Commissioner Pai is seeking to identify other wireless ETCs that were allegedly engaged in practices similar to those detailed in the FCC’s recent Notice of Apparent Liability (NAL) issued against Total Call Mobile. In a letter to Chris Henderson, USAC’s CEO, Commissioner Pai states that sales agents for Total Call

“testified that they worked side-by-side” with agents who were engaged by two separate wireless ETCs and “learned how to exploit the program” from employees who worked at two other ETCs.

In response, Commissioner Pai has requested that USAC provide the following information, for the time period October 2014 to the present, for the four companies identified by the Total Call sales agents (the names of which are redacted from the public version of the letter):

  • Audits or investigations conducted by USAC;
  • The number of duplicate customers identified by USAC and de-enrolled by the companies, as well as the de-enrollment dates in 2014;
  • The total number of customers enrolled (or transferred in), the number of times the National Lifeline Accountability Database (NLAD) was overridden, and the nature of the failures leading to the overrides (e. g. notice of duplication by third-party independent verification, address, or duplicate household); and
  • The number of customers who qualified for Lifeline based on SNAP participation and whether agents were presented with temporary or permanent SNAP cards. (It is unlikely that USAC will be able to fulfill this request as NLAD does not distinguish between temporary and permanent eligibility verification cards. Nor were ETCs permitted to retain proof of eligibility prior to February 2016.)

In addition, Commissioner Pai requests that USAC provide a list of Lifeline wireless resellers that overrode the NLAD verification checks more than 500 times since October 2014, the reason for the overrides, as well as the percentage of new enrollees resulting from overrides, reported on a monthly basis by study area. Commissioner Pai did not request similar information for wireless or wireline providers that are not resellers.

Finally, Commissioner Pai requests an “explanation of USAC’s plan for reviewing, auditing, and investigating eligibility documentation” since the implantation of the new document retention rule. Again, this request only applies to “Lifeline wireless resellers.”

Commissioner Pai gave USAC until May 2nd to respond to the requests.