Beginning in 2017, service providers must use a new process called "rolling" recertification.
For rolling recertification, service providers must verify each customers' eligibility to receive a Lifeline benefit by the anniversary of the service initiation date of their Lifeline-supported service. This means that providers will need to certify their customers' eligibility at different times throughout the year.
There will be a transition period after the current recertification process concludes, and before rolling recertification begins. Learn more in the FCC's Public Notice: Guidance on Rolling Recertification which was released on October 27, 2016.
USAC has created a sample version of the 2017 recertification form and subscriber letter for your reference. Please note that several states applied for and received waivers delaying the implementation of the streamlined eligibility criteria. In those states, recertification forms should be adjusted to reflect the current eligibility criteria.
The recertification process for 2016 remains the same as in previous years. For customers that a company claimed on their February 2016 FCC Form 497 that require recertification, follow the recertification process for 2016:
No recertifications for the federal Lifeline benefit are required for anniversary dates that fall from January through June, 2017, as service providers prepare for rolling recertification.
Starting with anniversary dates on July 1, 2017, service providers recertify customers according to their anniversary date. Service providers must initiate rolling recertification at least 65 days before the customer's anniversary date, and must de-enroll the customer by their anniversary date. For the July 1, 2017 anniversaries, service providers must initiate the process by April 27 (65 days before July 1, 2017), and must de-enroll ineligible/non-responsive customers by July 1.
Because of the transition period, the amount of time since a customer's last recertification will vary (see scenarios). Note that customers enrolled in January – June of any year, including 2016, do not need to be recertified until 2018.
Starting with anniversary dates on July 1, 2017, service providers recertify all subscribers according to their anniversary date.
The rolling recertification process is:
The "anniversary date" is every 12 months from the customer's service initiation date, or the date when their eligibility was last verified (see scenarios #5 and #6 below).
Service providers must recertify Lifeline customers' eligibility by their anniversary date each year.
Service Initiation Date
The "service initiation date" is the date the ETC begins providing the Lifeline-supported service to the customer.
Eligibility Database Query
The service provider (or other entity responsible for recertifying subscribers) must query any existing state or federal eligibility database to which it has access before it attempts to recertify subscribers using other means. If the query confirms ongoing eligibility, renew the service. If it does not, the service provider may contact the customer directly.
60-Day Response Window
If the service provider cannot confirm continued eligibility from the database query, the subscriber must be allowed 60 days to respond to recertification efforts. After the 60-day period expires, service providers must de-enroll ineligible/non-responsive subscribers within five business days.
These are some scenarios that may occur depending on when a subscriber is enrolled and when rolling recertification starts:
Carriers will still have the option of electing USAC to conduct the annual recertification on their behalf. To accommodate the rolling recertification, USAC anticipates changes to the recertification process beginning in 2017 and is reviewing the following elements of the recertification process:
USAC will share more information as it becomes available.
A1: No. Subscribers must be recertified on the anniversary of their service initiation date beginning with service anniversaries on July 1, 2017. The transition period from January 1 to July 1, 2017, is meant to give ETCs time to prepare for rolling recertification.
A2: No. The first time the subscriber needs to be recertified is June 15, 2018. Customers who initiate Lifeline-supported service in January-June 2016 do not need to be recertified until their service initiation anniversary in 2018.
A3: It is the date the ETC/LBP begins providing Lifeline-supported service to the subscriber.
A4: Yes, it will be, as long as the National Verifier is not implemented in their state.
A5: Yes. Customers that enrolled prior to December 2, 2016, using a retiring eligibility program can continue using their Lifeline benefit until their next recertification. Additionally, the 2016 recertification should be based on the current eligibility programs, not the new eligibility programs. Beginning with rolling recertifications in 2017, carriers should use the new eligibility programs.
A6: Yes. There's flexibility to batch subscribers, but the rules still apply to all anniversary dates within the batch. Further guidance about batching subscribers is under consideration with the FCC; we will update this page once more information is available.
A7: Yes. States can still choose to conduct their own recertifications for the federal Lifeline program until the National Verifier is in place. In conducting the recertification for federal Lifeline support, states must use the federal eligibility criteria for recertifications that start on December 2, 2016.
A8: For subscribers enrolled prior to 1/1/2016, use the "old" recertification process for their 2016 recertification. Existing customers that signed up in 2016 will have their first recertification in 2017. For 2017 and future recertifications, use the "rolling" process. Note that because of the "transition period," customers whose 2017 anniversary date falls in January – June skip 2017 recertification, and begin rolling recertification in 2018.
A9: There are no changes for the 2016 FCC Form 555 filing (due January 31, 2017). The FCC and USAC are currently reviewing the FCC Form 555 filing for 2017, and are likely to recommend changes. We will share more information when it becomes available.
A10: The anniversary date service providers need to use starting with the 2017 recertifications is every 12 months after the Lifeline subscriber's service initiation date. Not their birthday.