Lifeline National Verifier Rollout Goes on Despite Missing API, Databases

FCC preliminary numbers show about 12 percent ​of Lifeline subscribers de-enrolled in states where the national verifier is reaching final steps in the reverification process. Lifeline providers saw many Lifeline de-enrollments in recent weeks in some of the first states where the NV launched, but carrier application program interface remains unavailable and Universal Service Administrative Co. still lacks access to many state databases or the national Medicaid database, said John Heitmann of Kelley Drye, counsel to the National Lifeline Association. At least 2 million could be de-enrolled due to difficulties verifying, he said.

There has been progress in South Dakota, part of the second batch in the phased verifier launch, said Public Utilities Commissioner Chris Nelson. But other state and consumer groups said they remain uneasy about the pace of the rollout that the FCC and USAC aim to complete this year. The verifier soft-launched in 11 more states June 25 (see 1906180012). USAC didn't comment Monday.

Lack of transparency is "a real problem," FCC Commissioner Jessica Rosenworcel said in a statement to us. "The agency can start by publishing a timeline for updating the range of databases it expects to incorporate in the program and detailing the databases for which it lacks access."

FCC Commissioner Geoffrey Starks also expressed concerns. “No one should be removed from the Lifeline because of problems the FCC has experienced during the rollout and setup," he said. In particular, he added, the NV must be electronically connected to state databases used to establish applicant eligibility. "Applicants in states without this connection are 'failing' the manual eligibility process at an alarming rate," he said, and the NV shouldn't "go live in any state before electronic connections to that state’s eligibility databases are established.”

The FCC doesn’t have final de-enrollment numbers, its spokesperson said Friday. Verification starts with a query of automated data sources available in a given state, he emailed. “If the subscriber’s eligibility cannot be verified through this process, USAC then reviews the documentation the provider has on hand. Finally, the subscriber is given a direct opportunity to submit eligibility documentation if the first two steps fail. If after all these steps are taken, a subscriber’s eligibility cannot be verified, the FCC has an obligation to remove the ineligible subscriber.”

Wireless eligible telecom carriers see de-enrollments in phase one states -- Colorado, Montana, Mississippi, New Mexico, Utah and Wyoming (see USAC map) -- said Heitmann in an interview. Mississippi had more than 10,000 de-enrollments, he said. USAC hasn’t explained why it didn’t wait for the national Medicaid database to be accessible for verification, said the attorney for Lifeline ETCs. “USAC has been working on implementing access to that database for months and it almost certainly could have helped since the National Verifier has no access to Mississippi’s Medicaid database.”

Utility commissions in Mississippi and two other phase one states told us they don’t have Lifeline enrollment numbers to share. They referred us to USAC Lifeline disbursement data on its website. “I do know that USAC has integrated the [Supplemental Nutrition Assistance Program] SNAP, Medicaid, and Federal Housing Data for reverification purposes," and those reverification rates were about 72 percent, New Mexico Public Regulation Commission Telecom Bureau Chief Michael Ripperger emailed. Utah won’t have numbers covering January to June until later this month, said Utah Commerce Department Public Utilities Division's Utility Regulator Shauna Benvegnu-Springer.

Concerns

Stakeholders are concerned about the lack of NV progress.

NARUC remains “concerned that there has been no visible progress on establishing an API -- which should be a relatively easy thing to do, but the NV rollouts by State are continuing,” emailed General Counsel Brad Ramsay. NARUC’s July 2018 resolution sought those interfaces. Lack of APIs could effectively deny access to millions, he said. The association raised that and other concerns in a meeting last week with an aide to Rosenworcel (see 1907050032).

“Once fully implemented,” the NV will make the Lifeline program more efficient and effective for providers and consumers “through automated connections to federal eligibility databases, and streamlined manual review of applications when necessary,” the FCC spokesperson said. “The FCC is actively pursuing these automated connections.” The NV “is critical to reducing the unacceptably high rate of improper payments in the program,” he said.

South Dakota

South Dakota “had very productive dialogue with USAC” on Nelson’s concerns at NARUC’s February meeting about USAC's not accessing SNAP and Medicaid databases in such rural states with fewer Lifeline customers (see 1903080016), the state commissioner emailed.

“USAC has agreed to access our state-held SNAP database to determine eligibility,” Nelson said. “We are currently working through the agreement necessary to move forward with the necessary programming. USAC also indicated that they understood the difficulties we were facing regarding de-enrollments given that we don’t have a viable national verifier operating with our state databases. We have not heard of de-enrollments occurring but can’t guarantee they haven’t happened.”

“The FCC is ready and willing to work with any state that wants to make its databases available” for NV use and “USAC’s work with South Dakota is a case in point,” the FCC spokesperson said.

D.C.

District of Columbia Public Service Commission Chairman Willie Phillips urged better state-federal coordination (see 1904050019), about a month before the NV hard-launched there. The agency “won’t receive Verizon’s quarterly reimbursement request for Economy II (Lifeline) Service until the end of July,” PSC External Affairs Office Director Cary Hinton emailed last week. “However, since USAC has several steps to the verification process before a Lifeline Service customer is identified by USAC to Verizon for disconnection, we don’t expect to have a complete picture” about the NV’s impact on subscribership “until October or November.”

“Under the best-case scenario, the National Verifier will reduce the wait times for approval, because customers will be able to check their eligibility at the same time as enrollment,” emailed a D.C. Office of People’s Counsel spokesperson. But OPC has accessibility concerns, she said. “The program requires the use of machine-to-machine interfaces to verify enrollment, and it remains to be seen whether the National Verifier produces a user-friendly experience for telecom carriers and people of all abilities who choose to enroll themselves.”

OPC raised concerns about defining a household as a group of people who live together and share income and expenses, the spokesperson said. “This can be a difficulty for residents of shelters or other shared facilities, as some residents have been denied service if another resident already has Lifeline." Instructions on applicants’ honesty are “problematic,” because “the new application comes close to pre-emptively accusing Lifeline applicants of being dishonest and may be directing this message to the wrong group,” she said.

“Enrollment processes are designed with accessibility in mind,” the FCC spokesperson said. "USAC has worked hard to test the language used for things like truthfulness, certifications, and the one-per-household worksheet to make them as clear as possible while still complying with the FCC rules.”

National Advocates

Done correctly, a national verifier program could boost competition among providers, said Cheryl Leanza, policy adviser for the United Church of Christ, Office of Communications. “If a consumer is eligible for Lifeline, that consumer can shop with his feet.” Because Lifeline eligibility historically has been established through a provider, benefits tend to remain attached to that company, but now, consumers will understand they can take their subsidy with them in search of better service, she said. Leanza thinks that when run correctly, the NV can attract new companies to participate in the Lifeline program: “We want the program to have integrity.”

Leanza has heard there are limits on people participating in the NV, and that USAC is trying to work through them in two ways. One way is to work at the state level to provide better access to individual state databases like SNAP, she said, though some states are better at collaborating than others. She has heard access to Medicaid databases will move forward at the national level, and her understanding is “we’ll see that soon.”

It can be a challenge for those asked to provide additional data online to prove their eligibility, said Carmen Scurato, Free Press senior policy counsel. “It’s an accessibility issue. People applying for Lifeline may not have internet access at home or nearby.”

Scurato wants USAC and the FCC to be transparent about administrative changes they make to the NV and whenever they plan to offer new ways for consumers to provide evidence of eligibility, she said. USAC webinars helped, she said. “We continue to ask for chances to engage prior to going live” with changes such as an earlier requirement that participants show an expiration date on their SNAP benefits, said Scurato. “We’re asking for open disclosure, not just for us, but those signing people up.”