FCC Must Reach Out On Upcoming Changes to Lifeline Telecom Program

By the end of this month, the Federal Communications Commission (FCC) is expected to issue new rules aimed at reforming and modernizing the low-income Lifeline telephone program. The rules are expected to include many changes to the application process. It will also update the annual check-in which determines continued eligibility for the program.

Whether the FCC succeeds in this effort will depend on whether the reform order includes an extensive education and outreach component to explain the changes. Planning must start now.

The Lifeline order should:

• spell out the duties of telecom carriers to train their customer service representatives about the new program design,
• ensure the carriers’ websites include information that is easy to find and understand on the Lifeline benefit and how to apply,
• ensure that the Lifeline application forms are simple and easy to follow. The language should be understandable for those with low-literacy skills, and ideally tested with appropriate focus groups to ensure that the forms are understandable and usable (poorly designed forms can lead to mistaken rejections),
• ensure materials are accessible for consumers with disabilities and non-English speakers, including:
1. prominent carrier website information about the new Lifeline program,
2. clear materials that explain the new program processes, and
3. clear Lifeline application and annual re-certification materials, and
• include a role for community-based organizations to provide outreach, education and assistance with the applications process.

The FCC does not have to reinvent the wheel to roll out this plan.
With the recent duplications corrections process, the Universal Service Administrative Company (USAC), the (administrator of the Lifeline program, worked closely with the carriers to identify and educate customers about the need to select one Lifeline provider. USAC:

• developed a letter in English and Spanish that explained why the customer was receiving the letter and the process to inform USAC about which carrier the customer chose for Lifeline service,
• provided a toll-free number to make the process easy for the applicant, and
• followed up with a reminder postcard and phone call to nonresponsive customers.

Such additional customer “touches” will be especially critical for reaching out to existing Lifeline customers who may not realize the program has changed when it is time for them to recertify their continued eligibility.

The FCC is nearing the home stretch in issuing this upcoming order that will strengthen and bring the low-income Lifeline phone program into the 21st century.
Now is the time the FCC should hardwire into its order an inclusive and extensive outreach and education program for Lifeline beneficiaries. Failure to do so? Many current and future customers could be put on hold or get dropped. And that’s not the kind of customer service that will be good for anyone.

Olivia Wein is a staff attorney at the National Consumer Law Center.