Eligible telecommunications carriers (ETCs) must confirm a consumer's eligibility prior to enrolling the consumer in the Lifeline Program. Regardless of the method an ETC uses to confirm an applicant's eligibility for Lifeline Program-supported service (querying a database, receiving confirmation from a state agency, or reviewing a consumer's documentation) the carrier is required to retain certain records.
In each instance, carriers should note whether the program beneficiary is the applicant or a member of the applicant's family. If the applicant is enrolling based on the eligibility of a family member, the ETC should confirm in writing that the beneficiary named on the documentation (award letter, voucher, etc.) is a member of the applicant's household, and that the named beneficiary is not receiving program-supported service.
Carriers must not retain copies of applicant's personal documentation that is viewed to validate eligibility. Instead, ETCs must keep accurate records that provide details about how each consumer demonstrated his or her eligibility. Carriers should be sure their records sufficiently document the type of record relied on to verify eligibility. Carriers can use the following checklist to establish procedures that comply with the FCC's rules.
- Retain a completed application for each applicant that contains the following information from the prospective subscriber (see 47 C.F.R. Section 54.410(d)(2)-(3)):
- The subscriber's full name;
- The subscriber's full residential address;
- Whether the subscriber's residential address is permanent or temporary;
- The subscriber's billing address, if different from the subscriber's residential address;
- The subscriber's date of birth;
- The last four digits of the subscriber's Social Security Number, or the subscriber's Tribal Identification Number, if the subscriber is a member of a Tribal nation and does not have a Social Security Number;
- If the subscriber is seeking to qualify under the program-based criteria – the name of the qualifying assistance program from which the subscriber, his or her dependent, or his or her household receives benefits;
- If the subscriber is seeking to qualify under the income-based criteria – the number of individuals in his or her household; and
- A certification, under penalty of perjury, that:
- The subscriber meets the income-based or program-based criteria for receiving program-supported service;
- The subscriber will notify the carrier within 30 days if for any reason he or she no longer satisfies the criteria for eligibility. If the subscriber no longer meets the income-based or program-based criteria, the subscriber is receiving more than one benefit, or another member of the subscriber's household is receiving program-supported service);
- The subscriber is seeking to qualify as an eligible resident of Tribal lands, he or she lives on Tribal lands;
- The subscriber moves to a new address, he or she will provide that address to the ETC within 30 days;
- The subscriber provided a temporary residential address to the ETC, he or she will be required to verify his or her temporary residential address every 90 days;
- The subscriber's household will receive only one program-supported service and, to the best of his or her knowledge, the subscriber's household is not already receiving a program-supported service;
- The information contained in the subscriber's certification is true and correct to the best of his or her knowledge;
- The subscriber acknowledges that providing false or fraudulent information to receive benefits is punishable by law; and
- The subscriber acknowledges that the subscriber may be required to re-certify his or her continued eligibility at any time. The subscriber's failure to re-certify as to his or her continued eligibility will result in de-enrollment and the termination of the subscriber's benefits.
Proof of Eligibility Verification
- If the ETC relied on a state or federal social service or income database to determine an applicant's eligibility for the Lifeline Program, the ETC must retain the following records:
- The name of the database queried;
- The date the database was queried; and
- A copy of the confirmation received or a screen-shot of the page confirming eligibility (if available), or a confirmation by the ETC's employee or agent that the database confirmed eligibility.
- If the ETC relied on a state agency to determine an applicant's eligibility, the ETC must retain the following records:
- The name of the agency and contact person consulted;
- The date the confirmation of eligibility was received; and
- A copy of the notice provided by the agency that confirms eligibility.
- If the ETC relied on documentation received from the applicant (such as an award letter, voucher, benefits card, or income statement) to determine the applicant's eligibility (whether based on income or program participation), the ETC must record the following information:
Per FCC Rules, an ETC may not retain any documentation provided by a consumer to demonstrate his or her eligibility. (see 47 CFR Section 54.410(b)(ii) and Section 54.410 (c)(ii))
- Date or expiration date of documentation;
- Identifying information about documentation submitted (e.g., "blue SNAP card" or "letter from State Health and Human Services Agency");
- Date it was reviewed;
- Method the documentation was provided (whether it was delivered by fax, mail, electronically, or in person);
- Name or ID of the employee or agent who reviewed documentation;
- Name on the documentation demonstrating program participation (if different from name of applicant);
- Certification that the individual named on the documentation who is demonstrating program participation is part of the applicant's household (if different from name of applicant); and
- Certification that the individual named on the documentation who is demonstrating program participation does not already receive program-supported service (if different from name of applicant).