Changes to Lifeline in 2018

Davis Wright Tremaine LLP

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 the new “Lifeline Claim System” or LCS has replaced the Form 497 and all ETCs except those in California, Oregon, and Texas are required to use the LCS to submit reimbursement requests.  Moving forward, ETCs will only be reimbursed based on the number of subscribers in the National Lifeline Accountability Database (“NLAD”) on the first day of the month (February 1st for data month January).  ETCs should review the subscribers listed as being enrolled with them in the NLAD to ensure that they only receive funding for accounts compliant with applicable regulations.

ETCS in NLAD opt-out states (California, Oregon, and Texas) will be reimbursed based on a data file submitted to USAC either by the state or the ETC directly.  If the former, the ETC will be required to validate the data and re-submit the list to USAC.

Going forward, the FCC Form 497 may only be used to claim support for data months in 2017 and earlier.

New Form 555

The FCC form 555 has been modified to accommodate the new rolling recertification requirement. For 2018, the dates will only include July through December – ETCs will not report customers whose Lifeline enrollment anniversaries fell during the transition period (January – June 2017).

Extra Time for Hurricane Victims

ETCs who provided service in areas impacted by Hurricanes Harvey, Irma, and Maria, received temporary waivers of certain Lifeline rules, specifically de-enrollment for non-usage, de-enrollment for failure to certify, non-usage, and recertification.  With respect to re-certification, the FCC is giving ETCs serving subscribers in affected areas additional time to complete re-certification where the subscribers’ Lifeline enrollment anniversary dates are close to the time of the relevant hurricane.  It is important to note that these ETCs must submit their 555 forms by January 31, 2018 for non-affected subscribers (i.e., those not in affected areas or those with anniversaries outside the scope of the waiver).  But they should omit those subscribers covered by the waivers in their January 2018 filings to avoid reporting incomplete data.  Instead, the ETC must report its re-certification results for those subscribers as instructed in the relevant waiver order.  USAC has posted copies of the waivers on its website page addressing this issue.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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