 Hello, everyone. All right, it looks like everyone, oh, and there's the mics. All right, we're ready to go. Thank you all for coming today to listen to us talk about the Federal Communication Commission's lifeline program, which is the only federal program specifically designed to address the biggest cause of America's digital divide, the high cost of phone and internet service. Lifeline has been critical in connecting millions of Americans to these vital services, and we appreciate everyone taking the time today to come discuss the FCC's proposal from last year and why it's important that we collectively protect the lifeline program. So I'm Sarah Morris. I'm deputy director for New America's Open Technology Institute. New America is a non-partisan think tank in civic enterprise dedicated to the renewal of American politics, prosperity, and purpose in the digital age. Our experts here work on a wide range of issues from national security to the work-family balance, and of course, technology and telecom policy. And then the Open Technology Institute works at the intersection of technology and policy to ensure that every community has equitable access to digital technology and its benefits. We promote universal access to communications technologies that are both open and secure using a multidisciplinary approach that brings together advocates, researchers, organizers, and innovators. So a few housekeeping items before we start. First of all, just a reminder that this event is being live streamed, so when we move to our audience question and answer portion of the panel, just make sure to wait until you have a microphone. We'll have someone walking around with a microphone. That way your voice gets picked up and everyone watching at home or at work outside of this office can hear what you're asking. And because we have quite a few folks who I believe are joining us via live stream today, we are going to try to take questions from Twitter if there are folks online following along. So if you use the hashtag, which is hashtag save lifeline, ask your questions on Twitter, and we'll have a few folks monitoring that feed. And they can try to get your questions in towards the audience portion of our Q&A. And again, if you're tweeting along from inside the room as well, use the hashtag save lifeline for any comments and questions. So now turning to this All-Star panel that we have. We have Olivia Wein, staff attorney at the National Consumer Law Center, Yosef Getichu, the director of media and democracy program at Common Cause, John Heitman, partner at Kelly Dry and Warren, and Chris Shipley, attorney and policy advisor at Encompass. So thank you all for joining us today. I'm going to turn it to them to give a few brief opening remarks explaining why they're here talking about this issue and to present some of the key themes that we're seeing come up in some of the proposed reforms. So I'll turn it to Olivia first. Thanks, sir. Good afternoon. I'm Olivia Wein, a staff attorney at the National Consumer Law Center. The National Consumer Law Center is a nonprofit founded in 1969, originally as a legal services support center. NCLC focuses on consumer justice, economic security for low income consumers, and I work in the unit focused on affordable and reliable utility service. And before I go any further, I wanted to disclose that I'm also a board member of the Universal Service Administrative Company, USAC. You'll hear about USAC later on in the conversation today. But that I'm also not here today representing USAC. So my comments are not on behalf of USAC. I'm here today as a staff attorney for the National Consumer Law Center and a longtime low income consumer advocate and lifeline advocate. And I just wanted to sort of frame out why NCLC cares so much about the lifeline program. Voice and broadband are essential services in this day and age, and that's why the federal lifeline program is so critical. The current lifeline program provides a 925 a month benefit to help low income households afford voice, broadband, or a bundle of voice and broadband service. While this amount is a very modest sum, companies have been able to design products and services around the lifeline subsidy, many at no cost to marginalized, vulnerable low income households. Lifeline serves currently almost 11 million low income households, which is about 28% of the eligible. That's a rough estimate. Lifeline helps low income consumers access emergency services, which are particularly critical in times of natural disaster. Lifeline helps survivors of domestic violence rebuild their lives and stay safe. Lifeline helps families connect to medical professionals and educators. It helps veterans access telehealth applications and services and helps connect consumers to suicide prevention lines, as well as social services. Lifeline connects low income consumers to jobs and opportunity. It's available in every state and territory, and recently in 2016, it was modified to include broadband support. Affordability is a major barrier to continuous broadband service for low income households, and this is where lifeline comes in. NCLC has been active and committed to a strong lifeline program that helps low income households afford essential communication services. Great. Thanks. Thanks, Olivia. And then, Yosef, do you want to? Sure. Carry it on. Hi, everyone. My name is Yosef Kitachi. I am the director of the Media Democracy Program at Common Cause. Common Cause is a nonprofit organization dedicated to holding power accountable and infusing our democratic values in our policymaking. As part of our Media Democracy Program, we're focused on keeping our media communication systems open, independent, affordable, and diverse. So when we talk about media communication systems, broadband has become the essential communication system of the 21st century. And we at Common Cause strongly believe that access to broadband is critical to a functioning 21st century democracy. Broadband makes it capable for all types of communities to participate politically, civically engage, access government services, and voice their opinion. And what we've been seeing over the years is that there is a growing digital divide where millions of Americans can't access affordable broadband. Most of these Americans tend to be low income, marginalized communities, people of color, veterans, elderly, disabled. And these are the folks that can't participate in our democracy in the 21st century if they don't access to affordable broadband. And so the Lifeline Program is critical to helping close that digital divide by addressing the affordability gap and making sure that these communities have access to affordable broadband. And we at Common Cause strongly advocate for the Lifeline Program and oppose the FCC proposals, which we'll discuss about shortly. Good, John. Hi, everybody. I'm John Hyman. I'm a partner, Kelly Dry. And we represent the Lifeline ETCs, most of them are SME sellers. And we also represent the National Lifeline Association, also known as NALA. And they are an industry association representing stakeholders in the Lifeline community, including agents, distribution companies, phone manufacturers, and vendors who support the Lifeline ecosystem, as well as folks who depend on it, including some tribal entities and some consumers. Also represent, as I said, many carriers. Q-Link is among them. Q-Link's a unique Lifeline provider, I wanted to point out. They're unique because all of their enrollments are done online. And we're going to talk a little bit today about what some of the changes are going in the Lifeline Program mean to that business model. So thanks, Sarah, for having us. Today, I wanted to spend more time talking about what is happening under Lifeline under Chairman Pai than what isn't happening. I think what isn't happening, in my estimation, is a wireless reseller ban. And we can talk more about that in coming up. But I think that ban, in my estimation, is on hold. But we do have it as part of the tribal Lifeline rules, which we are glad to have been part of the legal effort to get stayed last August. That case is still pending. And we also see that reseller ban come up in different ways. High cost, excuse me, in the rural health care program. It's an element of that pilot program. So it's, in my mind, a harmful concept that we need to be vigilant to push back against. Also want to focus on the program shrinking. Olivia mentioned some statistics about the program. Our statistic suggests the program has shrunk 30% under Chairman Pai's watch. And it's set shrink by at least another 30% with the role of the national verifier. These are alarming numbers. And I hope today we can talk a little bit about why the program is shrinking. I'll give you three reasons in my mind. Regulatory uncertainty. Very hard to attract investment into this space, which is necessary for providers to provide service and get handsets, like smartphones in the hands of consumers. Minimum service standards and other regulatory changes that are, while well-intentioned, I think are having an adverse impact on consumers. And we can unpack that a little bit, I hope, later on. And the national verifier rule out complicated, but I'll point to two different things that are impacting consumers today. One is something called re-verification. As consumers are put into the national verifier, they are getting re-verified. And that is causing problems the manner in which they're going about doing it. And also, the change in the national verifier, because the national verifier lacks an API connectivity for carriers, carriers are reluctant to use it. And I can explain why and get into that deeper later. But I do think that the national verifier where it has been implemented has worked to move lots and lots of people out of the program who I doubt are ineligible. I think they are eligible and has made it really difficult to get people back into the program. So with that, I'm looking forward to the conversation today. Thanks so much, John and Chris. Yeah, thanks, Sarah. I appreciate you having me. Appreciate the opportunity to be here and apologize a little bit for my voice. It abandoned me on Saturday, and I haven't been able to get it back to the full extent yet. I'll try to manage it as best I can. Apologize if I'm brief in some of my remarks. But you know, Encompass appreciates the opportunity to be here. It always seems like a new administration is always looking to tinker with lifeline a little bit, and so we're happy to kind of provide our perspectives on some of our concerns with what's been proposed in the commission's current reform efforts, and then also to give our perspective on what could be done to sort of bolster the program going forward. Encompass is the internet and competitive networks association. Really competition and innovation are our mission, and we represent a number of competitive service providers, lifeline providers, both facilities-based and non-facilities based that provide voice and broadband services to eligible lifeline subscribers. We're talking about to the elderly, to veterans, to job seekers, low income consumers across the country. And Lifeline really is a program that's always been driven by competition. Really competition has helped drive innovation and affordability in the Lifeline program, and it's one of the things that we think needs to be preserved in the commission's 2017 proposals. Encompass is mostly concerned about the FCC's proposal to discontinue the Lifeline subsidy to non-facilities-based providers. Really, in addition to losing some of the cost savings benefits of competition, there's really no guarantee that's been provided that a lot of the big guys, the incumbents, the facilities-based providers that have left Lifeline, will re-enter the program and take up service where non-facilities providers will be sort of forced out. And I think as others in the panel have kind of addressed, this leaves families and, more importantly, job seekers in danger of losing some very critical services. Lifeline really began to reach an increased number of eligible consumers and eligible subscribers when competitive providers, mostly non-facilities-based providers, were allowed to enter the market and then compete in areas of targeted service packages, in price features, and then also in service quality. And so the first rung of any ladder is always critical. And competition at that first rung really drives down costs and encourages better customer service. Because the goal of most of these providers that do provide Lifeline is to stick with these subscribers as they get jobs and continue to need low-cost affordable service as they start to make their way towards a better future. So in addition to that first concern about the commission's discontinuance of support to non-facilities-based providers, we also have concerns about the self-enforcing budget that the commission has proposed. We're concerned about the commission's desire to leverage the Lifeline subsidy to build new networks. And then also, we believe that the commission should move quickly to fully implement the national verifier and to sort of set it up with real-time capabilities that allow for real-time eligibility verification and then to work collaboratively with industry to address concerns over some changing policies and some changing standards that USAC and the FCC have sort of set up for the program. Great. Thank you, Chris. Thanks, everyone, for that helpful context. And I think we're so fortunate to have this panel of advocates who have worked on this issue and been in the trenches for years and in some cases, I don't know, decades, Olivia. But for the folks in the room who maybe are less familiar with how the Lifeline program works, I think it might be helpful to kind of unpack this both from the consumer side. What does it look like for a consumer currently, a household, a low-income household that needs subsidized communication service? And then spend a little bit of time sort of unpacking how the market works and what we mean when we talk about facilities-based providers and non-facilities-based providers. So perhaps Olivia and Yosef, if you could start just sort of walk us through briefly what how the program sort of administrated from a consumer perspective. Sure. Happy to do that. Lifeline, as had been mentioned, is a program that has been evolving over time. So originally in its original incarnation, there was a lot of variability from state to state and even within a state from carrier to carrier, the amount of the benefit, the eligibility criteria, and so forth. Over a series of fairly recent orders, 2012, 2016, things have become more uniform. So right now, there's uniform eligibility criteria across the states and territories. There is a uniform benefit amount that you, as I had mentioned before, that varies, the 925 a month, unless you are eligible for the Tribal Lifeline subsidy, which is an additional $25 on top. One of the key changes, which you've heard the word national verifier, that came about in the 2016 order. Although sort of its roots are much older. The Lifeline advocates have been advocating for a long time from a consumer point of view that applying for Lifeline should be easy, should be streamlined, should be quick. And to the extent it could be automated, it should be automated because there are two ways to become eligible for Lifeline. One is to be a participant in one of five programs, Federally Subsidized Housing, SSI, Medicaid, SNAP, and a low-income Veterans Pension Fund. And there are some unique tribal eligibility programs. But let's set those aside for now. So if you participate in one of those five programs, the hope was that you could create a system where there could be a sort of a database ping. You would be able to check that database to see that you are currently a SNAP recipient, and that yes-no ping would make you automatically eligible for Lifeline, same for any of the other programs. The National Verifier sort of tasked to USAC the creation of a national process, manual and automated, to handle the eligibility verification. As I had mentioned, initially, when Lifeline was first created, the carriers took care of the applications. So we are in the midst of transitioning over to the centralized national eligibility verification process. And 12 states, one territory, or 15 states in one territory, I believe, are in this new land. And four additional states are in the soft launch, as we say. And they're about to also enter. By the end of this year, all states and territories should be using this new process. So this will be the new process moving forward for all consumers. You would apply to the centralized location or your carrier could help you apply to check for your eligibility status. I said it was a process. So there's a manual application component and an automated database ping component. In some states, and it will vary, there are certain databases that they've already set up data matching agreements, and they can automatically check and see if you're participating in one of the qualifying programs. But where those database matches have not been established, it is a manual process, which looks a little like the old process that maybe consumers are somewhat familiar with, where you would have to submit some documentation demonstrating current participation in one of the qualifying programs or submit proof of income eligibility. I've lost track of the question in describing the national verifier. The national verifier is a very important part of what's happening right now, and one that I expect we'll talk a lot more about as the conversation goes on. So if I'm a consumer and I'm looking to acquire a lifeline-supported service, do I go to my phone provider? Do I go to the FCC or USAC or some other process? So it'll depend on whether you fall into a state that has been rolled into this national verifier process, and we'll go into a little bit more detail about that experience, or you're still using that old process where you would go to your carrier. You can, in both scenarios, go to your carrier and your carrier can help you enroll or either be responsible for your enrolling, depending on, again, which world you're in right now. The goal here, again, as I said, is a process that's easy to understand for the consumer. So the application form is now uniform. There's no variation for states and territories carrier to carrier. They have to use the same application form. The annual re-verification form is also a uniform form, and then there's another sheet called a one per household sheet. So actually, once we get into a discussion on some of the Fraud, Waste, and Abuse measures set up, we can talk about duplicates and so forth, but let us say that there's an application process. The National Verifier also provides an online portal for consumers in those states so that you can apply directly to see if you are eligible, and if the state you live in happens to be one where there's the database matches set up, it could be a fairly instantaneous snow, or it could be a process where you're going to need to either upload documentation through the online portal or mail your documentation to the centralized National Verifier, USAC. Great, thanks, Livia. So now we've heard a little bit about what it looks like from the consumer's perspective, but it's also the case that there has been new types of markets that have grown to respond to sort of the structure of the Lifeline program generally, and to provide somewhat, I would say targeted services designed for low-income households. So maybe Chris and John, if you wanna talk a little bit about what the market looks like for the different types of services offered by Lifeline and how those play out. Sure. Go ahead, John, please. I'll give it a go. Over 90% of the program today is wireless, and so over the course of time, beginning roughly at the time of Hurricane Katrina, the program began to shift toward wireless services, and so what had happened is the wireless carriers were creative and innovative, and they began to calibrate products that were designed to match the subsidy. So rather than being 925 off your home phone service of $20, $30, $40, and you have to come out of pocket for the rest of it, the wireless providers introduced programs where you would have to come out of pocket for none of it, and so they had free programs. Basically, the benefit that you got was somewhere in the range of $10 to $13.50, a legacy provision of service, and so the service was calibrated to the amount of the benefit. The providers also, in many instances, would give the consumers a free handset, and that handset is, they're able to do it because the projection is that over the course of time they will make their money back on that investment. Nobody makes money on giving a handset out to a consumer and getting 925 back. You have to keep that consumer over the course of a period of time in order to make the business case to actually put a handset in consumers' hands. Over the course of time, it began, a lot of refurbished handsets in the marketplace. Today, mostly new handsets and mostly smartphones, and that's where the market has evolved. It used to be something like 64 minutes, and now consumers get, it varies, but generally 750 minutes or they're getting a gig or two gigs of data. It depends, often, most often, it gets some sort of bundle, and we can talk about why it's a voice-centric bundle versus a data-centric bundle when we get into minimum service standards, but we'll be giving you a shot at that. Oh, I just wanted to say, and point out, that we're talking really about, we're talking about lifeline, you end up talking about a symbiotic relationship, I think, between what we mentioned earlier was facilities-based providers and the non-facilities-based providers, and I think unpacking that, I think, is important. And when you're talking about facilities-based providers, you're talking about providers that have deployed network elements or network infrastructure, and when you're talking about non-facilities-based providers, you're talking about those wireless resellers, those companies that have worked with some of the facilities-based providers to lease some of their network elements in order to use some of their excess capacity to reach some of these subscribers and turning that excess capacity into a business case to reach some of those subscribers. And so, clearly, if we want to go all the way back, lifeline was a Reagan-era program that at the time was a sort of a fixed wire line, a sort of home phone program that, as John has sort of pointed out, particularly following Hurricane Katrina, has really transitioned to wireless. And then in 2016, the commission decided to add broadband to that particular component. And so, but when it comes to making a business case for lifeline, it really is the competitive providers, the resellers, the non-facilities-based folks that have seen an opportunity and have figured out a way to kind of make it work. And I think non-facilities-based providers at this point provide over 70% of the wire line service, of the 90% that is wireless. And so, when you're starting to talk about taking one of these groups of competitors out of the market, and especially one that's providing 70% of the service, then you're really talking about making dramatic changes to a program that is critical for job seekers and for a lot of low-income consumers. You have a couple of examples of what a facility stays to writers. Let me try and address that. AT&T, there are four major network providers still in the United States. You've got AT&T, Verizon, Sprint, and T-Mobile. And all four of those providers voluntarily resell their services to lifeline wireless resellers. Voluntarily, it's not compulsory. There was a compulsory wire line resale provision, I think, still in the statute kind of, right? And for the most part, this program is a wireless program. Those four providers are happy to resell their services to these wireless ETCs who don't own these network provisions. Why are they happy to do it? Because they're not particularly good at serving these low-income consumers. They are consumers that tend to not be able to put a credit card on file, so you can auto-pay. They tend to have problems paying a monthly amount because sometimes they don't have a monthly paycheck. They have a paycheck one month, but maybe not the next. And so they also tend to, for a variety of reasons, the studies showed they spent a lot more time on customer care lines and eating customer care, so they are higher cost to serve, many of them. And so there's a reason why a company like AT&T, who reports to Wall Street as average revenue per unit, and it's spectacular, right? It's a big number. Doesn't want to bake in a number that's 9.25 or less into that statistic. So there's all sorts of market dynamics that suggest that why wireless resale is happening. The network providers have the capacity, they're happy to sell it, and they're happy to get that revenue, but they do not want to incur the expense of serving this customer or the risk of serving this customer. And the regulatory risk of serving this customer is exceptionally high. And the regulatory expense of serving this customer is exceptionally high because of audits, investigations, and all sorts of things, including implementation and compliance, and interfacing with USAC and the USAC's National Verifier, which we can, of course, get into more. But that's, hopefully, address some of your questions. I think, oh, go ahead, Chris. Just real quickly, I want to add to that, just in that the relationship between the two, particularly when a wireless reseller is buying excess capacity from a facilities-based provider, that's a revenue stream. And an important revenue stream that's sort of being used by a lot of these facilities-based providers on broadband deployment projects. And to lose that, I think, really is something that we're seeing in the record, at least, is something that folks are, that there's a serious concern about losing that particular revenue stream between the two. And you get the revenue stream that it's also at the near-end. The equation, right? If we're selling lifeline services and we have lifeline subscribers, where do they live? Well, they live in low-income communities. And so if you add traffic to the network in low-income communities, you build out the business case to add capacity to the network or upgrade the network. You go from 3G to 4G. And so unless you have that traffic, the major carriers are not going to upgrade as quickly there. And the same can be said for rural communities, poor rural communities, tribal areas, for example. If you can get more people on the network, the business case then becomes more tenable to do things like upgrade and add repeaters or add additional cell sites or small cell sites. I think, sorry. Go ahead. Just to take it back to the consumer perspective, Commission has actually acknowledged all of these technological changes in the market over the years, where they've expanded the program to include wireless providers, to include resellers, to include broadband in 2016 to make the program as robust as possible. And going to the proposals now where we're thinking about eliminating the resellers, these are the actual carriers serving the low-income communities that John mentioned, the ones who don't necessarily have a bank account or good credit history or are suffering from disabilities or other types of harms, that they would need affordable services like that. And it's not the carrier, the wire line or the facilities-based carriers who are actually deploying in these areas or have any incentive to provide services in these areas. It's the resellers who have actually developed the relationships, the customer base and the credibility to actually provide service to these communities. So to add on to what everybody's been saying, a concern for the low-income consumer advocates is also when you look at what's happening in this sort of lifeline universal service marketplace, you have seen filings in 2017, in particular, for example, like AT&T stepping away from the universal service programs in the States, filing and announcing that they will no longer be providing or participating in lifeline. So the question would remain, if you remove the providers of 70% of the marketplace and the wire line have been leaving, sort of pointing to the resellers saying it's a competitive marketplace, who is left to guarantee that low-income households will be served. So that is something that we're very, very concerned about because you could have an end result of pockets, large pockets of unserved consumers. And these would be people who would not have connectivity in a natural disaster or all of the opportunities that would be denied to them because they would not have the ability to get affordable lifeline service. That point that you just made was an important point that came out in oral arguments in front of the DC circuit with regard to the tribal lifeline rules. Now the FCC has already adopted a facilities requirement for tribal lifeline. That was stayed in August. We had oral arguments in October, but the judge, the panel, did ask the FCC's lawyer, well, who is going to serve these customers if the resellers are gone? And the answer was maybe nobody, we're unsure, we don't know, but hopefully somebody will come in. I don't know that the judge is particularly impressed by that answer, but that was the answer, we don't know. And it doesn't look like anybody is going to come in. Yeah, I think to summarize, you have people, there's a very clear demand and need for broadband service and for phone, particularly wireless phone service. And critically, no entities to meet that need, but for this market of wireless resellers that has emerged as sort of against the backdrop of the lifeline program. And what the commission is proposing to do in its proposal that it released last spring is to remove from the lifeline program the providers that are actually providing service for that close communities. When we, so we've been, we've mentioned the national verifier and Olivia gave some context as to how and why that those reforms, that new portion of the program came about. I know others, particularly John, has some concerns about the verifier. And so I think we might as well just dive into that issue and talk a little bit about the dynamics at play there and what improvements might help make that process go more smoothly for consumers. I'll start, I'll frame out two issues and hopefully we can have a little bit of a conversation about it. But the national verifier, I look at the problems two different ways. One is in the process of launching the national verifier, they're going through something called re-verification. And so that is re-verification of all those folks who are in lifeline today and making sure they're eligible. When I read the order in 2016 about re-verification, what I expected was that they would, upon implementation of the national verifier, they would dip the databases that they got access to. And for those subscribers that they couldn't replicate in a database, they would go out to carriers and to the subscribers themselves, but mostly to carriers to get whatever proof of eligibility the carriers had on file. Since 2016, the carriers, February 2016, the carriers have had to retain a copy of this proof of eligibility. My thinking was that they would just provide a copy of that to the national verifier. If the customer was enrolled prior to that, since 2012, 2013 probably went into effect, they've had to re-certify their eligibility every year and these carriers keep records of that re-certification. So it was my thinking that a record of a re-certification or a documentation of proof of eligibility, program eligibility or income eligibility should suffice this re-verification process. But that's not how it's worked out. And so what has happened is you've got the national verifier launching in states with, in my mind, most states with inadequate database access. So far they have two states they're launching in where they have access to Medicaid and SNAP databases. Those two programs account for over 90% of Lifeline enrollments. If you are missing one or both of those databases, in my view, you should not be launching a national verifier in that state. You will not get to match most of the subscribers in the program. You're setting yourself up for failure. Secondly, they decided that if the proof that you had on file was older than 2018, it was unacceptable. You had to then make the consumer provide new proof that you had to make the consumer reapply for Lifeline and jump through an eight-page application. While standardized, it's daunting to a consumer. It's eight pages long. It has a lot of certifications on the penalty and perjury and the like. And so it's a process that doesn't lead to much success because lots of these subscribers are signed up at events. They're signed up because these Lifeline providers will go into communities, they'll go onto a tribal reservation and send a team out to collect information and to enroll people. And then they leave, right? And the support is on your phone, dial 611. The Lifeline program rarely is robust enough to support a retail footprint. It supports a retail footprint in a state like Oklahoma, which is a widespread tribal support, and in a state like California, which is a very robust state program. So these consumers don't necessarily have a retail location to go in and say, well, here's my proof, right? They've got to figure out how to upload it. Not easy for a lot of people figuring this out. Not easy for a lot of people to get to the internet to do it. They also have to mail it. Well, it's not easy for them to make a copy or get a stamp or get an envelope and do all that. So what we're seeing is a lot of fallback. And so that process, what does it lead to? In a state like Colorado, 30% of the people in Lifeline are going to get kicked out of this program, 30%. That's a good scenario. That's a state that has access to Medicaid and SNAP database. Flipside, Wyoming, 97% of the people in the Lifeline program are going to lose service in the next month. 97%. Most of them live on the Wind River Reservation. You know, anything about the Wind River Reservation, it is unlikely they're not eligible. So that's a problem. And what happens to these people once they're kicked out of the program? It's very hard to get back in, because the National Verifier has been set up without an API. So carriers cannot actively help these consumers through the process. It's a blind process to the carriers. And with the regulatory risk and enforcement risk in the program, they're not willing to accept a blind process, because the commission has been perfectly clear the National Verifier will not be a safe harbor. So we can't trust the National Verifier unless we see what's going into it. And right now we have no way to see it. And consumers, I mentioned Q-Link before, consumers have no way to enroll online. Q-Link can, you know, one thing that Q-Link does really well is to help consumers navigate this process. No, that is not adequate proof. No, that's not going to work. This is a problem. We need to have proof of your identity. It's a challenge to get these people through this process. It takes time, but without an API, we can't get through that process. It's like you'd have to go, even there's a service provider portal, where agents can help consumers through the process, but the carriers can't monitor that. So they're very reluctant to use that process. And otherwise what you have to do is send the consumer and say, good luck getting through that process, and please come back to me. This is if you filled up your card at Amazon, right? And then Amazon told you, OK, go to the bank, key all that information in. Get a code that says you can pay for it and then come back to me. How many of you would do that? Nobody. So it's terribly flawed in my estimation. And I think that's the thing that's been the most frustrating for our members that do serve lifeline customers is that the answers to some of these questions are there. API, this sort of application program interface, is a sort of regularly applied product in a way that our members interact with other folks and can sort of do database dips and things along those lines. Everyone is for using a neutral third party to determine the eligibility of lifeline applicants. But if the way that the National Lifeline Eligibility Verifier is going to be rolled out, if it's like this, I think the way that our members have talked about it is it's been far from flawless for the reasons that John sort of was talking about. APIs are something that these providers are accustomed to, that they use on a daily basis. Their Q-Link wireless, who John mentioned earlier, has a petition at the commission that has been sitting dormant and pending for months to require this machine-to-machine capability, this ability to do real-time eligibility verification. And that's frustrating. I think mostly just because I think industry wants to collaborate with USAC, they want to. They're accustomed to doing this kind of verification. And they feel like they're not being allowed, or that the goalposts are kind of moved on a regular basis. I want to come back to how we might solve that. But I'm mindful of time, because I want to make sure we have a lot of folks in the room, and I want to make sure we leave time for audience questions. I have many questions left. I'm going to answer maybe one or two, and then we'll turn to the audience. And then I'll ask a few to wrap up. But one thing we've sort of alluded to in some of the introductory remarks and some of the answers so far is this issue of waste, fraud, and abuse. This is something that folks who have been following the lifeline modernization proceedings have, I don't call it a buzzword, but it's a phrase that we've heard quite a bit as an ongoing criticism of the program, this notion that the program is rife with waste, fraud, and abuse. And some even say that the Lifeline program is worn out. It's welcome, that it's no longer useful, and that we should just wipe it out and replace it with something else. So can we talk a little bit about waste, fraud, and abuse? Is this still a problem? Is it a big enough problem to justify just wiping the slate clean and starting again? Sure. So, yeah, you hear this phrase, waste, fraud, and abuse all the time with the Lifeline program. I feel it's unfortunately stigmatized the program when it's not as big of a problem as some of its critics make it out to be. We've talked a lot about the National Verifier, which is one of the biggest ways that these implications of waste, fraud, and abuse would get weeded out. But even before that, the FCC was constantly making reforms to the program to take out some of the claims of waste, fraud, and abuse. So one of the aspects of the program is that its eligibility is based off one household. And so if you're in a household, you get access to Lifeline, no matter how many individuals are in there. So there was a lot of claims about duplicative processes, multiple people in a household getting access to this. Well, the FCC has actually addressed this through different proposals to eliminate some of these harms associated with duplication processes. In addition to that, I'll just say that the FCC's proposals under the current administration don't do anything to actually address waste, fraud, and abuse besides a couple of audit reforms. But eliminating the resellers, the budget cap, these don't actually address the harms that critics associate with the program. And I'd like to build on what Yosef was saying. So as was mentioned, Lifeline has been an evolving program. So this 9.25 a month program has lots of procedures in place. So Yosef mentioned duplicates. There is a National Lifeline Accountability Database to check for duplicates. The way billing is handled now, instead of carriers submitting a form saying I have this many customers a month, they're using the NLAD as sort of the point in time how many customers are being served by each carrier. So the USAC determines the reimbursement amount based on the NLAD data. They've set up processes to do the identity authentication. So when you apply, there's several things going on when you are engaging in your application. They're doing the duplicates check on you. They're doing a third-party identity verification. They're checking you against, I think, Social Security has a database of deceased persons. So just making sure that you are actually alive. You're a real person. So there are these systems that are being put into place. The National Verifier takes the eligibility determination out of the hands of the carrier, puts it into this centralized entity, neutral entity. So while that is an important fraud, waste and abuse issue, what we're seeing actually is not that we've got problems with fraud, waste and abuse, but I think some of the things that John has been raising are actually perhaps an overabundance of caution going the other way, which inadvertently are creating barriers of entry now. To be super, super sure, super, super safe, that you are actually eligible seven ways till Sunday before you get to go in. I think they have gone overboard. I agree with that. I think they've gone. They've flipped the scales and lifeline a couple years ago. Two to 3% in proper payment rate. And then it spiked to 21%. But USAC was very candid in saying why it was so, because any time USAC found a discrepancy with the lifeline form, it found it in proper payment. So 19% of that was form-based. We now have a unified form. So no one's quibbling about what's on the form, whether it says under penalty or perjury. That was a favorite finding. You didn't say it enough times, because consumers don't understand it the first time you need to see it four times. You don't say it in the right places. So that's been resolved. So again, most of the problems that people pointed to have been resolved. And you're always going to have a degree of rice thrown abuse in a government disbursement program. And so lifeline has typically traveled at a rate that is relatively low compared to many other government benefit programs. So I think that they have made many improvements designed to address real and perceived rice thrown abuse most recently by including in the identity verification, which is something USAC has been responsible for since 2012, part of the NLAD. Only in 2017 did they include the dip of the master death file. And so we improve as we learn and the program involves. So I think we have to be vigilant on waste-fraud and abuse. But that is not the key problem for the program. Is it fair to say that the program is underutilized currently based on who is eligible for participation? I think that was the point that I wanted to make was just when you start to look at how the commission has worked since 2012, really just sort of rein in this waste-fraud and abuse argument. I mean, you've seen a program that's gone from $2.1 billion down to $1.5, and that's not an insignificant amount of money. That's naturally not the answer. That's after they put in all of, as my panelists have sort of talked about, as they've put into effect all of those different reforms for the lifeline program in terms of verifying that's the kind of reduction in the budget that you've seen. And as Olivia pointed out, I mean, you have an undersubscribed program that, if I remember correctly, I think you said it was 28% of eligible lifeline enrollees have signed up for the program. And so I think that's where, to the question of, is lifeline still a valuable thing? I think the answer is absolutely. And let's not throw the baby out with the bathwater to be indelicate as we try to use the tools of the FCC, of USAC, of the Enforcement Bureau to rein in waste fraud abuse. I think that there is a balance in any implementation, any program design between sort of ease of entry and the controls, the program integrity controls. And what you're seeing is a program that is sort of swung along this pendulum one way or another. And we're looking for that right balance. I don't think this data should be interpreted to mean that people don't want lifeline benefits. I think it could be interpreted to mean that perhaps there have been inadvertently additional barriers put into the process and in terms of the marketplace because of the regulatory uncertainty, sort of maybe whereas we were hoping for a constant, robust series of products that consumers can choose from, there's sort of like a wait and see what's going to happen. It's hard to invest in this space with this amount of regulatory uncertainty. So you're not seeing products evolve other than to meet different changing service standards. But I think to your question, Sarah, about where the program's one-ounce utility, I would say not. And I think that those people worry about whether the lifeline's program is serving the truly needy. Well, the eligibility triggers for the program suggest, yes, it is. You're truly needy if you're in SNAP and Medicaid. You're not living well. And some of those folks who say, well, I've seen people sign up for lifeline and they have a phone. Having a phone doesn't mean you actually have service on the phone. It doesn't mean you have service on the phone today. It doesn't mean you'll have it tomorrow. Lots of people have phones. What they do is they come in and out of connectivity. And because they can't put a credit card on file, they don't have reliable service. And if you happen to have one cell phone connection to your family and you have more than one person, I would submit it's not enough connections because these days in America, how many families? I have a family of five. We have five phones. And that is the norm. I do want to make sure we circle back to voice, broadband, and minimum service, which is, I think, an area ripe for discussion, particularly among the various panelists here. But I'm going to ask one quick question, though, in the meantime, and then turn it to audience questions, and then we'll come back to minimum standards and voice and broadband. We mentioned early on, when we talk about some of the reforms and the problems, we've talked about the cap to the program. And since we're talking about underutilization and waste fraud and abuse, I think it's helpful to talk about what, as Yosef points, Yosef mentioned that the proposal on the table from the FCC would not actually address waste fraud and abuse. And you mentioned the cap. So let's talk about what the cap, and there's really two caps. There's the lifetime benefits, the individual cap, and then the programmatic cap. So I don't know if I should take it. You want to take it? You're better at that. OK. One of the proposals, they didn't give a hard number. There wasn't a hard number in the notice of proposed rulemaking, but would cap the lifeline program amount. It was also unclear whether or not, if the cap were hit mid-year, what happens? Does everybody's benefit amount change? Is there a hard stop in certain places? I mean, there's just a lot of questions. It raises more questions about how that could happen and not be super disruptive. It seems clear that the range that they're talking about is somewhere between 800 million and 1.5 billion. And that would, when you're looking at the importance of connectivity in this day and age to help people access emergency services, especially in times of crisis like natural disaster or 911 to get a job, all of these critical things, to make other benefit programs operate better, health care. How do you take care of a patient and a family when you see them in the emergency room but then cannot reach them for the follow-up care? Things just become more expensive and less efficient. Continuous connectivity is very important. Universal services is a very important concept. Lifeline addressing affordability is that key piece that we're talking about here. And then the individual cap was in the notice of inquiry. So they were throwing this idea out to see what people thought about putting a maximum amount on anybody's ability to use lifeline. So for example, if in your 20s you fell upon hard times, got injured, lost your job, needed lifeline to help pull your lifeline, life back together, and then hit your cap. But then now you're a senior, perhaps you got a disability. You really do need that connectivity to stay in touch with your health care provider and your loved ones, but you can't access it anymore. So I mean, it's a problematic sort of concept. One that sort of doesn't factor in real life and sort of the vicissitudes of life and bad luck happens. It seems to require a lot of administration. Like when we talk about hurdles and administrative costs, like tracking someone's lifetime usage after their name may change when they get married or they may move to another state, like keeping track of that. That seems to me like a... Sorry, I guess I'm taking off my moderator cap there briefly, but has always seemed like a problematic aspect of that. That is the most absurd thing because then you would be creating a lifetime database. You would be tracking a lifeline recipient until the day they showed up on that social security death file and you could take them off. I just want to chime in on the program cap. The program cap, of course, has been something that's been controversial. And on behalf of the Industry Association, we actually filed in support of the cap and it's a qualified filing for sure because we certainly don't want to see the program rolled back. But what we do see is a lot of folks who are critical of the Lifeline program, particularly Republicans on Capitol Hill, their criticism of the program is not the program conceptually. It's subject to uncontrolled spending and they just want to know what it will be at. And so what we proposed, and we actually see Brad Ramsey in the back of the room, we endorsed a NAIRUK proposal. NAIRUK, in a session I think it was about a year ago in February, seems like commissioners got together, Republicans and Democrats alike, and agreed on something. They agreed on a resolution that asked the FCC not to adopt a reseller ban, but also said that they should convert the current budget mechanism into a cap. The current budget mechanism set at $2.25 plus billion. And if you convert that to a cap in the ideas, then you have some certainty. Well, what happens if we go beyond $2.25 billion? Right now we've got about $1 billion of room to grow. Well, if we grow that much, we succeed in getting 60% of the people on the program, then we can revisit the issue, right? It doesn't mean people should be denied service or we should be able to say to somebody, I'm sorry, we're out of money, it's October, come back in January. Too bad you just lost your job. It can't work like that. But it means, for us it was a way of diffusing criticism about the program while providing a more thoughtful approach to how we can address things should be fortunate to come up against the cap of $2.25 billion. Because if we do, then we're reaching more people and we're getting up to 60% participation program, which is where we would hope we would pick. I also think it would be interesting, I mean just to sort of see where the 2016 order takes us and that the 2016, you know, lifeline reform order included that budget mechanism to address the $2.25 billion cap. And we haven't been in a situation where the commission has had to sort of consider going over the cap itself. And so let's let the 2016 order play out in terms of that, in terms of seeing how the commission can address lifeline funding if it does end up going over that potential cap. Let's let that process play out, at least for the time being. All right, let's hit some, thank you, thank you all. Let's hit some audience questions. Who, anyone, anyone that's sitting here? Oh, we've got one back here in here. Hi, thank you, thank you for this great panel. John. Oh, and if you could say who you are. I'm sorry, I'm Mark Rubin with Track Phone Wireless. Excuse me. John, if you were going to suggest to congressional staff if they were planning an oversight hearing on to the implementation of the verifier, what one or two questions would you suggest that they ask? I think I would ask questions about the performance of the verifier. What is the impact of the verifier? How many people actually are getting removed from the program because of the re-verification process? What are the percentages and how many people are getting affected? And is that within the realm of what you expected? And also in states that are now you have to go through the national verifier, what's the impact? In Colorado, I know that 500 people got signed up in Colorado for lifeline through the verifier in November. Cue inquiries alone signed up 5,000 people in September of this year. That's one carrier versus, so let's think of the difference there, right? So what is the impact? I want to see numbers. And so we can hit the, everyone is in support of the national verifier. People like the idea of having a third party verify identity, verify eligibility. But in my mind, we should use the first couple of states that we've gotten and hit the pause button so we can understand why, why some of these outcomes are happening. For example, we hear USAC is conducting a cost benefit analysis. And that is the reason why they're not gonna build into the Medicaid and SNAP databases in certain states. These states tend to be rural states, by the way. So I see a divide here where these rural states are getting no database access, which means we're gonna get basically eliminated from the lifeline program. We need to revisit the cost benefit analysis because if the outcome is, like I said, in Wyoming, we're nearly everybody on lifeline gets booted from the program. I think we've gotten it wrong. Other questions? Phil over here has one. Thanks for calling on me. So... Can you let the folks who are streaming know who you are? Oh, hi, I'm Phillip Barenbrod with public knowledge. So Sprint plays a pretty outsized role in the lifeline program as sort of the most active national facilities-based provider and as the underlying wholesaler for a lot of the resellers. T-Mobile isn't that active and those companies are looking to merge. Maybe Olivia and Yosef, can you guys speak to what that merger likely means to the lifeline program and low-income consumers that rely on it? Sure, so thanks, Phil, for that question. As folks so know, Sprint and T-Mobile are currently in the process of seeking approval for their merger at the FCC and DOJ. As Phil mentioned, Sprint is the primary, if not the only big, facilities-based lifeline provider. They also work with a lot of wireless resellers and lease wholesale capacity to mobile virtual network operators. And T-Mobile doesn't. T-Mobile has said that the lifeline program is not worth their time more or less or it's just not something they're going to invest in. And so the concern here is if they merge, all of a sudden you have a new T-Mobile entity that will not engage in lifeline either as a facility-based provider or working with resellers to give them affordable rates to provide lifeline service to low-income communities. And so if you look at the reseller numbers that folks have gathered together, T-Mobile will actually own a huge market of the prepaid or the MVNO market where they'll be able to charge astronomically higher rates which would essentially price out some of the smaller resellers or MVNOs from leasing capacity from them. And this all of a sudden just trickles down to the consumer because all of a sudden as a consumer you don't have access to these services or to these providers for lifeline or affordable broadband in general. Hi, I'm Carmen Scrotto with FreePress and I have a question. It could be addressed by all of the panelists but Olivia, I was thinking of you since you mentioned it. Can you explain a little bit more of the importance of the lifeline program when it comes to natural disasters and especially because we saw so much in 2017 so many hurricanes and wildfires in 2018 and how lifeline can help in that situation? Absolutely. One of the important functions of the lifeline benefit is access to emergency services. And if we think about even sort of before disaster occurs we get alerts. How do we get alerts? We get texts, right? Bad weather's on the way, ice. The wildfire alerts. So after disaster occurs as well, how do people find out where their shelter, where tents have been set up for benefits, where assistance is available? They need a phone. So this is a service that switched moved into the wireless space after Katrina. I mean when you have natural disasters you're dealing with displaced populations. You're dealing with people that have lost their jobs. You're dealing with people that have lost their homes. You're dealing with people that are starting from square one. You need connectivity. You need connectivity to find your assistance. You need connectivity to let your loved ones know you're okay. You need connectivity to sort of move forward with finding your shelter. How you're gonna provide for your family. Sort of the transition piece to a more stable place. So it is critical in this, could circle back to the minimum standards conversation because I don't know if the folks in the room are watching or aware that for voice in the original 2016 order, the benefit amount, the reimbursement amount for voice will tick down next year and each year after that. So it is in the advocacy space, we've been advocating for the preservation of voice service, particularly now. I mean the marketplace is sort of because of the uncertainty and wherever we are, the voice component is very, very important. And so we would like that to be preserved. Certainly the upcoming December one ramp down a voice next year, we would really like to sort of hold off on that one while we sort of take a look at the ecosystem, how people are using their phone, particularly in the issue of disaster relief. Yeah, I think that's actually a very natural transition I think into where we were thinking about going. So maybe, and maybe while we're talking about minimum standards and voice and broadband, we can check and see if there's any questions from Twitter. And, but yeah, so in 2016, the commission very deliberately under Chairman Wheeler expanded support under the program to include standalone broadband. Up until that point, bundled services were considered to be eligible, but there were some caveats there. But this was the first time that broadband became an option for users who wanted to use their 9.25 a month subsidy for a different service. And so I guess I'd like to unpack this a little bit. What is that trade-off me, what trade-offs are implicated in that shift from voice to broadband or from voice to include broadband and did the commission get it right then and what still needs to be done going forward? I think Olivia just kind of teed it up, so maybe, John. I'll take a stab and I'll start with voice, right? Olivia said the support for voice starts going down in December and it goes down rapidly and it disappears by 2021. So in 2021, the program won't support voice. And I think the idea behind that may have been a wireline-centric point of view that you can get voiced over your internet, right? And many people do, for example, Comcast at home, get voice over your internet, you have Verizon Fios, your voice and travels over the Fios product, which is over the internet, but that's not exactly how it's working on the wireless side. So people are buying broadband-only products from wireless providers and adding voice apps to it. And the voice app is so people are so used to having it being incorporated into the phone, it's different and so it's important. And so I think on the minimum service students, what the commission did is that they created a two-tier structure. You could have a minimum amount of voice, number of minutes, or a minimum number of megabytes on the data side. And it started off and we actually forestall, I think, disaster back in 2016 by getting the commission to moderate its proposal. And so then it was a proposal we thought in the industry we could live with for about a year before things started to fall apart. And it's 500 minutes or 500 megabytes. Over the course of time, a minute and a megabyte, it's my understanding, are about the same cost now. It was a little higher for megabyte back then. What has happened since then, you've got an asymmetric standard out there where it went to 750 minutes and a gig. So it's lopsided. At the same time, it took away the port freeze, which is also something that was, I think, very smart for the commission to have done. It actually incentivized providers to incentivize the broadband or push the broadband-centric plans because you got to keep the customer for 12 months. It was something that the carriers saw it worthwhile doing because they could then invest in a smartphone and give that consumer a smartphone. And we agreed, the commission was the first and worst-less office, for example, on a plan that these smart friends would also include hotspot capability and Wi-Fi capability. And so, keep in mind, it's not just the phone, the service that they get from a provider that you can use on your phone. You can get the internet off a wireless hotspot, whether it be a library or a McDonald's or a Starbucks. And people have to be creative how they get their data. But these minimum service standards and the takeaway of that port freeze have shifted carriers toward the cheaper product, the voice product. And so now this year, you've got 1,000-minute minimum or two gigabytes of data. Now, you guys can go out and look and figure out how much a gigabyte of data costs, but it's generally about $10 a gig you can upgrade for. And if the subsidy's only nine and a quarter, you can figure out the math. It can't be done for free. I don't know that the Tom Wheeler commission at the time minded eliminating free over time. It's something I think is worth revisiting and it's just affordable choice for these consumers. And I think it's hugely problematic. Yeah, so there's one argument that, and I will say, OTI has generally advocated for more aggressive minimum standards. And the justification there was that without minimum standards, you create two tiers of service for one for the general population and then another for poor people. And that was something that we saw as problematic. Though we recognize, of course, the challenges that John raises and this problem where once the cost of the service goes beyond that comfort zone of $9.25 or about $10 a month, then that means that consumers who are using their lifeline subsidy for a service that has all the minimum service requirements under the FCC's regulations is no longer $10 a month. It may be 15 or 20 or 25 and so there's an implicit requirement that the consumers have to pay in in order to get the service. And that raises problems as well. So that I think is sort of the contours of the challenge here. So I don't know if Olivia and Yosef have anything to add from a consumer's perspective. I'll start. The choice is important. Some consumers prefer voice. Some prefer more of the broadband. But to dictate that thou shalt not have subsidized voice lifeline service takes choice out of the hands of the consumers. So we would like an ecosystem where these array of products exist, including robust broadband. And we're hoping that that marketplace would grow over time. And we, you know, still hold out hope that we can evolve that program to that space. But right now for this point in time I would say in particular because of the access to emergency services voices an absolutely critical service and it's a logical choice for a lifeline consumer to pick the voice product. I think we raised some interesting points there in terms of this two different types of products and obviously the products that a lot of lifeline people get about a ten dollar value is not what you and I buy. It's not what a lot of people have but it's what these people can afford. But one thing I would like to see is to see if people would take a ten dollar discount off of different products. Some people can and they will. So I'd like to see service providers offer a more robust array of packages and many do. The other thing is that we haven't seen in the marketplace is the FCC has not let a new reseller into the marketplace since 2012. People in new ideas would come in and you'd have competition. Competition generally works to the benefit of consumers and you have not seen new entry into the space since 2012. It's time to figure that out. I know there was one more question in the room. Let me go back here and then if we have any from Twitter we can take the online questions as well. Hi Dave Cal communications daily. John can you just clarify you said under Chairman Pi we've seen a 30% drop in enrollment and you expect another 30% drop over the course of his term here. Can you just clarify are you attributing roughly speaking most or all of that to his commissions actions or does a good chunk of that result from implementation of previously adopted measures and secondly is your 30% going forward what are you assuming there are you assuming the reseller ban or not or is that just kind of current trends without the reseller ban. The 30% drop in the program over the past two years I would attribute to a large part regulatory uncertainty created over during Chairman Pi's administration he started by eliminating LBP designations within weeks of walking in the door and what an LBP designation is. Lifeline broadband provider so companies got designated to provide broadband services and handful companies got designated he immediately rolled back those designations and so that sent a signal to the marketplace that we had problems so the companies have been having difficulty attracting investment to continue to grow in the lifeline space other things like the removal of the port phrase the proposal of the ban wireless resellers the action to ban wireless resellers from the tribal lifeline program these things add up and they inhibit you know the business model where it's something that is entrepreneurial it's not like the you know the publicly traded companies are doing this business they're not, it's too risky it's not what they're good at in terms of the 30% going forward that is what we're seeing as a best case scenario for the national verifier implementation because of the re-verification process 30% is the number we're seeing fall out in Colorado and that's a state with good database access SNAP and Medicaid many states don't have that we're seeing numbers upward of 90% and frankly most of the states that are currently in the pipeline the national verifier have access to one database it's the HUD database so it's a public housing database it accounts for about half of 1% of all lifeline enrollments guess what, you're not going to find many people qualifying for a lifeline in that database because it's not being done it's being done on Medicaid and SNAP so I think that we have supported the position TrackPhone has filed a petition about database access and my view is that if you don't have access to Medicaid and SNAP I'm not sure what we're launching the national verifier it's not fair to consumers it's making it too difficult for them to stay in the program or to get into the program Amir, I... go ahead that's the best case scenario if you blend the numbers it looks more like two thirds what people are estimating that's a staggering number from a program that's in addition to the 30% we've already lost over the past two years Amir, I think we had one here online so we have one from Colleen Wong at New America here's the question overall what are the biggest barriers in streamlining the inefficient process for eligibility verification for lifeline what proposals to increase the ease of access have been successful and why any panelists want to take that how do we tilt the scale back to efficiencies where we had, you know where the commission might have aimed for certainty in catching like fraudulent behavior well I think with the national verifier in particular the access to the databases the ability for the USAC national verifier to ping the different databases for that yes-no solely that yes-no for enrollment into lifeline whatever it takes to facilitate those data matching agreements could help sort of ease a lot of I think of the streamlining issue there's reason for optimism USAC says it's working on an agreement a national agreement with Medicaid and if that could be done that would be a great step forward for getting consumers ease of access because if you can verify electronically that's easy for them there's also the low-income veterans pension funds so if the VA could facilitate access to that database that would be helpful I will throw out well, I'll hold off but any creative thoughts with the SNAP database they're usually at the state level they are run by the state so that would be really important to figure out how to do that and then also for consumers it's the API process carriers today can help consumers through this process they can't do it so with an API they can help aid consumers through the process and sometimes you might think well, how hard is it? it can be quite hard understanding what is going to suffice for proof of eligibility what is going to suffice if the database doesn't recognize or can't verify your identity in some jurisdictions the database doesn't verify your identity easily I'm told in, for example, in Puerto Rico over half the people get identity verification failure and so they have to then use an exception process to prove they are who they are it's perfectly legitimate but there are reasons databases aren't perfect they use Lexis and Exis for identity verification it is one of the components that's credit history and since this demographic doesn't have a lot of credit history sometimes it's challenging to verify these individuals so API is another thing I would say is going to help these consumers get through this process I would completely agree and that's what we're hearing from our members with respect to the machine or the API but I'd also point out I think the FCC and USAC are missing an opportunity to really collaborate with industry on the rollout of the national verifier we've been hearing reports from a lot of our members that there have been abrupt policy changes or that there's been sort of the retroactive application of new standards that are kind of announced and without any kind of forewarning or without any kind of heads up that these kind of changes are coming an industry is well positioned given their success in delivering Lifeline over the last decade particularly wireless resellers but also the facility space folks as well and I think if the FCC and the USAC would just provide industry with an opportunity to comment on some of these potential changes they would find that either they're ill-advised or they can at least understand how some of these changes could be how you could tweak some of these changes in order to make sure that at least industry and carriers and providers can help with the process just to expand that table but also other points of view I think could be helpful too like the low income consumer and the state agency point of view in that sort of feedback loop could be helpful definitely for example on snap cards and USAC issued guidance about what snap cards would be acceptable and not acceptable recently alarming guidance because according to my sources one state issues snap cards that are acceptable 49 don't that's a problem and yet snap is the number one trigger of eligibility of Lifeline so we gotta figure out what does that mean what is it we're looking at is the states put on these cards and not are there other ways consumers can prove out that they're eligible maybe it's some combination of documents where they can print out a receipt from a grocery store that says it was an EBT card that was used with Medicaid maybe it is a slip from a service provider saying that you were in I don't really love the idea of getting service provider receipts saying you participate in Medicaid but that's what we can do at a table together we can think about solutions to these problems nobody wants people who are ineligible into the program carriers certainly don't want them because they will come out of the program and they'll come out of their pockets but we need to find these solutions for these people and I think a multi stakeholder engagement with USAC to assess where we are as a verifier and how we can improve is a good next step so that leads me to what I was going to what I was saving as the sort of wrap up question which is and you know the title of this event is death by a thousand cuts and just to kind of recap some of the challenges that we've seen the threats to lifeline that we've seen there are those that you could categorize as being an output of the potential reforms proposed in the 2017 or sorry 2018 proposal from the commission the chairman pie proposal so 17 sorry forget what year we're in these days the 2017 proposal and that includes things like the proposed cap or lifeline cap in the NOI the removal of wireless resellers and non-facilities based providers from the program and then but then there's also I would say some peripheral issue peripheral threats to the lifeline program that are not necessarily central to those proposed reforms but which nonetheless seemed to have the potential to have a very big impact on the success of the program and the ability for the program to reach the households that need it and so what the question I would throw back with just a few minutes remaining which is kind of a big question but what needs to be done it sounds like and I don't want to put words in anyone's mouth that there seems to be agreement at least in this panel that the proposal from 2017 should be should be scrapped but what else is there are there things that the commission should be doing are there things that Congress should be doing besides convening you know various stakeholders what are the explicit mechanisms that need to be the levers that need to be pulled in order to ensure that the program has success going forward I think the commission is well aware of a lot of some of these issues that have popped up that we've talked about today you know as we mentioned earlier you know Q-Link wireless has a petition you know to include machine to machine capability in terms of real-time eligibility verification track phone has one in terms of acts providing access to some of the eligibility databases and for the commission I think to act on those I mean those have been pending for quite some time and you know the support for those is clearly on the record and so I think you know one of the things that the commission can do immediately you know is to rule on those pending petitions to grant them and to ensure that USAC has the tools that it needs in order to provide the kind of access that it needs to service providers and then get the kind of access it needs to some of these eligibility databases I think there may be a congressional component or a way Congress could help sort of facilitate access to some of the databases to for that automated eligibility SNOPING because there are certain databases out there that aren't linked up I would say the commission needs to come out and remove regulatory uncertainty by doing a couple of things eliminating the wireless reseller ban proposal once and for all and that would be quite helpful and hopefully they will use, hopefully we'll get a decision out of the court that can spur that activity on national verifier, getting it right granting these, the Q-link petition granting the track phone petition and coming together in an environment that says national verifier everyone agrees is so important but we need to come together to get it right because we don't see we don't necessarily like what's going on so far and then finally minimum service units ticking time bomb it's got to go and I suggest that we should work together and figure out how we can make sure consumers get what you feel they need but without government mandating what they should have on their service plans, data no voice and certain amounts and instead replace someone that was in competition and figure out what competition can do for those of regulation so three things I'd say real quick one withdraw withdrawing as 2017 proposals off the bat would be a great start second would be figuring out some of these challenges with the verifier that John has talked about here and determining whether it's the database issue, recertification issues working with stakeholders on that but third is something we haven't talked about a lot but figuring out why are there so many consumers in different states that aren't subscribed to this program but are eligible outside of the administrative problems is it an education piece is it a digital literacy piece what are the barriers there that are preventing so many eligible people from actually subscribing to the program and taking it back to I think 2012 when the FCC did their initial pilot program to figure out how do we expand lifeline to the broadband program they saw a couple different things one was a potential digital literacy issue one was a minimum standards or different types of standards that consumers would subscribe to so figuring out what are the challenges from a barrier perspective that both the FCC and Congress could tackle I know we're trying to wrap up here I absolutely want to agree with the panelists in terms of shelving a lot of these proposals but I also want to point out the one thing that exists now that didn't exist when the lifeline NPR or fourth report and order and order and reconsideration and the reforms were introduced is the office of economics and analytics I think one thing that was missing from the lifeline fourth report and order I think was contingency planning and it was impact estimates on what this would kind of do to not just to subscribers but then also to the industry as well so I think it would be really interesting for the commission to go back to use its new office of economics and analytics to do a real deep dive on the kind of impact that it's that these proposals would have and then on any future ones as well so the use of that new office I think would be helpful Olivia Thank you I do want to echo Yosef's recommendation to investigate who's not enrolling and why what are those barriers so how do we reduce them but also I'm not as a consumer organization we're not there with getting rid of the minimum standards I think you've heard that we've been strong advocates for minimum standards but there is a space to have a conversation of are they at the right are they set at the right point for where this program is at this point in time we could have a conversation of what the details of the minimum standards could be and what would be appropriate given sort of the ecosystem where we currently have because if the end goal is a robust program what will it take and also understanding that we're transitioning this program into a broadband support program but we're not there quite yet so what is that there has to be affordability though there has to be affordability there's a green light there alright, thank you all for joining us today thank you so much to our panelists this has been a really engaging and enlightening conversation thank you all