Legacy Recertification

Q1: In paragraph 418 of the Order it says, “Beginning July 1, 2017, all subscribers enrolled prior to January 1, 2017, will need to be recertified on a rolling basis based on the subscriber’s service initiation date.” If an ETC recertifies 100% of its eligible base before July 2017, can it roll out the new process after that date?

A1:

No. Subscribers must be recertified on the anniversary of their service initiation date beginning with service anniversaries on July 1, 2017. The transition period from January 1 to July 1, 2017, is meant to give service providers time to prepare for rolling recertification.

Q2: With rolling recertification, does a subscriber that enrolls on June 15, 2016, need to be recertified by the end of 2017?

A2:

No. The first time the subscriber needs to be recertified is June 15, 2018. Customers who initiate Lifeline-supported service in January-June 2016 do not need to be recertified until their service initiation anniversary in 2018.

Q3: What does “service initiation date” refer to: the date that the customer initiated telephone service or the date that the customer enrolled in Lifeline?

A3:

It is the date the service provider begins providing Lifeline-supported service to the subscriber.

Q4: Right now, there’s an option for carriers to let USAC conduct recertification on their behalf. Will this be available under the new reformed program?

A4:

Yes, it will be, as long as the National Verifier is not implemented in their state.

Q5: If a subscriber enrolled using a retiring eligibility program, are they still eligible until their next recertification? And how can the carrier recertify them going forward?

A5:

Yes. Customers that enrolled prior to December 2, 2016, using a retiring eligibility program can continue using their Lifeline benefit until their next recertification. Beginning with rolling recertifications in 2017, carriers should use the new eligibility programs (except for subscribers who reside in waiver states).

Q6: Can service providers batch rolling recertifications by month or quarter?

A6:

Yes, there’s flexibility to batch subscribers. If you use batching, make each part of the process is compliant with the rules for every customer in the batch. USAC recommends using one- or two-month batches.

Q7: If a state commission is responsible for recertification, and has additional eligibility criteria for its own low income telephone assistance program, will it continue to play a role in recertification for federal Lifeline?

A7:

Yes. States can still choose to conduct their own recertifications for the federal Lifeline program until the National Verifier is in place. In conducting the recertification for federal Lifeline support, states must use the federal eligibility criteria for recertifications that start on December 2, 2016 (unless they were granted a waiver).

Q8: For existing customers, when should we use the “old” recertification process (based on the February FCC Form 497), and when should we use the new “rolling” process?

A8:

For subscribers enrolled prior to 1/1/2016, use the “old” recertification process for their 2016 recertification. Existing customers that signed up in 2016 will have their first recertification in 2017. For 2017 and future recertifications, use the “rolling” process. Note that because of the “transition period,” customers whose 2017 anniversary date falls in January – June skip 2017 recertification, and begin rolling recertification in 2018.

Q9: How does rolling recertification affect the FCC Form 555 filing?

A9:

There are no changes for the 2016 FCC Form 555 filing (due January 31, 2017). The FCC and USAC are currently reviewing the FCC Form 555 filing for 2017, and are likely to recommend changes. We will share more information when it becomes available.

Q10: When does the customer need to recertify each year: Their birthday, or activation date?

A10:

The anniversary date service providers need to use starting with the 2017 recertifications is every 12 months after the Lifeline subscriber’s service initiation date. Not their birthday.

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