Drop Lifeline Address Requirement for Victims of Abuse, Groups Tell FCC
Protecting against abuse in the Lifeline program is a worthwhile goal, but protecting against abuse of battered spouses should take priority, said several organizations in comments urging the FCC to drop its home address requirement for people in state confidentiality programs. The Wireline Bureau had sought comment on how the Lifeline accountability database could accommodate victims of domestic violence who wish to keep their residential address out of public records.
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The prohibition on using post office boxes could lead to an unintended consequence, said the National Association of State Utility Consumer Advocates (http://bit.ly/195G8RR). “Lifeline eligible households that have established confidential addresses through state programs should not have to make the choice between foregoing receipt of telephone service with Lifeline assistance or maintaining the confidentiality of their residential addresses.” In the 24 states where the confidentiality program is offered, the FCC should work with state administrators and public interest groups to ensure that carriers don’t reject Lifeline applications “simply because of a check of a third party database such as Lexis shows some different address,” said the association.
Individuals in Indiana’s address confidentiality program “are already legitimately concerned for their safety and scared that someone may one day show up on their doorstep to victimize them further,” said the Office of the Indiana Attorney General (http://bit.ly/195FMuC). Someone in the state’s confidentiality program “could receive a phone call from the individual they have the protective order against posing as a Lifeline representative,” the office said. It said that if that Lifeline recipient “has already submitted a physical address to Lifeline, they would be more likely to divulge that information again, thereby opening themselves up to the dangerous situation they were seeking to escape initially.” The manager of Maine’s confidentiality program also supported the waiver request (http://bit.ly/195G2tA).
"When a victim separates from an abuser, she or he often struggles to establish economic stability,” said the Pennsylvania Coalition Against Domestic Violence. “A victim who separates is at an increased risk of severe physical violence or homicide by an intimate partner,” it said (http://bit.ly/1bNwEwV). Lifeline and address confidentiality programs work in tandem, it said: The basic phone service afforded by Lifeline lets victims “establish economic independence from an abuser while ensuring the victim’s continued ability to access emergency assistance,” while confidentiality programs offer anonymity that’s “sometimes essential to the victim’s ability to stay safe.” A waiver of the address requirement for these individuals is “essential to the proper functioning of each program, and will assist victims to overcome the unique and significant barriers they face,” the coalition said.
"The integrity of the Lifeline program would not be harmed by this waiver,” said the Family Violence Law Center (http://bit.ly/195DnzR). “The proposed rules would require the Lifeline eligible customer to provide official documentation that he or she is participating in the address confidentially program. This requirement would allow the telephone carrier and Lifeline program to still check and flag any potential duplicate accounts.”
The FCC and Universal Service Administrative Co. could work with state officials “to assuage any fraud, waste and abuse concerns,” said the National Consumer Law Center, representing more than 20 public interest groups, including Free Press, Common Cause and the Benton Foundation (http://bit.ly/1bNwEwV). The Lifeline recipient would still be required to certify that he or she is only receiving one Lifeline benefit per household, the groups said. They also asked the commission to “consider extending critical Lifeline deadlines” for participants in confidentiality programs, as “mail receipt is delayed a few days” because all first-class mail is forwarded through an intermediary.