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

Tanea Foglia

Posts by Tanea Foglia

FCC Proposes $63 Million Lifeline Fine

Posted in FCC

The FCC has proposed a $63.5 million fine against American Broadband and Telecommunications Company for alleged Lifeline violations. The Notice of Apparent Liability alleges that American Broadband falsified Lifeline customer accounts by enrolling more than 12,000 deceased customers, manipulated existing customers’ personal information to create new subscribers, and failed to de-enroll ineligible subscribers. In all,… Continue Reading

Changes to Lifeline in 2018

Posted in FCC, USAC

By Danielle Frappier with contributions from Tanea Foglia   Although the future of the Lifeline program is in doubt, business must go on. ETCs should familiarize themselves with two key administrative changes taking place in 2018. New Lifeline Claim System (LCS) Replaces Form 497 The FCC issued a Public Notice last week reminding ETCs that… Continue Reading

FCC Reduces Reporting Requirements for High Cost ETCs

Posted in FCC

Four days after ETCs were required to submit FCC Form 481 (54.313 / 54.422 Data Collection Form); the FCC released an order streamlining the process for high-cost USF recipients by eliminating reporting requirements it deemed “duplicative” or “simply no longer necessary.”  The new rules, which will take effect once OMB has published its approval in… Continue Reading

FCC Reminds ETCs of Responsibility to Prevent Lifeline Fraud

Posted in FCC

The FCC issued a Public Notice reminding ETCs that despite the safeguards put in place by NLAD and the pending National Verifier, and the transition of Lifeline enrollment to USAC, ETCs are ultimately responsible for ensuring that only eligible customers receive Lifeline support. The reminder comes shortly after the GAO released its report on the… Continue Reading

New Lifeline Rules Take Effect December 2 and Draft Plan Released for National Verifier

Posted in General, USAC

The Lifeline program, created more than 30 years ago to make telephone service more affordable for low-income families, has undergone its most radical change to date.  Effective last Friday, Lifeline has been expanded to cover broadband (including the broadband component of bundles containing both voice and broadband service).  It is the last of four USF… Continue Reading

ETCs and State Commissions Seek to Overturn Some of the New FCC Lifeline Rules

Posted in FCC

As was expected after the FCC’s sweeping Lifeline rule changes, several parties filed Petitions for Reconsideration of the controversial Lifeline Modernization Order.  Petitioners, consisting of trade associations, ETCs, and a state public utilities commission, individually filed eight petitions for reconsideration on June 23rd, the last possible day to file. Each petition varies in the issues… Continue Reading

New FCC Lifeline Rules: Effective Dates Clarified Multiple Times But Some Discrepancies Remain

Posted in FCC

Update: The FCC corrected the discrepancies previously noted in our post by publishing corrections in the Federal Register The Lifeline Modernization Order was published in the Federal Register on May 24, making the effective date of the Order June 23, 2016.  Most of the rule changes, however, cannot take effect until the Office of Management… Continue Reading

Down to the Wire – OMB Approves Changes to FCC Form 481

Posted in FCC

The FCC announced on May 31 that the Office of Management and Budget (OMB) has approved changes to the FCC Form 481 (Carrier Annual Reporting Data Collection Form), which is due July 1. The revised Form 481 includes a number of non-substantive changes that clarify the filing instructions.  For Lifeline-only ETCs, there are no substantive… Continue Reading

Commissioner Pai Seeks Information on Potential Lifeline Abuse

Posted in FCC, General, National Lifeline Accountability Database

Commissioner Pai is seeking to identify other wireless ETCs that were allegedly engaged in practices similar to those detailed in the FCC’s recent Notice of Apparent Liability (NAL) issued against Total Call Mobile. In a letter to Chris Henderson, USAC’s CEO, Commissioner Pai states that sales agents for Total Call “testified that they worked side-by-side”… Continue Reading

Commissioner Clyburn Embarking on Nationwide Tour

Posted in FCC

Commissioner Clyburn announced her forthcoming Connecting Communities: Bridging the Communications and Opportunities Divide tour in which she will visit communities around the country to “hear first-hand the opportunities and challenges of bringing robust, affordable communications services to all Americans.” Interested parties can keep up with Commissioner Clyburn’s journey via Twitter using the hashtag #ConnectingCommunities or… Continue Reading