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Last year, the FCC issued the 2015 Lifeline Reform Order. There were four main rule changes outlined for the Lifeline Program and a few additional, smaller changes that each become effective on given dates throughout calendar year 2016.
We're here to help you navigate the implementation of these various changes so don't hesitate to contact us with any questions or concerns.
As of February 17, 2016, carriers and non-ETC resellers had to begin retaining subscriber eligibility documentation. Previously, you were not permitted to keep such documentation. The Order requires you to keep documentation for as long as the subscriber receives Lifeline Program service, but not less than the three preceding calendar years. State regulations that require carriers to maintain documentation for longer than three years are not in conflict with the revised federal Lifeline Program rules. It also does not apply retroactively to past actions, but only applies to conduct going forward, such as enrolling a new subscriber.
The document retention policy also applies to the NLAD dispute resolution process, including TPIV and address failures, and port freeze exceptions. You must keep all documentation reviewed to verify the identity or information of a subscriber as part of the NLAD dispute resolution process.
You must also maintain documentation of appropriate database queries or signed certifications from subscribers in relation to recertification, except in states where a state administrator or agency is responsible for recertification. If you use a state verification system to determine eligibility, you should keep unaltered proof and any correspondence received from the state.
The Oklahoma Tribal boundaries interpretation change only affects carriers serving the state of Oklahoma. The Order interprets the "former reservations in Oklahoma" as the boundaries reflected in the Oklahoma Historical Map provided. These boundaries determine areas in which carriers can receive enhanced Tribal support from the Lifeline Program. For more information about receiving additional Tribal support, see "Acceptable Forms of Documentation for Tribal Programs" on the Program Eligibility page.
In addition, on February 2, 2016, the FCC released an Order (DA 16-117) extending the transition period for the updated Oklahoma Tribal Map for 120 days, until June 8, 2016.
These maps are also downloadable as a shape file for GIS mapping software.
Effective August 15, 2016, 1) carriers can only receive reimbursement in instances where they provide Lifeline Program service directly to subscribers and 2) ILECs are no longer obligated to resell Lifeline Program services. Once the resale of Lifeline is eliminated, carriers that are a CLEC resellers with an eligible telecommunications carrier (ETC) designation will be allowed to seek reimbursement. A CLEC reseller carrier without an ETC designation will not be allowed to seek reimbursement.
Telephone companies that are designated ETCs will continue to offer Lifeline Program service to eligible customers, pursuant to the FCC's rules. For those non-ETC resale companies, the 2015 Lifeline Reform Order establishes a 180-day transition period (after OMB approval) after which those companies may not obtain reimbursement for Lifeline Program services. The Order does not establish specific requirements for transfer of those customers to other Lifeline Program service providers. If a telephone company relinquishes its ETC designation or discontinues a service under Section 214(a) of the Act, then existing state and federal relinquishment and discontinuances requirements will continue to apply.
A snapshot date is the date on which a carrier determines the number of Lifeline Program subscribers to report on their next FCC Form 497. Effective as of September 1, 2016, carriers will be required to take a snapshot of their subscribers on the first day of the month. Previously, carriers were permitted to claim subscribers based on any snapshot date during the month.
This means that the first form this rule affects is for the August 2016 FCC Form 497. You should claim on this form the subscribers captured on the September 1 snapshot. You do not have to wait until September 1 to implement this change, however. You can make the change at any time between now and then.
You can take the snapshot at any time on the 1st of the month, but it has to be taken on the 1st, even if the 1st is a weekend or holiday. You do not, however, need to submit a copy of the snapshot with your FCC Form 497 submission but you should keep a copy for audit purposes. You may continue to file your FCC Form 497 quarterly if you choose.
Subscribers who are enrolled and de-enrolled between snapshot dates should not be included in the snapshot. For instance, if a subscriber enrolls on the third day of a month, but de-enrolls the last day of the same month, they should not be included in the snapshot.
Subscribers who enroll on the first day of one month, and de-enroll on the first day of the next month, should be included in one monthly snapshot, or both monthly snapshots, depending on the timing of the snapshot. For example, if a subscriber is enrolled on November 1, prior to the snapshot being taken, the subscriber will be included in the November 1 snapshot. If the subscriber is enrolled after the snapshot is taken, the subscriber will not be included. If the same subscriber is de-enrolled on December 1, prior to the snapshot being taken, the subscriber will not be included in the December 1 snapshot. If the subscriber is de-enrolled after the snapshot is taken, the subscriber will be included.
In addition to the adoption of the four main rule changes outlined in the sections above, the Public Notice (DA 16-56) released on January 15, 2016, stipulates other changes that have also received OMB approval and were published (with the exception of the Oklahoma Tribal map) in the Federal Register on February 17, 2016. Most of these additional changes require no action on the part of carriers. Please see below for more information on the specific changes.
We will communicate additional information on these changes as it becomes available. Sign up for news bulletins in our Subscription Center.
The Lifeline Program team is here to help you every step of the way. Contact us with your questions or comments.
Go to the 2016 Lifeline Order.