Recertify Subscribers (FCC Form 555)

Beginning in 2017, service providers must use a new process called "rolling" recertification.

For 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. This means that providers will need to certify their customers' eligibility at different times throughout the year.

There will be a transition period after the current recertification process concludes, and before rolling recertification begins. Some specifics about the process are still under consideration with the FCC; we will update this page once further guidance is available.

2016 Recertification Process

The recertification process for 2016 remains the same as in previous years. For customers that a company claimed on their February 2016 FCC Form 497 that require recertification, follow the recertification process for 2016:

Transition Period

No recertifications for the federal Lifeline benefit are required for anniversary dates that fall from January through June, 2017, as service providers prepare for rolling recertification.

Starting with anniversary dates on July 1, 2017, service providers recertify customers according to their anniversary date. Service providers must initiate rolling recertification at least 65 days before the customer's anniversary date, and must de-enroll the customer by their anniversary date. For the July 1, 2017 anniversaries, service providers must initiate the process by April 27 (65 days before July 1, 2017), and must de-enroll ineligible/non-responsive customers by July 1.

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 rolling recertification process is:

  • Confirm the customer's eligibility using the list of qualifying programs (use the streamlined list, which is effective Dec. 2, 2016).
    • First attempt to verify the customer through a state or federal eligibility database query (if available), or
    • If no database is available, contact the customer for self-recertification at least 65 days before their anniversary date; the customer must respond within 60 days.
  • De-enroll ineligible/non-responsive customers within 5 days after the 60-day response period expires, and by the customer's service initiation anniversary.

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.

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.


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 will still have the option of electing USAC to conduct the annual recertification on their behalf. To accommodate the rolling recertification, USAC anticipates changes to the recertification process beginning in 2017 and is reviewing the following elements of the recertification process:

  • Recertification timeframe
  • Collection of subscriber data

USAC will share more information as it becomes available.

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 ETCs 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.

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. The customer can continue using their Lifeline benefit until their next recertification. If their next recertification is before the new list of eligibility programs takes effect on December 2, 2016, the customer can re-certify using a retiring eligibility program. But if their recertification is on December 2, 2016 or later (i.e., the service provider sends the customer a recertification letter on Dec. 2 or later), ask them to self-certify that they participate in one of the eligibility programs included in the 2016 Modernization Order.

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

A6: Yes. There's flexibility to batch subscribers, but the rules still apply to all anniversary dates within the batch. Further guidance about batching subscribers is under consideration with the FCC; we will update this page once more information is available.

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.

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.