Eligible telecommunications carriers (ETCs) must confirm an applicant's eligibility prior to enrolling the applicant in the Lifeline Program. Regardless of the method an ETC uses to confirm an applicant's eligibility for Lifeline Program-supported service (querying a database, receiving confirmation from a state agency, or reviewing an applicant's documentation) the carrier is required to retain documentation demonstrating subscriber eligibility, effective February 17, 2016.
Prior to February 17, 2016, carriers were not permitted to retain copies of documentation reviewed to validate eligibility. Previously, ETCs were only required to keep accurate records of the data sources used to verify eligibility.
Carriers can use the following checklist to establish procedures that comply with the FCC's rules.
- Retain a completed application for each applicant that contains the following information from the prospective subscriber (see 47 C.F.R. Section 54.410(d)(2)-(3)):
- The subscriber's full name;
- The subscriber's full residential address;
- Whether the subscriber's residential address is permanent or temporary;
- The subscriber's billing address, if different from the subscriber's residential address;
- The subscriber's date of birth;
- The last four digits of the subscriber's Social Security Number, or the subscriber's Tribal Identification Number, if the subscriber is a member of a Tribal nation and does not have a Social Security Number;
- If the subscriber is seeking to qualify under the program-based criteria – the name of the qualifying assistance program from which the subscriber, his or her dependent, or his or her household receives benefits;
- If the subscriber is seeking to qualify under the income-based criteria – the number of individuals in his or her household; and
- A certification, under penalty of perjury, that:
- The subscriber meets the income-based or program-based criteria for receiving program-supported service;
- The subscriber will notify the carrier within 30 days if for any reason he or she no longer satisfies the criteria for eligibility. If the subscriber no longer meets the income-based or program-based criteria, the subscriber is receiving more than one benefit, or another member of the subscriber's household is receiving program-supported service;
- The subscriber is seeking to qualify as an eligible resident of Tribal lands, he or she lives on Tribal lands;
- The subscriber moves to a new address, he or she will provide that address to the ETC within 30 days;
- The subscriber provided a temporary residential address to the ETC, he or she will be required to verify his or her temporary residential address every 90 days;
- The subscriber's household will receive only one program-supported service and, to the best of his or her knowledge, the subscriber's household is not already receiving a program-supported service;
- The information contained in the subscriber's certification is true and correct to the best of his or her knowledge;
- The subscriber acknowledges that providing false or fraudulent information to receive benefits is punishable by law; and
- The subscriber acknowledges that the subscriber may be required to re-certify his or her continued eligibility at any time. The subscriber's failure to re-certify as to his or her continued eligibility will result in de-enrollment and the termination of the subscriber's benefits.