COMPTEL and NTCA said in separate FCC filings that the regulator should work to alleviate service providers from the burden of having to verify Lifeline service recipients.
One of the issues COMPTEL raises on the Lifeline program is foregoing an electronic signature requirement for recipients.
"To better serve the Commission's universal service mandate and ensure that the Lifeline program reaches as many eligible beneficiaries as possible, the Commission must refrain from implementing enhanced requirements for electronic signatures," COMPTEL said in a filing. "In this proceeding, COMPTEL has argued that any proposal to modernize or increase the efficient administration of the Lifeline program must "ensure that low-income Americans have the same opportunities to participate in the digital economy as other citizens."
The organization agrees with the joint commenters that consumers understand the legal validity of consenting in an electronic format by clicking an "I ACCEPT" button. Joint commenters said by requiring additional safeguards would be "unnecessary, burdensome and ultimately harmful to Lifeline subscribers because such a change would fail to treat them like non-low-income consumers interacting with the digital economy."
Instead of implementing new requirements, COMPTEL said that the Lifeline program "already provides the necessary safeguards to demonstrate that current and proposed low-income subscribers are providing valid electronic signatures and that ETCs' document retention policies meet the Commission's goal of preventing waste, fraud and abuse."
Taking it a step further, NTCA says the FCC should not require service providers -- particularly smaller rural telcos that have limited staff -- to have to oversee the Lifeline eligibility approval process.
"For NTCA members, with an average of 25 total employees, the burden is particularly acute," NTCA said in an FCC filing. "The eligibility verification process consumes an inordinate amount of resources, including training staff to keep up with constantly changing Lifeline eligibility procedures."
NTCA added that having to comply with new "document retention rules will require additional staff training at the outset, in addition to additional staff resources on a continuing basis and IT system upgrades necessary to properly protect Lifeline subscribers' private information."
In its initial comments, NTCA said the FCC should create a coordinated enrollment process that would use existing federal benefit programs that already qualify low-income consumers for Lifeline benefits. With this approach, NTCA said that a consumer that applies for and is approved for "state-administered federal benefits program intended for low-income Americans would be enrolled in the Lifeline mechanism."
Upon being approved for one of the federal benefits programs, a consumer would be given information on the benefits of enrolling in the Lifeline program with the choice to enroll. When it gets approval for the qualifying program, the state administrator would add the subscriber's name to the National Lifeline Accountability Database (NLAD) database and if the customer indicates that he or she has service with an existing service provider, then the carrier will be notified.
For more:
- see the COMPTEL filing (PDF)
- see the NTCA filing (PDF)
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