Lifeline

Recertify Subscribers (FCC Form 555)

Beginning in 2017, service providers must recertify their customers’ eligibility on a rolling basis. In "rolling recertification,” service providers must verify each customers' eligibility to receive a Lifeline benefit by the anniversary of the service initiation date of their Lifeline-supported service.

There is a transition period in early 2017; no recertifications are required for customers whose anniversary dates fall in the first half of 2017. At the end of the year, service providers must report the recertification results using FCC Form 555, which is due January 31 each year.

See below for the rolling recertification process, sample schedules, the sample letter and the sample form. Requirements vary by state due to select eligibility program waivers. Learn more in the FCC’s Public Notice: Guidance on Rolling Recertification which was released on October 27, 2016.

Transition Period for Rolling Recertification

No recertifications for the federal Lifeline benefit are required for anniversary dates that fall from January through June2017.

Service providers must recertify customers on a rolling basis starting with anniversary dates of July 1, 2017. Service providers should initiate rolling recertification at least ~65 days before the customer’s anniversary date, and must recertify or de-enroll customers by their anniversary date. For the July 1, 2017 anniversaries, service providers should initiate the process by April 27 (65 days before July 1, 2017), and must de-enroll ineligible/non-responsive customers by July 1 (see sample schedules below).

Because of the transition period, the amount of time since a customer’s last recertification will vary (see scenarios). Note that customers enrolled in January – June of any year, including 2016, do not need to be recertified until 2018.

Rolling Recertification Process

Starting with anniversary dates on July 1, 2017, service providers recertify all subscribers according to their anniversary date. The entire process (including de-enrollment) must be completed by the customer’s anniversary date.

The rolling recertification process is:

  1. First, attempt to verify the customer’s eligibility through a state or federal eligibility database query (if available). If no database is available, proceed to step #2.
    • Service providers are responsible for determining eligibility, even when using a state’s database. Please confirm the state is in compliance with the streamlined eligibility criteria as of December 2, 2016.
    • If the database verifies the customer’s eligibility, no further action is required.
    • If the database cannot verify the customer’s eligibility, proceed to step #2.
  2. Contact the customer to confirm their continued eligibility for the Lifeline Program, and to complete the required certifications.
    • Contact the customer no more than 150 days before their anniversary date.
    • The recertification process takes a minimum of ~65 days.
    • A sample subscriber letter  and recertification form   are available for reference.
    • Use the updated list of qualifying programs (effective Dec. 2, 2016), unless the customer resides in a waiver state. In waiver states, you must include otherwise-retired programs.
    • Service providers are permitted to batch customers into groups by anniversary date. If you use batching, make each part of the process is compliant for every customer in the batch. USAC recommends using one- or two-month batches.
    • Follow all requirements for the letter and form, including obtaining a signature and that the notification must be in writing separate from the bill. See the Lifeline Program Rules, Sections 54.405(e) and 54.410(f), for details.
  3. Allow 60 days for the customer to respond.
    • Optional: Send reminders to customers via mail, phone, or SMS.
  4. De-enroll failed and non-responsive customers.
    • De-enroll customers from your internal company systems within five (5) business days after the 60-day response period expires, and by the customer’s anniversary date.
    • De-enroll customers from NLAD within one (1) business day after you de-enroll the customer from your internal company systems, and by the customer’s anniversary date.
    • Optional: Notify customers of their pending de-enrollment from the Lifeline benefit.
  5. No further action is required for successfully-recertified customers.
  6. The entire process must be completed by the customer’s anniversary date.
    • If you are recertifying in batches, make sure the process is complete on time for every customer in the batch.

If you need assistance, contact us via LI Verifications.

Sample Recertification Schedules

Sample Schedule 1 (Recommended)
This schedule begins well in advance and groups the anniversary dates into one-month batches. Here, the company sends a recertification letter approximately three (3) months before the anniversary date, allows a 60-day response period, has a full five (5) business days to de-enroll failed subscribers from their internal systems, and ends ~20 days before the deadline (the first anniversary date in the batch).

Batch Schedule: July Anniversaries
Subscriber anniversaries: July 1 – July 31
1. Verify eligibility using state database (if available): 3/20/17
2. Send initial notice to subscribers: 4/2/2017
3. 60-day response window: 4/2 – 5/31/17
4a. De-enroll failed subscribers from internal company systems: 6/7/17
4b. De-enroll failed Lifeline subscribers from NLAD: 6/8/17
Complete the recertification process for subscribers in this batch by: 7/1/17

Batch Schedule: August Anniversaries 
Subscriber anniversaries: August 1 – August 31
1. Verify eligibility using state database (if available): 4/20/17
2. Send initial notice to subscribers: 5/2/ 2017
3. 60-day response window: 5/2 – 6/30/17
4a. De-enroll failed subscribers from internal company systems: 7/10/17
4b. De-enroll failed Lifeline subscribers from NLAD: 7/11/17
Complete the recertification process for subscribers in this batch by: 8/1/17

Sample Schedule 2 (Meets Minimum Requirements)
This schedule shows the latest timing possible that groups the anniversary dates into one-month batches and still complies with all of the program’s rules. Here, the company sends a recertification letter 65 days before the anniversary date, and the five-day period to de-enroll customers from their internal system (and one day for NLAD) is cut short so the company can complete the de-enrollments before the deadline (the first anniversary date in the batch).

Batch Schedule: July Anniversaries
Subscriber anniversaries: July 1 – July 31
1. Verify eligibility using state database (if available): 4/27/17
2. Send initial notice to subscribers: 4/28/2017
3. 60-day response window: 4/28 – 6/26/17
4a. De-enroll failed subscribers from internal company systems: 6/30/17
4b. De-enroll failed Lifeline subscribers from NLAD: 6/30/17
Complete the recertification process for subscribers in this batch by: 7/1/17

Batch Schedule: August Anniversaries 
Subscriber anniversaries: August 1 – August 31
1. Verify eligibility using state database (if available): 5/28/17
2. Send initial notice to subscribers: 5/29/17
3. 60-day response window: 5/29 – 7/27/17
4a. De-enroll failed subscribers from internal company systems: 7/31/17
4b. De-enroll failed Lifeline subscribers from NLAD: 7/31/17
Complete the recertification process for subscribers in this batch by: 8/1/17

Report Results on FCC Form 555

FCC Form 555 is the "Annual Lifeline Eligible Telecommunications Carrier Certification Form." The form reports the results of the annual rolling recertification process and includes data accuracy certifications. Service providers must submit one form per SAC participating in the Lifeline Program.

FCC Form 555 is due on January 31 each year (if January 31 falls on a Federal holiday or weekend, the form will be due on the next business day). Carriers must also file a copy of their FCC Form 555 in the FCC's Electronic Comment Filing System, Docket 14-171, and with their state regulatory commission.

Visit the Lifeline Program Forms page to view and submit the form. Single-form entry and bulk upload are both available.

Rolling Recertification Terms

Anniversary Date
The "anniversary date" is every 12 months from the customer's service initiation date, or the date when their eligibility was last verified (see scenarios #5 and #6 below).

Service providers must recertify Lifeline customers' eligibility by their anniversary date each year.

Service Initiation Date
The "service initiation date" is the date the ETC begins providing the Lifeline-supported service to the customer.

Eligibility Database Query
The service provider (or other entity responsible for recertifying subscribers) must query any existing state or federal eligibility database to which it has access before it attempts to recertify subscribers using other means. If the query confirms ongoing eligibility, renew the service. If it does not, the service provider may contact the customer directly. Service providers are responsible for ensuring the state’s verification process/eligibility database is in compliance with the streamlined eligibility criteria that went into effect on December 2.

60-Day Response Window
If the service provider cannot confirm continued eligibility from the database query, the subscriber must be allowed 60 days to respond to recertification efforts. After the 60-day period expires, service providers must de-enroll ineligible/non-responsive subscribers within five business days.

Scenarios

These are some scenarios that may occur depending on when a subscriber is enrolled and when rolling recertification starts:

Show All

 
Scenario 1: Legacy Subscriber; Service initiation date: March 2015
  • 2016 recertification: Recertify or de-enroll by December 31, 2016
  • 2017 recertification: None
  • 2018 recertification: March 2018 (rolling)
Scenario 2: Legacy Subscriber; Service initiation date: August 2016
  • 2016 recertification: None
  • 2017 recertification: August 2017 (rolling)
  • 2018 recertification: August 2018 (rolling)
Scenario 3: Legacy Subscriber; Service initiation date: December 2016
  • 2016 recertification: None
  • 2017 recertification: December 2017 (rolling)
  • 2018 recertification: December 2018 (rolling)
Scenario 4: New Subscriber; Service initiation date: March 2017
  • 2017 recertification: None
  • 2018 recertification: March 2018 (rolling)
Scenario 5: Anniversary Date if Changed Service Initiation Date during Enrollment
  • Voice service initiation date: July 1, 2017 (eligibility validated at enrollment)
  • Switch to broadband service: October 1, 2017, eligibility not validated
  • Anniversary Date: July 1
Scenario 6: Anniversary Date if Interrupted Service during Enrollment
  • Broadband service initiation date: July 1, 2017 (eligibility validated at enrollment)
  • De-enrollment due to non-usage: October 1, 2017
  • Customer re-enrolls in the broadband service: November 1, 2017, eligibility is validated
  • Anniversary Date: November 1
  • Note: For the purposes of the port freeze, the relevant service initiation date continues to be July 1, 2017
 

USAC-Elected Recertification

Carriers have the option of electing USAC to conduct the annual recertification process on their behalf. Elections for 2017 were due December 15, 2016. Enrollment for 2018 elections will open in the late summer or early fall.

Frequently Asked Questions – Rolling Recertification

Show All Answers

 
Q1: In paragraph 418 of the Order it says, "Beginning July 1, 2017, all subscribers enrolled prior to January 1, 2017, will need to be recertified on a rolling basis based on the subscriber's service initiation date." If an ETC recertifies 100% of its eligible base before July 2017, can it roll out the new process after that date?

A1: No. Subscribers must be recertified on the anniversary of their service initiation date beginning with service anniversaries on July 1, 2017. The transition period from January 1 to July 1, 2017, is meant to give service providers time to prepare for rolling recertification.

Q2: With rolling recertification, does a subscriber that enrolls on June 15, 2016, need to be recertified by the end of 2017?

A2: No. The first time the subscriber needs to be recertified is June 15, 2018. Customers who initiate Lifeline-supported service in January-June 2016 do not need to be recertified until their service initiation anniversary in 2018.

Q3: What does "service initiation date" refer to: the date that the customer initiated telephone service or the date that the customer enrolled in Lifeline?

A3: It is the date the service provider begins providing Lifeline-supported service to the subscriber.

Q5: If a subscriber enrolled using a retiring eligibility program, are they still eligible until their next recertification? And how can the carrier recertify them going forward?

A5: Yes. Customers that enrolled prior to December 2, 2016, using a retiring eligibility program can continue using their Lifeline benefit until their next recertification. Beginning with rolling recertifications in 2017, carriers should use the new eligibility programs (except for subscribers who reside in waiver states).

Q6: Can service providers batch rolling recertifications by month or quarter?

A6: Yes, there's flexibility to batch subscribers. If you use batching, make each part of the process is compliant with the rules for every customer in the batch. USAC recommends using one- or two-month batches.

Q7: If a state commission is responsible for recertification, and has additional eligibility criteria for its own low income telephone assistance program, will it continue to play a role in recertification for federal Lifeline?

A7: Yes. States can still choose to conduct their own recertifications for the federal Lifeline program until the National Verifier is in place. In conducting the recertification for federal Lifeline support, states must use the federal eligibility criteria for recertifications that start on December 2, 2016 (unless they were granted a waiver).

Q8: For existing customers, when should we use the "old" recertification process (based on the February FCC Form 497), and when should we use the new "rolling" process?

A8: For subscribers enrolled prior to 1/1/2016, use the "old" recertification process for their 2016 recertification. Existing customers that signed up in 2016 will have their first recertification in 2017. For 2017 and future recertifications, use the "rolling" process. Note that because of the "transition period," customers whose 2017 anniversary date falls in January – June skip 2017 recertification, and begin rolling recertification in 2018.

Q9: How does rolling recertification affect the FCC Form 555 filing?

A9: There are no changes for the 2016 FCC Form 555 filing (due January 31, 2017). The FCC and USAC are currently reviewing the FCC Form 555 filing for 2017, and are likely to recommend changes. We will share more information when it becomes available.

Q10: When does the customer need to recertify each year: Their birthday, or activation date?

A10: The anniversary date service providers need to use starting with the 2017 recertifications is every 12 months after the Lifeline subscriber's service initiation date. Not their birthday.