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Lifeline Law Advisor Insight & Commentary on Lifeline Program Compliance & Regulatory Issues

About the Lifeline Program

The Lifeline program provides subsidies to lower the retail rates of telephone services to low income consumers.  Lifeline participants qualify based on participation in another social program (e.g., food stamps) or certain income level (which is 135% of federal poverty guidelines in most states).  Telephone companies must first obtain eligible telecommunications carrier (“ETC”) designation from the relevant state public utility commission, or in some cases, the FCC.  The program is funded through the federal Universal Service Fund.

Lifeline eligible telecommunications carriers (“ETCs”) turn to DWT for our extensive and in-depth experience handling market entry and compliance issues at both the federal and state levels. DWT has a dedicated Lifeline team that lives and breathes the Lifeline program every day. We represent top-10 Lifeline ETCs as well as much smaller firms. We are highly experienced in ETC legal issues, but more importantly, we understand how the legal issues affect your business.

In January 2012, the FCC adopted a comprehensive overhaul of the Lifeline program, including a proposal to require “Lifeline resellers” to obtain formal certification as ETCs. The FCC’s action presents compliance and operational challenges–but also real business opportunities–for Lifeline providers. We can help you succeed in this new environment. Our services include:

ETC designation and FCC compliance plans
Under the FCC’s new rules, scale is critical. We can help you grow by obtaining ETC designations in the markets you wish to serve. DWT acts as national counsel for Lifeline providers and seamlessly coordinates with a network of local firms, as needed. In addition, entities without their own complete telecommunications network must have a compliance plan approved by the FCC. We prepare compliance plans targeted to our clients’ actual business practices and operations–not “cookie cutter” compliance plans that may not suit your needs.

Audits and regulatory inquiries
Audits and inquiries from regulators are a fact of life for Lifeline providers–they are a matter of “when,” not “if.” We have extensive experience responding to regulatory inquiries and audits, including those originating from the administrator of the Lifeline program (USAC). When your business is audited, DWT attorneys will stand by your side throughout the process.

Regulatory compliance 
The FCC’s new Lifeline order affects all aspects of a Lifeline provider’s business: marketing and advertising, service plans, customer eligibility and enrollment, service terms and conditions, customer service, handset distribution, and more. We can guide your business through the maze of new rules and keep you in compliance to ensure full Lifeline payments from USAC and to avoid penalties.

Obtaining Lifeline universal service funding
We regularly assist clients with implementing best practices regarding filing forms (497s) needed to receive Lifeline funding on a timely basis and compiling documentation necessary to back up those funding claims in the event of an audit.

DWT attorneys have established relationships with key Lifeline decision-makers at the FCC, state commissions and USAC. We can help you shape the direction of federal or state Lifeline rules by preparing comments or by meeting directly with key officials.