Industry Broadly Supportive of National Lifeline Database
Eligible Telecommunications Carriers should have their Lifeline customers re-certify their own eligibility for the program, TracFone said in comments posted to dockets 11-42, 96-45 and 03-109. But mandating minimum monthly charges for Lifeline customers “would do nothing to prevent waste, fraud and abuse” and only “make Lifeline service unaffordable to millions of low-income households who are intended to benefit from the program.” TracFone has heavy Lifeline customers and has been singled out as one of the wireless companies that are driving pay phone companies out of business (CD Jan 20 p9), especially in states like Florida. The company reiterated its argument that the Lifeline fund shouldn’t be capped. It also convened a meeting with Chairman Julius Genachowski and aide Zac Katz late last week to press TracFone’s case, according to an ex parte notice released Wednesday.
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CTIA agreed with TracFone on minimum charges but picked up AT&T’s proposal for a centralized national database to check Lifeline eligibility. CTIA also took aim at suggestions of “one per residence” rules, which CTIA said would force companies to “face significant difficulty … because of its complexity and its reliance on information ETCs are not best suited to collect and evaluate.” AT&T said the one-per-household rules is “contrary to sound public policy.”
Verizon, too, joined calls for a centralized database. But it also reiterated its calls for a voucher-style program. “With beneficiaries empowered to make service selections using a voucher with a pre-set value that can only be used once, claim duplication -- a substantial focus of fraud and abuse today -- would be largely avoided,” Verizon said in its reply comments. “Absent such a program, a personal identification number (PIN) system of the type proposed by AT&T makes sense, because it would enable real-time enrollment in and certification of eligibility for Lifeline, automate the annual Lifeline verification process (used to determine continued eligibility for those already enrolled in the program), and streamline the USAC-provided reimbursement process for Lifeline discounts."
In its reply comments, CompTel said it “was gratifying to see the strong support expressed in the development and implementation of a national database.” Both CompTel and the National ALEC Association/Prepaid Communications Association warned the commission away from eliminating reimbursement for toll limitation service in Lifeline.
But the National Association of State Utility Consumer Advocates warned the FCC not to be distracted by industry. “There appears to be consensus only on two lofty principles: that low-income persons should be assisted in their need for telecommunications services, and that measures to limit waste, fraud and abuse in an assistance program are important,” NASUCA said. “Beyond those general principles, there is little agreement among the industry or among regulators as to how the principles should be implemented. And, unfortunately, there is far too much of a typical theme that runs through the industry comments: ‘Help me … and whether or not you help me, please don’t help my competitors!'” Part of the problem comes from a lack of real data, NASUCA said. There is little direct evidence, for instance, of widespread “duplicative claims” in the Lifeline program beyond a single Mississippi Public Utilities staff report that found “hundreds of customers were claiming Lifeline subscriptions from as many as three ETCs.” NASUCA said the report was “not entirely helpful."
Lobbyists for pay phone companies made another pitch for Lifeline funds to help save their industry. In comments posted to the dockets, the American Public Communications Council said the commission “must not fail to consider the opportunity presented by the existing base of payphones across the country and the need to preserve that national asset as a core component of providing universal service.” A single wireline phone “can provide access to communications to a single household, and a single wireless phone can provide access to a single user, a single payphone can provide access to a nearly unlimited number of users,” the Council said in its comments. “Thus, support for payphone lines can have very real efficiencies as compared to the other forms of providing Lifeline support.”