Lifeline

National Lifeline Accountability Database (NLAD)

Benefit Transfers

A benefit transfer is when one carrier transfers a subscriber's Lifeline Program benefit to another carrier. The benefit transfer is at the request of the subscriber. The recipient carrier of the new subscriber will initiate the transaction in NLAD on the subscriber's behalf.

Prior to initiating a benefit transfer in NLAD, a carrier must obtain the consent of the subscriber (As of June 6, 2014, obtaining proper documentation of consent for a benefit transfer is mandatory). Obtaining consent ensures that a subscriber is not transferred without prior knowledge. In the normal course of business, a subscriber receives their Lifeline Program benefit from a carrier ("ETC A"). If the subscriber wants to transfer their benefit to another carrier ("ETC B"), the subscriber will contact ETC B and provide consent for the transfer.

How do I obtain consent?

In addition to obtaining a completed Lifeline Program eligibility certification and reviewing proof of eligibility, as of June 6, 2014, obtaining proper documentation of consent for a benefit transfer, as outlined below, is a mandatory step in the benefit transfer process. As a carrier initiating a benefit transfer, remember to keep record of all communications made with the subscriber when gaining consent, including records documenting the subscriber's affirmative consent. Such records must be kept in accordance with the FCC rules on record retention.

ETC B, the recipient of the subscriber, should initiate the transfer by sending either a paper or electronic consent request to the subscriber. The subscriber can provide their affirmative consent of the transfer either verbally or written (on paper or electronic).

The subscriber's affirmative consent must include the following:

  • An acknowledgement that, once the transfer is complete, the subscriber will lose their Lifeline Program benefit with ETC A.
  • An acknowledgement that ETC B has explained to them that they may not have multiple Lifeline Program benefits with the same or different providers.

Benefit Transfer Process

After gaining the consent of the subscriber, ETC B will log into NLAD and complete the "Transfer NLAD Benefit" screen. ETC B must complete all required fields for the subscriber to be transferred. Once all the information is completed, ETC B will select the "Transfer Benefit" button.

Even if some information entered by ETC B does not match the existing record for that subscriber, such as address or phone number, NLAD will still be able to identify the subscriber using these criteria:

  • Last name
  • Date of birth
  • Last four digits of the subscriber's Social Security Number

If the benefit transfer is a success, NLAD will:

  • De-enroll the subscriber from ETC A and label the subscriber in NLAD as having been de-enrolled as the result of a benefit transfer.
  • Enroll the subscriber with ETC B and label the subscriber in NLAD as having been enrolled as the result of a benefit transfer.
  • Notify ETC A and ETC B of the change.
  • End the benefit transfer transaction.

There are a few reasons why the benefit transfer process may fail, including:

  • If the subscriber has enrolled or has had their benefit transferred within the last 60 days, NLAD will deny the request.
  • If any of the subscriber information entered by ETC B is different from the existing subscriber record, the new subscriber information must pass all "new subscriber" rules, including TPIV.

If the benefit transfer fails, ETC B will be provided with the appropriate error codes and messages defining the reason for failure and the process will end. In the case of a benefit transfer failure, the subscriber will stay active in NLAD under ETC A.