Attempts at Lifeline Enrollment Expansion Face Challenges, Opportunities

Industry, policymakers and consumer advocates are seeking new ways to expand Lifeline enrollment and benefits in response to the public health and economic crisis, we're told. Some advocates are pursuing emergency funding to provide a more robust residential broadband Lifeline benefit to meet the demands of working and learning at home. Stay-at-home orders put restraints on Lifeline promotion and enrollment.

“During this critical time, we need more outreach by all parties to tell those who need the service what it is and how they can get it,” said National Regulatory Research Institute Telecom Principal Sherry Lichtenberg. Stay-at-home orders make signing up even trickier for those without home internet, she said: “You can’t even go to a friend’s house” to do so.

Universal Service Administrative Co. employees continue "to work with states, consumer groups, and social service agencies to help connect eligible consumers to Lifeline Program support," a spokesperson emailed.

Lifeline providers are essential workers during the pandemic, said Lifeline attorney John Heitmann of Kelley Drye. It's harder to meet potential new enrollees face to face because the social services offices and bus depots where providers had set up tents aren't open now. Some suggest promoting in front of supermarkets, he has heard. The volume of new enrollments is down tremendously, but it's not shut down completely, he said.

TruConnect encourages new enrollees to sign up online, said CEO Nathan Johnson. "We go through the national verifier program and mail the phone out in a matter of days." He said the model works, "and in the pandemic we're in, it works very well." TruConnect wants more focus on Lifeline's value during a crisis. The company is developing a telehealth app for Lifeline customers, he said.

Heitmann credited the FCC for waiving de-enrollment rules during the pandemic. It's hard to produce manual eligibility documentation because social service agencies are closed. Non-usage can also trigger Lifeline de-enrollment, but there are reasons one might not use phone service for 30 days, he said. Some Lifeline subscribers can't get a signal on remote tribal lands and use mobile service only when they go to work. "You don't want to burn through your battery trying to get a signal when there's not one," he said. If a device is broken during a pandemic, "you can't go to the store to fix it," he added. And someone hospitalized for 30 days with COVID-19 shouldn't have to worry about having lost phone service after leaving the hospital, he said.

Lifeline advocates want Congress to allocate emergency appropriations for broadband for those affected by COVID-19. The National Digital Inclusion Alliance and a working group of other advocates, ISPs and industry associations plan to ask Congress for an emergency Lifeline subsidy for home-based broadband, NDIA Executive Director Angela Siefer said. The working group is "still early days," she said, and not yet a formal coalition. NDIA drafted a letter it plans to send Congress Monday, and may propose that Congress appropriate new emergency funding and not USF money. "I suspect nobody would want to call it Lifeline," Siefer said, since Lifeline isn't universally loved. But it's recognized as the existing mechanism that can distribute the connectivity subsidy quickly, and has a national verifier to check eligibility online. "We'd have to figure out how to widen eligibility to the newly unemployed" and not yet eligible for Lifeline under another qualifying program such as the Supplemental Nutrition Assistance Program (SNAP).

The National Hispanic Media Coalition signed the NDIA letter asking for emergency broadband funding from Congress, said Strategic Policy Adviser Daiquiri Ryan. "The tricky part is how do we accurately measure the income levels" to see who's eligible, she said: "Many people filed their taxes earlier this year and have since had a change in income."

Others have similar goals for emergency Lifeline support outside the NDIA working group. "We're all looking at how to get Lifeline to more people and a bigger benefit to more people," Heitmann said. He would like subsidies to support unlimited voice and more data. "COVID-19 is a good time to decide what's the right subsidy, what's the right service, and if there's enough competition in the market," he said.

USTelecom asked the FCC to suspend its prohibition on duplicative Lifeline support so families following stay-at-home orders could have multiple connections for students and working adults. In a March 27 filing in docket 11-42, it also asked for a temporary emergency Lifeline subsidy to those unemployed and gig workers not receiving a paycheck due to COVID-19.

State Struggles

“One of the struggles that we’re really having right now is helping people who are newly unemployed and finding themselves in situations that they’ve never been in before,” Nebraska Public Service Commissioner Crystal Rhoades said. There’s not widespread knowledge about Lifeline, and educating people about available services is “incredibly difficult to do when you don’t have the internet, and you’re in a pandemic, and you’re being told to go home and stay there.” The Nebraska PSC and Lifeline providers are thinking through how best to increase awareness, she said.

Philadelphia will soon make grants to three or four organizations to create "Digital Navigators,” remote case workers who by phone or text-based chat can help people get connected to the internet by highlighting affordable options including Lifeline, said Andrew Buss, the city’s deputy chief information officer-Office of Innovation and Technology (OIT). Working on an accelerated time frame, the city announced the grants April 20 and plans to decide by Friday, he said.

Unlike with unemployment benefits, Lifeline awareness is likely low among city residents not previously in the social service system, said OIT Digital Inclusion Fellow Juliet Fink Yates. Providers and all levels of government should do outreach, she said. The officials said their sense anecdotally is that most Philadelphians use the one-per-household discount for mobile phones rather than home internet. “But that’s challenging because mobile Internet use is more limiting than that offered with other larger screen devices,” said Buss.

Buss estimated 20-30% of Philadelphians lack internet access at home, with the number much higher in some neighborhoods. The income-based broadband gap has “never been as clear as day as it is right now,” said Fink Yates. Without internet, it’s hard to do banking, telehealth, online learning and job searching, she said. People used to be able to go to libraries and public computing centers for access, but those places are closed, she said. That could make applying for Lifeline difficult, she noted: “You have to copy and scan all these documents that verify that you are eligible, and there's no place for folks to do that.”

“Because of the recent COVID-19 emergency, more consumers whose incomes have been reduced may now be eligible to qualify for this program,” said Pennsylvania Public Utility Commission Chairman Gladys Brown Dutrieuille April 15. To increase Lifeline awareness, the PUC is working with state legislators, county public assistance offices and Pennsylvania departments, a PUC spokesperson emailed Thursday. The agency’s “education and outreach specialists are in regular contact with hundreds of community-based human service organizations across the state” to update them on Lifeline and other programs that could help vulnerable people, he said. The PUC participates in Lifeline awareness programs and promotes the availability in consumer education programs, social media and its website including on a COVID-19 page, he said.

The California Public Utilities Commission is contacting utility customers about low-income telecom benefits through news releases, social media, its website and community-based organizations, said a CPUC spokesperson, highlighting a search tool for affordable internet plans.

Several federal programs automatically enable a person to get Lifeline, with SNAP “most likely to now be reaching households where someone is suddenly unemployed,” the Pennsylvania PUC spokesperson said. Pennsylvanians who apply for qualifying low-income programs administered by the state’s Human Services Department are provided information about Lifeline, and eligible telecommunications carriers are required to notify customers about the program’s availability at least twice a year through bill inserts, he said. Customers without computer access can call USAC via an 800-number and request a paper form be mailed, he said.

FCC Commissioner Geoffrey Starks wants the agency to sign memos of understanding with the federal agencies that offer social services that make participants eligible for Lifeline. That's to have them promote the telecom subsidy, he told NTCA. "We’re always open to suggestions on how to continue to improve the program and FCC staff will take the Commissioner’s comments into account," an FCC spokesperson said Friday. Commissioner Brendan Carr told reporters Thursday it makes sense, and the FCC already works with the Department of Health and Human Services on the new telehealth program. "As this virus places new strains on our economy and households across the country, we need to double down on our efforts to make sure no one is left behind when it comes to communications," said FCC Commissioner Jessica Rosenworcel in a statement. "This includes making it easier for families in need by getting the word out about programs like Lifeline.”