Lifeline will be on the agenda once again at the summer meetings of the National Association of Regulatory Utility Commissioners (“NARUC”) in Denver on July 21-24. Among the items to be considered is a Resolution to improve the annual recertification process. This draft Resolution, among other things, “commends the FCC on its efforts to eliminate waste, fraud and abuse in the Lifeline program” but urges the FCC to “examine the recertification process to ensure that legitimate participants continue to receive the benefits provided by the Lifeline program.” It also “encourages the FCC to ensure that the National Lifeline Accountability Database and the national eligibility database”—the former of which is under development, and the latter is proposed for implementation by the end of 2014—are both “available before the end of 2013 so that ETCs may use these databases in 2014.”

Interestingly, the draft Resolution includes several findings (contained in “whereas” clauses) that most Lifeline ETCs likely would applaud and support. Among others, the draft concludes that although “recent media reports have claimed that the vast number of de-enrolled Lifeline subscribers [during the 2012 recertification process] is proof of continuing waste, fraud and abuse in the Lifeline program . . . a significant proportion of the customer de-enrollment may have occurred because eligible consumers failed to complete and return their forms or experienced difficulty completing the required forms completely and accurately.” It also finds that “a recertification form that is simpler and easier for consumers to understand, to be used in the interim period before the automated eligibility process is implemented, may improve the accuracy of program participation;” and that “while NARUC supports the annual recertification process as a necessary step in helping to eliminate waste, fraud and abuse, it believes that requiring ETCs to obtain signed recertification forms may not be the most efficient option for Lifeline subscribers or ETCs.”

NARUC’s Board of Directors is scheduled to vote on the Resolution on July 24.