In July 2018, Q Link Wireless filed an emergency petition to the Federal Communications Commission (FCC) to immediately change how people submit eligibility proof documentation when they enroll in the Lifeline Program with an ETC online. The FCC’s potential changes will make the online eligibility and enrollment process more difficult, discouraging customers who need Lifeline phone and data services.

Online Lifeline Enrollment Using Third-Party Verification

Many eligible consumers like veterans, seniors, and the disabled rely heavily on the online sign-up enrollment process. Because of the new third-party verification systems being implemented, consumers will have to work through a government-run website and then repeat the process to enroll with a specific carrier. This two-step process is unnecessary, and if the consumer needs help with the verification process, he or she would have to find an in-person sales agent.

“The USAC’s proposed change will be unnecessarily difficult and confusing for consumers,” said Issa Asad, founder and CEO of Q Link Wireless in a press release. John T. Nakahata of Harris, Wiltshire & Grannis LLP (counsel for Q Link Wireless) added, “The new eligibility confirmation process will differ significantly for rural consumers compared to urban consumers.” He explained,, “Rural consumers who attempt to enroll online in the Lifeline program must use the National Verifier’s consumer portal. By contrast, someone living in an urban area can more easily get assistance from an in-person agent. This will disproportionately and adversely affect rural Americans eligible to receive Lifeline services.”

Sprint Comments on Q Link Petition for Online Lifeline Enrollment APIs

Sprint Corporation (Sprint) filed comments agreeing that the FCC should grant Q Link’s petition and implement Application Programming Interfaces (APIs) to consolidate the process to a single step. Sprint commented that APIs are essential for online enrollment and it will reduce costs for the Universal Service Administrative Company (USAC) National Verifier (NV).

Sprint says that because applying for Lifeline service in-person is not an option sometimes, APIs are critical for consumers who apply for Lifeline service online. Even with the assistance of a live agent, the process faces an uphill battle for consumers. “Without an API, a live agent cannot forward personal information provided by the consumer to the service provider to the NV, or receive information provided by the consumer to the NV; thus, the end user must enter his personal information twice (once to the NV for purposes of determining his Lifeline eligibility, and once to the ETC for purposes of applying for that ETC’s Lifeline service). This is not a user-friendly process and could discourage eligible low-income Americans from undertaking or completing the process for applying for Lifeline service.”

Cost Benefits of Online Lifeline Enrollment APIs

Not only will the use of API’s simplify the enrollment process for consumers, but it will reduce administrative costs for USAC National Verifier.

“The APIs will allow service providers to assist potential Lifeline customers in real time, including answering ETC-specific questions that USAC or other NV representatives cannot answer, and helping customers to submit a complete and legible application package. APIs will result in substantial savings in administrative and customer care expenses for the NV/USAC,” Sprint states in the filed comments.

Lifeline Providers work closely with potential Lifeline consumers to answer questions and ensure that their application is filled out properly. Lifeline Provider Assurance Wireless denies up to 75% of applications they receive because they were incomplete, incorrect or because the consumer was not eligible for Lifeline services. “Use of APIs will allow ETCs to continue to field many of the consumer inquiries, thereby reducing USAC’s costs of administering the Lifeline program and speeding up the eligibility determinations.”