CPUC Gathers Support for SSN-Less LifeLine Eligibility Plan

"While the staff proposal shows a commitment to finally implementing the decade-old decision to expand” LifeLine to include consumers without SSNs, “it must not do so in a manner that creates discriminatory or insurmountable barriers for the population it seeks to include,” said low-income advocates including Legal Services of Los Angeles County and the Legal Aid Association of California in docket R.20-02-008. The CPUC should expand its proposed list of accepted ID documents, collaborate with other agencies to enroll people in LifeLine when they enroll in other benefit programs and have a “comprehensive outreach plan,” the advocates said.

The CPUC should expand accepted ID documents to include those accepted by Medi-Cal, Cal Fresh and the federal affordable connectivity program, agreed The Utility Reform Network (TURN), Greenlining Institute and UNITE-LA. The CPUC should "require all providers to accept applications from applicants without SSNs and prohibit service providers from discriminating against applicants without" SSNs, the consumer groups said. Make it clear that providers may not refuse service to applicants because they lack SSNs, they said. Public advocates in January commented that the existing SSN requirement adversely affects vulnerable populations (see 2401290041).

Assurance opposed a mandate. The T-Mobile subsidiary said it might withdraw its opposition to the staff proposal if enrolling applicants without SSNs is an "option" not an "obligation." SSNs are key to the company's "ability to mitigate fraud and abuse,” but the staff proposal "creates a wholly separate enrollment track that would require providers to process, review and collect a fluid set of unfamiliar and unverifiable ‘identity documents’ without any safe harbor,” it said.

Other companies didn’t oppose the staff proposal, including Cox, Verizon’s TracFone Wireless and the National Lifeline Association (NaLA). Cox supported parts of the plan "that seek to keep the enrollment processes as similar as possible for all Lifeline applicants” because that will ensure “integrity” and “contribute to its overall, long-term success."

Verizon said it generally supports the proposal, though it's concerned about transitioning all enrollments to a customer portal that the LifeLine third-party administrator (TPA) will manage "with unclear involvement and support from LifeLine providers and their in-person and other enrollment supports." That approach would create risks "including (1) eliminating in-person enrollment assistance that many LifeLine consumers require to access the LifeLine Program; (2) creating potential consumer confusion about selecting their desired provider and offer through the TPA process; and (3) disincentivizing provider competition,” it said.

Staff’s proposal is "consistent" with NaLA recommendations that California LifeLine should replace the lost federal Lifeline reimbursement and that applications without SSNs "are the exception rather than the rule,” the association said. But the TPA shouldn't take LifeLine outreach and enrollment from providers, NaLA said. "That would take away service provider incentives to conduct outreach and acquire customers, which would drastically shrink the California LifeLine program and render it largely ineffective."

"The proposal reflects a nuanced and phased approach, which should help mitigate concerns about unintended consequences for the LifeLine budget and potential over-inclusivity or abuse in the enrollment process,” a group of small rural telcos said. Such a plan, "if not properly framed, has the potential to drastically increase the LifeLine budget and create extensive customer confusion,” the small telcos said. They said they “remain concerned about the potential ramifications of relaxing the SSN requirement," but overall believe it's "a reasonable way to execute the policy."

Still, AT&T wants to see additional details before the commission adopts the staff plan, commented the carrier: The plan "is ambiguous as to: (1) the implementation timeline for all but one of the proposed phases; (2) service provider requirements, if any, and who bears the costs of any such requirements; and (3) the increase to the California LifeLine Program budget and/or California LifeLine Fund."

Consumer and low-income advocates urged caution concerning staff’s plan for using TrueID, a LexisNexis authentication software, for verifying applicants' identities. The CPUC "should ensure that strict data privacy protections are part of any contract with LexisNexis to collect and process LifeLine applications,” including opt-out rights and data minimization requirements, said the TURN group. "Data processors should not be able to use LifeLine consumer data for purposes beyond identity verification and should delete that data once processing is complete."

Minimize data sharing and make TrueID “an optional way for people to confirm their ID,” the Legal Aid Association and other low-income advocates advised. The LexisNexis software could be problematic for some applicants because it requires a digital device with the ability to upload selfies and photos of ID documents, they warned. "Requiring individuals who cannot afford a phone plan and/or a smartphone to utilize a smartphone to apply for a low-income phone plan does not make sense."