The FCC needs to make continued Lifeline program overhaul...

program would benefit from a rule change permitting eligible telecom carriers (ETCs) to retain proof of eligibility for audit purposes, and to “respond to negative media stories that claim an ETC did not require proof of eligibility, the coalition said. ETCs should be required to do a non-commission-based review and approval of all enrollments, the group said. Minimum standards for state eligibility databases would enable real-time enrollment and “guard against denying Lifeline service to eligible consumers,” the group said. The coalition also asked for a safe harbor from enforcement actions for alleged duplicate enrollments for Lifeline subscribers that have been submitted to the National Lifeline Accountability Database (NLAD) or a similar state database. Commission rules don’t define a “duplicate” for purposes of the one-per-household rule, the coalition said. “Despite the lack of clarity regarding duplicate accounts prior to NLAD implementation, the Commission has undertaken a misguided and harmful process of proposing multi-million dollar fines against ETCs for failing to eradicate 100 percent of end-user fraud allegedly perpetrated in the form of intra-company duplicate enrollments in the Lifeline program,” it wrote. “The Commission should establish a safe harbor reflecting a minimum level of due diligence that a Lifeline ETC should employ to screen for duplicates.” A Lifeline provider that has conducted appropriate due diligence to identify duplicates should not be liable for retroactive reimbursements to USF, the coalition said.