Transfer Consumers in NLAD

Important News: On January 11, the FCC released an Order announcing the wind-down requirements of the Affordable Connectivity Program, due to a lack of additional funding from Congress. On March 4, the FCC provided further information in a Public Notice that announced the last fully funded month of the program is April 2024. Providers currently participating in the ACP are strongly encouraged to review the FCC’s Order and Public Notice, which set out requirements regarding the specific and frequent notices to enrolled ACP households about the end of the program.

Consumers enrolled in the ACP can choose to transfer their ACP benefit to a different service provider. When a consumer who already receives ACP service wants to enroll with a new service provider, that new provider should perform a transfer transaction in NLAD to enroll the consumer with their company.

Obtain Consumer Consent to Transfer

Providers seeking to transfer an existing ACP subscriber must obtain consumer consent either orally or in writing before each transfer transaction in NLAD. This consent must indicate that the household reviewed the required transfer disclosures and consents to transfer its benefit to the transfer-in provider. Documentation of the subscriber’s affirmative consent must clearly identify the ACP subscriber name, acknowledge the subscriber was provided the required disclosure language and that the subscriber gave its informed consent to transfer its benefit, and the date consent was given.

Providers must retain documentation or recordings related to the required disclosures and necessary consents for ACP benefit transfers consistent with the document retention requirements.

Consent is required for every transfer attempt, and providers may not rely on older consent given for a previous transfer. Each time a provider initiates a transfer-in transaction for an ACP subscriber; it must first provide the subscriber with the required disclosures and obtain consent.

Transfer Transactions in NLAD

Service providers can perform transfer transactions using the standard NLAD batch upload process, an API connection, or by using a National Verifier application ID. The consumer’s current service provider does not have to de-enroll the consumer or take other steps in NLAD for the new service provider to transfer their ACP benefit.

To protect ACP subscribers against uninformed or unwanted transfers, ACP subscribers are limited to one benefit transfer per calendar month, with limited exceptions.

Service providers are required to enter in NLAD the date and time they collected a consumer’s consent to enroll or transfer them.

• Consent Date Time: The date and time the consumer’s consent was received (e.g., yyyy-mm-dd hh:mm:ss)
• Time Zone ID: The time zone the provider captured the consent date in.

Refer to our Consumer Consent Fields bulletin and ACP field descriptions for more information. Service providers who attempt to transfer a subscriber who has already transferred once within the calendar month will receive an INELIGIBLE_FOR_TRANSFER: Date eligible for transfer: mm/dd/yyyy error.

Service providers can access a record of subscribers who transfer in or out of their company using the NLAD “Detail Transaction Report.” Service providers do not receive an email update when subscribers transfer in or out of their company.

If a service provider is transferring a consumer who received an ACP device benefit from another service provider, the service provider will receive a DEVICE_WARNING soft error when performing the transaction. This warning will not prevent the consumer’s enrollment or verification; it is intended to let the service provider know that that consumer is no longer eligible for a device reimbursement.

Transfer Exceptions

Consumers can exceed the one transfer limit per service month (which corresponds to calendar month) under certain exceptions. Providers must obtain confirmation from a subscriber before utilizing a transfer exception. Providers can obtain this confirmation via the Transfer Exception Worksheet or can use their own method to gather the confirmation, however, signature from the consumer, either electronic or on paper, must be obtained prior to performing the transfer exception in NLAD. Providers must obtain a new completed exception form for every transfer transaction where an exception is sought.

There are four exceptions where a subscriber can transfer service providers more than once a month. If a consumer is eligible for a transfer limit exception, the provider will use an exception reason during the transfer transaction. An exception cannot be provided unless the consumer is actually within the transfer limit period. The exception reasons and corresponding codes are:

• TE1 – Improper Transfer
  • A subscriber was improperly transferred due to the internet company not making the required disclosures or obtaining the required consent from their household to proceed with the transfer transaction
• TE2 – Operations Ceased
  • A subscriber’s internet company ceased operations or failed to provide service
• TE3 – Rules Violation*
  • A subscriber’s internet company violated the program rules and the violation impacts the customer
• TE4 – Moved Outside Service Area
  • A subscriber’s residential address changed to a location outside of your internet company’s ACP service area

*Note: The TE3 exception is not on the Transfer Exception Worksheet. Providers cannot use this exception unless the FCC or USAC directs them to do so.