National Lifeline Association Submits Comments to Senate Universal Service Fund Working Group

Congress and the Federal Communications Commission must act swiftly and purposefully to ensure that low-income households continue to have sustainably affordable access to communications services through a fully funded low-income program that is structured to effectively close the affordability component of the digital divide while preserving program integrity. National Lifeline Association (NaLA) offers the following recommendations and observations:

• Congress and the FCC should either consolidate the Lifeline program with the Affordable Connectivity Program (ACP) or reform both so that they better serve the goal of making essential communications services affordable each and every month. Consolidating the ACP and Lifeline program would require reconciling policy differences.
• Any future low-income program should be designed to ensure that low-income households have sustainably affordable access to essential communications services by carrying forward key program design elements from the ACP
• The effectiveness of a low-income support program should be measured by whether low-income households have sustainably affordable access to essential communications services
• Appropriated funding will be needed at least until USF reform can be accomplished
• If ACP and Lifeline remain separate programs, they should be reformed to be more complementary and consistent
• The FCC and USAC must be more transparent and accountable in the administration of any low-income affordability program