Common Audit and Assessment Findings: Lifeline Program
In USAC’s continuing efforts to ensure service providers are successful at implementing the Federal Communications Commission (FCC) rules and program requirements, the Lifeline team compiled a list of problem areas identified during Beneficiary and Contributor Audit Program (BCAP) audits and Payment Quality Assurance (PQA) assessments. This list of common findings below is not meant to be all-inclusive.
Common Findings
Lifeline program non-compliance is most often caused by limited knowledge of program rules and insufficient internal procedures to support program compliance. Below is a list of common audits and assessments.
Description of Finding
Lifeline service providers are required to:
1) Have an effective process for identifying subscribers that have not used their service within 30 consecutive days if the eligible telecommunication carrier (ETC) does not assess and collect a monthly fee from the subscriber.
2) Provide the subscriber 15 days notice, using clear, easily understood language, that the subscriber’s failure to use the Lifeline service within 15 days will result in service termination.
3) De-enroll subscribers that have not used their service in 45 consecutive days.
4) Retain documentation to demonstrate that an effective non-usage process is in place.
| Examples: Improper Non-Usage Process | How to Address or Prevent this Finding |
|---|---|
| The service provider did not provide documentation to demonstrate the usage of its subscribers to determine whether the subscriber had used the phone service in 30 consecutive days. | The service provider must implement a system to retain documentation to demonstrate how it evaluates the usage of its subscribers to determine when the subscriber has not used the phone service in 30 consecutive days. |
Service providers may not claim ineligible subscribers for reimbursement in the LCS. Service providers can only claim subscribers for a data month if they serve them by the first of the following month in LCS. Service providers are also required to pass through the full amount of support to qualifying consumers.
- The federal Lifeline support amount for eligible consumers is up to $9.25 per month (except for voice-only service subscribers, who may receive up to $5.25).
- Consumers on Tribal lands can receive a support amount of up to $34.25 per month.
Service providers should implement a process to ensure their subscriber count is not overstated and its reimbursement claim matches the benefit amount provided to the subscriber.
| Example | Preventative Measures |
|---|---|
| Service providers over-reporting subscribers for reimbursement in LCS and claiming subscribers who no longer qualify or should have been de-enrolled from the program. |
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| Service providers are passing through partial support amounts to qualifying consumers, instead of the full amount. |
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Note: Service providers in NLAD opt-out states (CA, OR, and TX) must ensure data shared between the ETC and state public utility commission (PUC) is accurate and reflects actual Lifeline subscribers for which the service provider may receive reimbursement. As a reminder, service providers in NLAD opt-out states can only claim subscribers listed on the file in LCS provided by their state PUC.
Description of Finding
Service providers cannot claim support more than once for the same subscriber. The service provider did not have adequate processes in place to prevent providing more than one Lifeline benefit to the same subscriber and claiming these subscribers in the Lifeline Claims System (LCS).
This finding may apply to both National Lifeline Accountability Database (NLAD) states and NLAD opt-out states.
| Example | Preventative Measures |
|---|---|
| Service providers list the same subscriber more than once on their subscriber listing. | Service providers should develop processes to thoroughly review their subscriber listing for accuracy and remove any duplicate subscribers prior to submitting their claims to USAC for reimbursement. |
Eligibility documentation must ensure that the subscriber is qualified for the Lifeline program through the following options:
- A government program such as:
- Supplemental Nutrition Assistance Program (SNAP)
- Supplemental Security Income (SSI)
- Medicaid
- Federal Public Housing Assistance (FPHA)
- Veterans Pension or Survivors Benefit Programs
- Tribal specific programs
- Subscriber income at or below 135% of the Federal Poverty Guidelines.
This finding may apply to NLAD opt-out states.
| Example | Preventative Measures |
|---|---|
Eligibility documentation is inadequate due to at least one of the following reasons:
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Eligibility documentation must be carefully reviewed as required by the Lifeline rules before an eligibility determination is made. (See 47 CFR § 54.410). |
For more information about the BCAP audit process, review USAC’s BCAP page. For more information about the PQA assessment process, review USAC’s PQA page. You can also visit USAC’s Lifeline Rules and Requirements page to stay informed about Lifeline specific rule changes.