USTelecom representatives raised concerns about a provision in an FCC order released...
USTelecom representatives raised concerns about a provision in an FCC order released last week approving a temporary waiver the group sought of the June 1 deadline for implementing new Lifeline eligibility rules on eligible telecom carriers (CD June 1 p5).…
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The group raised concerns about a statement in the order: “During the waiver period, in accordance with sections 54.410(b)(2)(i) and 54.410(c)(2)(i), these states must provide notice to the ETCs that their subscribers have complied with the Lifeline eligibility requirements and have executed a certification form.” USTelecom said the provision draws a conclusion it should not regarding ETCs. “While this language may address the issue of whether ETCs are entitled to seek reimbursement prior to having received customer certifications, it takes for granted a very important factual matter, that is, whether states have actually modified (or intend to modify during the waiver period) their processes to seek and collect end-user certifications,” USTelecom said (http://xrl.us/bna5sn). “It stands to reason that a state cannot send notice to ETCs that customers have executed a certification form if it has not actually required customers to execute such form. And this concern is not merely a hypothetical one, as the regulatory agencies from at least two jurisdictions that are covered by the waiver have already acknowledged that they will not be able to comply with the June 1st requirement to collect end-user certifications.”