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

Davis Wright Tremaine

Posts by Davis Wright Tremaine

Rosenworcel Nominated for New FCC Term

Posted in FCC, General

On June 13, the White House announced that Jessica Rosenworcel, who served as an FCC commissioner from 2012 until her term expired on Dec. 31, 2016, will be nominated to a new term at the agency. Rosenworcel, a Democrat, has been a strong supporter of the E-rate program, and of broader efforts to close the… Continue Reading

DWT Gains Approval of Three Lifeline Broadband Provider Petitions Among Five New FCC Grants

Posted in FCC

On January 18, the FCC’s Wireline Competition Bureau issued an order granting five Lifeline Broadband Provider (LBP) petitions, enabling the grantees to receive Lifeline support for the provision of broadband Internet access services to eligible applicants. As we reported in a prior post, the Bureau granted four LBP petitions on December 1, so the new… Continue Reading

FCC Proposes First-Ever Forfeiture Against Rural Health Care Program Service Provider, For $21.7 Million

Posted in FCC

On November 4, the FCC issued a Notice of Apparent Liability for Forfeiture (“NAL”) against Network Services Solutions, LLC (“NSS”) and its CEO, Scott Madison, alleging multiple and egregious violations of the Commission’s program rules pertaining to the federal Universal Service Fund’s (“USF”) Rural Health Care (“RHC”) Program.  An accompanying press release stated that the… Continue Reading

DWT Serves Up Fixed Fee Lifeline Compliance Service

Posted in General

Last month, DWT’s Lifeline Team introduced its Lifeline Compliance Service Menu, designed to give Lifeline providers five star regulatory support at reasonable rates.  DWT believes that the fear of high legal costs should not deter service providers from seeking the best Lifeline guidance available.  Fixed fee services include: Prix Fixe Option Annual review of Lifeline… Continue Reading

The Lifeline Modernization Order

Posted in FCC

Last week, the FCC finally released the full, 224-page text of its controversial and anxiously awaited Lifeline Modernization Order, which was approved by a bitterly divided, party-line 3-2 vote on March 31. As we advised in a post summarizing the meeting, the new Order transforms Lifeline from a voice-only subsidy program to one that subsidizes high speed broadband,… Continue Reading

FCC Releases Eagerly Anticipated Lifeline Order

Posted in FCC, General

Four weeks after voting 3-2 along party lines to modernize the Lifeline program; the FCC has finally released the text  of the Order.  The new Lifeline rules: Provide a mechanism for Lifeline subsidies to support broadband service Eliminate voice service by December 2021 with few exceptions Create minimum service standards for broadband and mobile voice… Continue Reading

Open Internet Webinar

Posted in FCC

Keeping up with the Latest Happenings at the FCC, Capitol Hill, and Beyond Tuesday, April 26, 2016 2:00 – 3:00 p.m. EDT As the Obama Administration winds down, the FCC has moved forward with a series of Internet-related initiatives in quick succession including new rules impacting Lifeline and Open Internet and proposed privacy rules. Please… Continue Reading

Lifeline Proceeding Highlights Flaws, Reflects Political Climate at FCC

Posted in FCC

Last week’s contentious vote on Lifeline reform, remarkable for playing out so publically, not only highlighted flaws in the FCC’s administrative practices but also reflected how polarized the political climate has become at the FCC and other agencies. Three weeks before the March Open Committee meeting, the FCC released a fact sheet containing details of… Continue Reading

FCC Passes New Lifeline Rules During Dramatic Meeting

Posted in FCC

After a series of delays due to intense last minute negotiations and culminating in its meeting starting 3.5 hours late, the FCC voted yesterday along party lines to permit low-income recipients to apply their Lifeline discount to broadband service. As Chairman Wheeler noted in his written statement, Internet access has become essential for full participation… Continue Reading

The People Have Spoken, Will the FCC Listen?

Posted in FCC

If you’ve been following the most recent round of Lifeline reform proceedings, you will have noticed two things: The overwhelming majority of Lifeline stakeholders agree that Lifeline support should cover broadband service; and Stakeholders are united in their opposition to the FCC’s proposed reforms, which include a phase-down of mobile voice service and the imposition… Continue Reading

FCC Delays Effective Date of Oklahoma Tribal Lifeline Change to June 8

Posted in FCC

This past Tuesday, the FCC’s Wireline Competition Bureau issued an Order delaying for 120 days the effective date of the agency’s new interpretation of “former reservations in Oklahoma” for purposes of delineating the area in that state eligible for “Enhanced Tribal Lifeline support.”  The additional Tribal support augments the standard monthly Lifeline subsidy of $9.25… Continue Reading

USAC Request for Information Contemplates National Lifeline Eligibility Verifier With Verification Lag

Posted in USAC

On September 10, USAC posted a Request for Information (RFI)—usually a precursor to an RFP—to prospective vendors of a third party “national Lifeline eligibility verifier” system, proposed in the FCC’s pending Lifeline Further Notice of Proposed Rulemaking as a replacement for the current process wherein Lifeline ETCs receive and review proof of Lifeline eligibility presented by… Continue Reading

Comment Deadline Extended in Lifeline Rulemaking

Posted in FCC

In July, we reported that the FCC implemented several changes to the Lifeline program, and the corresponding deadlines when those changes will become effective.  At the time, the Commission also issued Further Notice of Proposed Rulemaking (“FNPRM”), which proposed additional reforms to the Lifeline Program and requested comments on those changes. Several petitioners requested an… Continue Reading

New Lifeline Order to Become Effective Aug.13

Posted in FCC

Comment Deadlines Announced Last month we reported that the FCC had adopted new reforms to the Lifeline program and proposed further rule changes in its Second Further Notice of Proposed Rulemaking, Order on Reconsideration, Second Report and Order, and Memorandum Opinion and Order (Second Order and FNPRM).  Only the Second Order was published in the… Continue Reading

Update: Senate Hearing Vents Lifeline Concerns, Proposals In Advance of New FCC Rulemaking

Posted in Congress

As previously reported, on June 2 the U.S. Senate’s Subcommittee on Communications, Technology, Innovation and the Internet held a hearing on “Lifeline: Improving Accountability and Effectiveness,” in anticipation of the FCC’s expected June 18 adoption of a new Lifeline order and further notice of proposed rulemaking.  It is anticipated that the notice will propose further changes… Continue Reading

Open Internet Webinar

Posted in FCC

June 11, 2015 1:00 PM – 2:00 PM EDT CLE   Please join us for an interactive discussion on the FCC’s new “Open Internet” (a.k.a. net neutrality) rules on the eve of their effective date to learn how these sweeping new regulations may impact your business operations. Agenda Overview & June 12 Highlights – Chris… Continue Reading

Senate Subcommittee To Hold June 2 Hearing on Lifeline

Posted in Congress

In advance of the FCC’s expected adoption on June 18 of a new order and further notice of proposed rulemaking proposing further changes in the Lifeline program, the U.S. Senate’s Subcommittee on Communications, Technology, Innovation and the Internet has announced a hearing on Tuesday, June 2, 2015 on “Lifeline: Improving Accountability and Effectiveness.” (The anticipated… Continue Reading

AT&T and SNET to Pay $10.9 Million for Overbilling Lifeline Program

Posted in FCC

AT&T and SNET  (while affiliated with AT&T), have agreed to pay a collective $10.9 million in order to settle an FCC enforcement proceeding involving the failure to timely de-enroll “a number of” subscribers who were no longer eligible to receive support from the Lifeline program and the failure to maintain proper enrollment documentation. Both companies… Continue Reading

FCC Clarifies Lifeline Subscriber Usage Rules

Posted in FCC

On March 31, 2015, the FCC’s Wireline Competition Bureau (“Bureau”) released an Order clarifying subscriber usage rules of Lifeline-supported service established in the 2012 Lifeline Reform Order in an attempt to curb Lifeline support for inactive subscribers. The Bureau clarified that ETCs must both assess and collect a monthly fee from subscribers in the program… Continue Reading

Oklahoma Commission Revises Universal Service Rules

Posted in State

On March 12, 2015, the Oklahoma Corporation Commission (OCC) adopted revisions to its rules relating to administration of federal and state universal service programs, including Lifeline.  While the revisions generally consist of an overdue overhaul of many outdated telecom service regulations, the OCC adopted a number of substantive rule changes affecting Lifeline ETCs, including:  (1) removing regulatory distinctions between… Continue Reading