subscribers will be limited to the $3.50 in KUSF support,” the carriers said.