Legacy Recertification Process

Service providers must recertify all subscribers according to their anniversary date. The entire process (including de-enrollment) must be completed by the customer’s anniversary date.

Service providers are required to use the FCC’s Universal Lifeline Consumer Forms for recertification (FCC Form 5630).

Requirements vary by state due to select eligibility program waivers. Note that no recertifications for the federal Lifeline benefit were required for anniversary dates that fell from January through June2017 (the “transition period” to rolling recertification). Learn more in the FCC’s Public Notice: Guidance on Rolling Recertification, released on October 27, 2016.

Skip to: Sample SchedulesRolling Recertification Terms, or visit the Legacy Recertification FAQs page

Rolling Recertification

Each Lifeline subscriber must be recertified by their anniversary date. Service providers are permitted to batch customers into groups by anniversary date. If you use batching, make each part of the process is compliant for every customer in the batch. USAC recommends using one- or two-month batches.

The rolling recertification process is:

  1. Database Query: First, attempt to verify the customer’s eligibility through a state or federal eligibility database query (if available). If no database is available, proceed to step #2.
    • Service providers are responsible for determining eligibility, even when using a state’s database. Please confirm the state is in compliance with the streamlined eligibility criteria as of December 2, 2016.
    • If the database verifies the customer’s eligibility, no further action is required.
    • If the database cannot verify the customer’s eligibility, proceed to step #2.
  2. Direct Contact: Contact the customer to confirm their continued eligibility for the Lifeline Program, and to complete the required certifications.
    • Contact the customer in writing, separate from the bill, no more than 150 days before their anniversary date.
    • The recertification process takes a minimum of ~65 days.
    • Use FCC Form 5630 (annual recertification form) and FCC Form 5631 (one-per-household worksheet) for mailings on July 1, 2018 and later.
    • If you create your own form (prior to July 1, 2018), use the updated list qualifying programs (effective Dec. 2, 2016), unless the customer resides in a waiver state. In waiver states, you must include otherwise-retired programs. Follow all requirements for the letter and form, including obtaining initials next to each certification statement and a signature. See the Lifeline Program Rules, Sections 54.405(e) and 54.410(f), for details.
  3. Allow 60 days for the customer to respond.
    • Optional: Send reminders to customers via mail, phone, or SMS.
  4. De-enroll failed and non-responsive customers.
    • De-enroll customers from your internal company systems within five (5) business days after the 60-day response period expires, and by the customer’s anniversary date.
    • De-enroll customers from NLAD within one (1) business day after you de-enroll the customer from your internal company systems, and by the customer’s anniversary date.
    • Optional: Notify customers of their pending de-enrollment from the Lifeline benefit.
  5. No further action is required for successfully-recertified customers.
  6. The entire process must be completed by the customer’s anniversary date.
    • If you are recertifying in batches, make sure the process is complete on time for every customer in the batch.

If you need assistance, contact us via LI Verifications.

Sample Recertification Schedules

Sample Schedule 1 (Recommended)
This schedule begins well in advance and groups the anniversary dates into one-month batches. Here, the company sends a recertification letter approximately three (3) months before the anniversary date, allows a 60-day response period, has a full five (5) business days to de-enroll failed subscribers from their internal systems, and ends ~20 days before the deadline (the first anniversary date in the batch).

Batch Schedule: July Anniversaries

Subscriber anniversaries: July 1 – July 31

    1. Verify eligibility using state database (if available): 3/20/18
    2. Send initial notice to subscribers: 4/2/2018
    3. 60-day response window: 4/2 – 5/31/18
    4. De-enroll failed subscribers from internal company systems: 6/7/18
    5. De-enroll failed Lifeline subscribers from NLAD: 6/8/18

Complete the recertification process for subscribers in this batch by: 7/1/18

Batch Schedule: August Anniversaries

Subscriber anniversaries: August 1 – August 31

    1. Verify eligibility using state database (if available): 4/20/18
    2. Send initial notice to subscribers: 5/2/ 2018
    3. 60-day response window: 5/2 – 6/30/18
    4. De-enroll failed subscribers from internal company systems: 7/10/18
    5. De-enroll failed Lifeline subscribers from NLAD: 7/11/18

Complete the recertification process for subscribers in this batch by: 8/1/18

Sample Schedule 2 (Meets Minimum Requirements)
This schedule shows the latest timing possible that groups the anniversary dates into one-month batches and still complies with all of the program’s rules. Here, the company sends a recertification letter 65 days before the anniversary date, and the five-day period to de-enroll customers from their internal system (and one day for NLAD) is cut short so the company can complete the de-enrollments before the deadline (the first anniversary date in the batch).

Batch Schedule: July Anniversaries
Subscriber anniversaries: July 1 – July 31

    1. Verify eligibility using state database (if available): 4/27/18
    2. Send initial notice to subscribers: 4/28/2018
    3. 60-day response window: 4/28 – 6/26/18
    4. De-enroll failed subscribers from internal company systems: 6/30/18
    5. De-enroll failed Lifeline subscribers from NLAD: 6/30/18

Complete the recertification process for subscribers in this batch by: 7/1/18

Batch Schedule: August Anniversaries
Subscriber anniversaries: August 1 – August 31

    1. Verify eligibility using state database (if available): 5/28/18
    2. Send initial notice to subscribers: 5/29/18
    3. 60-day response window: 5/29 – 7/27/18
    4. De-enroll failed subscribers from internal company systems: 7/31/18
    5. De-enroll failed Lifeline subscribers from NLAD: 7/31/18

Complete the recertification process for subscribers in this batch by: 8/1/18

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. Confirm subscribers’ anniversary dates using the “Detail Active Subscriber Report” in NLAD.

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. Service providers are responsible for ensuring the state’s verification process/eligibility database is in compliance with the streamlined eligibility criteria that went into effect on December 2.

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.