In conjunction with the 2015 Congressional Black Caucus Annual Legislative Conference this week, our co-chairs Jamal Simmons and Larry Irving have penned a memo for participants highlighting recommendations for Lifeline reform that ensure 21st century connectivity for low-income Americans. Here are those recommendations:
The FCC should move swiftly to address existing structural flaws that hamstring the program and the Lifeline marketplace by adopting the following essential reforms:
1. Safeguard Lifeline by taking eligibility determinations away from self-interested service providers.
The FCC’s proposal to remove the responsibility of consumer eligibility determination from Lifeline providers is the right one. Determining eligibility for receiving benefits from a government program is an inherently governmental function; as such, eligibility determinations should not be left to service providers that may have improper economic incentives to increase enrollment.
2. Simplify and protect the Lifeline program by vesting administration in a state agency using a “coordinated enrollment” and de-enrollment process.
Rely on state governmental agencies as the neutral entities charged with using a coordinated enrollment process to verify consumer eligibility and administer the enrollment and de-enrollment processes. Under this process, consumers determined eligible to receive Supplemental Nutrition Assistance (SNAP) by the State would automatically be deemed eligible to receive Lifeline assistance. A reformed federal Lifeline program should link eligibility determination to a single, mature assistance program – SNAP – which would increase administrative efficiency, promote participation by both consumers and service providers, and reduce the potential for waste, fraud, and abuse.
3. Empower consumers with a “Lifeline Benefit Card” – a direct-to-consumer benefit.
Lifeline program benefits should be transferred directly to the consumer using a “Lifeline Benefit Card” or similar approach (e.g., coordinated enrollment taking advantage of existing SNAP EBT cards and adding the Lifeline benefit to that EBT card). Eligible consumers could use the “Lifeline EBT Card” as a voucher to buy whichever communications service meets their needs from authorized and registered providers, whether broadband, wireline, or wireless voice service (on a standalone or bundled basis). For further convenience, service providers could offer Lifeline customers an automatic payment feature that allows low-income customers the ability to electronically activate their recurring discount, thus bypassing the need to visit a service provider on a monthly basis to swipe their EBT card.
4. Incentivize voluntary participation in the Lifeline program by cutting red tape.
Delinking the ETC designation from the Lifeline program would enable subsidy recipients to receive the complete benefits of robust competition that full service provider participation could offer. Removing existing regulatory roadblocks will make it easier for service providers to participate in Lifeline and incentivize them to compete for the purchasing power of Lifeline consumers.