As the only ecosystem-based organization focused on ensuring that low-income Americans have sustainable, affordable access to essential communications services, NaLA has submitted comments to the Senate Universal Service Fund (USF) Working Group focused on ensuring that low-income Americans have sustainably affordable access to essential communications each and every month. 

NaLA’s members include service providers, distributors, network access aggregators, compliance and software solutions vendors, device manufacturers, enrollment representatives, program supporters and beneficiaries invested in the future of the Lifeline and ACP programs. NaLA notes that wireless resellers play an important part in ensuring the success of these programs, including by serving over a third of all ACP subscribers.

The USF Working Group is seeking comments on the effectiveness of – and necessary reforms to – the programs funded by the universal service fund, which includes Lifeline.

Some highlights from the comments NaLA submitted:

• NaLA submits that with ACP funding set to run out as early as April 2024, appropriated funding will be needed at least until USF reform can be accomplished.
• NaLA proposes that either Congress and the FCC consolidate the Lifeline program with the ACP or reform both so that they better serve the goal of making essential communications services sustainably affordable each and every month.
• NaLA recommends that any future low-income program should incorporate key program design elements from the ACP, including a robust monthly service and device benefits, technology neutrality, reasonable benefit transfer limits, and a safe harbor and entry requirements that encourage competition that translates into compelling choices and value for eligible consumers.  
• NaLA maintains that program integrity can be preserved by conforming eligibility requirements and by reliance on the National Verifier which should be subject to continuous improvement and greater transparency.
• NaLA submits that the effectiveness of a low-income support program should be measured by whether low-income households have sustainably affordable access to essential communications services. Adoption is a secondary benefit that can be addressed only in part by a low-income affordable connectivity benefit program.

The full comments, including an executive summary, are available here.