Shauna Edson

NDIA Joins Partners to Advocate for Lifeline Participants in Comments to the FCC

NDIA, along with nine partner organizations, submitted comments to the Federal Communications Commission (FCC) on the Lifeline program. The FCC published a Federal Notice of Proposed Rulemaking (FNPRM) to gather feedback on proposed changes to the Lifeline Program aimed at reducing  ‘waste, fraud, and abuse’. These proposed changes include several administrative and programmatic adjustments that could further complicate the enrollment process for qualified individuals, making it harder to reach the program’s goal of universal service. 

Thirty years ago, the FCC was tasked with guiding the Universal Service Fund and its programs to achieve ‘universal service,’ the principle that all Americans should have access to communications services. The goal has not yet been achieved; 23.5 percent of US households do not have a high-speed home internet subscription. The Lifeline Program was created to support universal service objectives by making internet subscriptions more affordable for low-income households. In every state, the main reason households lack internet access is affordability. Lifeline is one of the FCC’s most important tools for bridging the digital divide, but only 21 percent of eligible households nationwide participate in the program. 

Our comments express concerns that the proposed changes to the Lifeline program could create significant barriers for eligible households. The FCC should simplify the application process rather than complicating itating it, and should actively address provider misconduct.

Key Takeaways from the comments:

  • Bolster the Benefit Amount to Meet Connectivity Needs: At $9.25 per month and $34.95 a month for Tribal lands, the benefit has not kept pace with modern broadband costs or inflation. This has made the program insufficient to support reliable home internet connections for vital services like telehealth and education.
  • Social Security Number (SSN) Requirements Create Barriers to Enrollment: The proposal to require full SSNs, rather than the current last four digits, would create a barrier to enrollment due to privacy and security concerns, and is unnecessary given the existing verification system’s effectiveness.
  • The One-Per-Residence Proposal Harms Shared-Housing and Multigenerational Families: Replacing the “one-per-household” rule with a “one-per-residence” limit would disproportionately harm multigenerational and shared-housing families by potentially excluding separate families living at the same address.
  • A Need for Easier Enrollment to Lessen “Time Tax” and Increase Participation in the Program: Lifeline applications and the applications for the (now defunct) Affordable Connectivity Program have shown high rates of applications being abandoned due to complex manual reviews and documentation requirements. Proposed changes, such as expanded identity verification and usage tracking, risk making the process even more burdensome for low-income households who already face a “time tax” of due administrative burden. 
  • Address Provider Misconduct: Fraud and abuse narratives often place blame on consumers, even though enforcement actions show that internet service providers are often engaging in such practices. We call for stricter enforcement of rules regarding provider enrollment representatives and commission-based compensation.
  • Create a Lifeline Outreach Grant Program: To address enrollment challenges and provider misconduct, we urged the FCC to establish a grant program to fund neutral, high-touch outreach and enrollment support by trusted community organizations.

The Lifeline provides a monthly discount of up to $9.25, enhanced to $34.25 on Tribal land, for phone, internet, or bundled service. Eligibility for the Lifeline program is open to individuals with incomes at or below 135 percent of the federal poverty guidelines, as well as those who participate in needs-based programs like Medicaid, SNAP, Supplemental Security Income, federal public housing assistance, or Veterans Pension and Survivors Benefits. Learn more about the program on the Lifeline website.

Access the full text of our Joint Comments to the FCC on Lifeline here.