Lifeline ETCs Back Reimbursement During Non-Usage 'Cure Period'; Tribal Concerns Flagged
Lifeline USF providers endorsed a request that program providers be reimbursed during a subscriber non-usage grace period. The National Lifeline Association recently petitioned the FCC to rule that Lifeline eligible telecom carriers (ETCs) be "permitted to seek reimbursement for all…
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Lifeline eligible subscribers served as of the first day of the month ... including those subscribers that are in an applicable 15-day cure period following 30 days of non-usage." Universal Service Administrative Co. had reversed guidance that let Lifeline ETCs be reimbursed during the cure (grace) period, providers said in comments posted Monday and Tuesday in docket 11-42. "FCC rules require ETCs to provide Lifeline customers with service during the cure period (Section 54.405(e)(3)), and mandate provision of Lifeline support to eligible Lifeline subscribers served on the first day of the month (Section 54.407(a))," Sprint said. "The reasonable and logical import of these rules is that Lifeline support is due for Lifeline customers who are in the cure period as of the first of the month." It said providers incur "significant" costs for accounts during the cure period, and said if USAC's reversal is upheld, it should be applied only prospectively. Q Link Wireless and Smith Bagley filed supportive comments (here and here). Smith Bagley discussed with FCC staffers an upcoming transition to a national verifier of Lifeline eligibility and "ways to mitigate potential impacts on Tribal areas," said another filing. Tribal representatives affiliated with the National Congress of American Indians also voiced support for Lifeline on tribal lands, in discussions with Chairman Ajit Pai, other commissioners and staffers in conjunction with NCAI's meeting Feb. 15 (see 1803130057). Chickasaw Nation Lt. Gov. Jefferson Keel "expressed concern about changes to the geographic scope of the enhanced Tribal subsidy," filed Barbara Esbin, Consumer and Governmental Affairs Bureau deputy chief. "Teresa Hopkins, Navajo Nation Telecommunications Regulatory Commission, expressed concern about the loss of one-on-one relationships between providers and Lifeline recipients in the move to the National Eligibility Verifier, which have proven particularly important to those serving and living on Tribal lands, where many rely on mobile wireless and Smartphones as their only source of communications services." It said tribal leaders urged the FCC to act on a February 2017 draft order to exempt carriers primarily serving tribal lands from operating-expense limitations (see 1802020058), and supported a tribal broadband factor proposed by a recently circulated draft NPRM and order (see 1801160040).