National Association of Regulatory Utility Commissioners
National Association of State Utility Consumer Advocates
JOINT RESOLUTION
Requesting the Joint Board on Universal Service and the FCC to Increase Subscription to Lifeline and Linkup by Changing the Eligibility Standards and Subscription Process
WHEREAS, The National Association of State Utility Consumer Advocates (NASUCA) and the National Association of Regulatory Utility Commissioners (NARUC) recognize the national goal of universal telephone service;
WHEREAS, Many low-income families, including the elderly and many working poor Americans, do not have basic local telephone service due to such factors as the cost of service, the overall cost of living, and the availability and level of financial assistance programs other than Lifeline;
WHEREAS, NASUCA and NARUC strongly support the Lifeline and Link-Up programs, which are intended to enable low income customers to obtain telephone service through federal and state subsidies that make telephone service more affordable;
WHEREAS, the FCC in 1997 in its Universal Service Order ruled that under the federal regulations a consumer would be eligible for Lifeline and Linkup benefits only if the customer participated in Medicaid, food stamps, Supplementary Security Income (SSI), federal public housing assistance or Section 8, or Low Income Home Energy Assistance Program (LIHEAP);
WHEREAS, it is commonly accepted that some low income persons, particularly the elderly, are unwilling to participate in the public assistance programs that would make them eligible for Lifeline and Linkup programs;
WHEREAS, the shrinking rolls of public assistance programs due to welfare reform are reducing the number of consumers eligible for Lifeline and Linkup;
WHEREAS, consumer participation in Lifeline and Linkup, as well as overall telephone subscribership rates, would increase by adding level of income as an independent criterion for eligibility, independent of participation in other public assistance programs;
WHEREAS, a reasonable level of income standard is 150% of federal poverty guidelines;
WHEREAS, states that provide state support in addition to the federal assistance for the Lifeline and Linkup programs may establish their own eligibility standards;
WHEREAS, existing eligibility standards for this federal program vary widely among the states and Lifeline subscription is especially low in some states with narrow eligibility standards;
WHEREAS, a minimum federal eligibility standard applicable to the federal program support, with a waiver for good cause, would increase subscription to Lifeline and Linkup as well as overall telephone subscribership;
WHEREAS, the enrollment in Lifeline and Linkup programs would be increased by establishing automatic enrollment, whereby customers are automatically enrolled in Lifeline and Linkup when they participate in the public assistance programs that make them eligible for Lifeline and Linkup, with such persons being given the option of declining such enrollment and while establishing mechanisms for protecting consumer privacy;
THEREFORE, BE IT RESOLVED that NARUC and NASUCA urge the Joint Board on Universal Service (“Joint Board”) and the Federal Communications Commission
(AFCC@) to adopt rules for the Lifeline and Linkup programs that establish a federal minimum income eligibility standard set at 150% of federal poverty guidelines, which
standard would be the minimum for federal program support and with temporary waivers for good cause; and,
BE IT FURTHER RESOLVED, that NARUC and NASUCA urge the Joint Board and the FCC to adopt rules requiring telecommunications providers to use automatic enrollment, with privacy protections and the option to decline participation, for Lifeline and Linkup.
Approved by NASUCA: Submitted by:
June 19, 2002 NASUCA Consumer Protection Committee And
NARUC Utility Consumer Affairs Committee