USTelecom Offers Suggestions on Emergency Broadband Benefit Program

In order to move quickly but also deliver a successful and efficient Emergency Broadband Benefit Program, the Commission should make its decisions with the following principles in mind:

• Use Existing Resources: Over the past few years, the Commission has made significant changes to Lifeline to verify eligibility and this updated structure provides a solid springboard for this new program—look first to it. Verifying eligibility with the new criteria will be one of the most important parts of the new program. The Commission and USAC have already undertaken a significant amount of work to establish the Lifeline National Eligibility Verifier and National Lifeline Accountability Database. The Commission should use them as the primary federal tool for providers to verify participants in all states—a “one stop shop” for providers who choose to use this service to determine eligibility. While the statute permits providers the flexibility of using alternative methods for verifying eligibility, to encourage broad participation and minimize administrative roadblocks, the Commission should be clear that providers have the option of relying solely on the National Verifier for this purpose.
• Keep it Simple: USTelecom members are eager to do their part, but participating inevitably requires implementation work, from IT systems development to call center training. If the program becomes complex, the implementation timeline will grow, ultimately delaying when customers can take advantage of the broadband benefit. Complexity could also discourage broad participation by providers. Clear compliance guidelines that recognize the unique nature and circumstances of the program are also critical. The simpler the Commission can make the program to implement the more effective it will be.
• Build Flexibility into Program Implementation: Given the emergency nature of this program, broadband providers will also be doing the internal work required to participate concurrently, so they will require some level of flexibility and optionality to adapt it to their existing plans and systems. Providing that flexibility will maximize participation and help ensure consumers receive the benefits Congress intended.
• Plan for Transitions from the Outset: It is important to plan now for how providers will transition into and out of the program. As there is a finite amount of money that will last an indeterminate amount of time, it is important for customers and providers alike to understand their responsibilities once the appropriated funding is fully expended.