NARUC, Consumer Groups, Lifeline Providers Support Q Link National Verifier API Request
Parties urged the FCC to ensure a Lifeline national verifier has electronic interfaces that will ease verification of consumer low-income eligibility. State regulators and consumer advocates were supportive, and the National Lifeline Association (NaLA), Sage Telecom, Sprint and TracFone Wireless expressly backed Q Link Wireless' emergency petition to direct Universal Service Administrative Co. to implement machine-to-machine application programming interfaces for the national verifier (see 1807050046). No opposition was filed in comments posted Friday and Monday in docket 17-287. The FCC and USAC declined comment Monday.
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NARUC noted its concerns predated the petition, but said Q Link detailed "serious flaws" in USAC's national verifier implementation plan, which backed off an original plan to include APIs. “Absent an interface to allow carriers to assist applicants, the online application process is unnecessarily complicated and daunting for even the most computer-savvy consumer,” the group said. "This deficit in the implementation scheme threatens to disconnect millions of qualified Americans from the enrollment process and expose others to data security risks, including phishing scams. It also would increase costs for the National Verifier for applicant screening and associated transaction costs normally handled by the service providers during the intake process." It urged the FCC to "restore carrier APIs" before the national verifier's planned hard launch in six states.
"The National Verifier is potentially heading in the wrong direction," wrote New America's Open Technology Institute and 15 other consumer-oriented groups. They are troubled by USAC's "lack of transparency" in removing the national verifier's API functionality, and worried "USAC has not made clear if there will be consumer (low-income applicant) testing of the consumer portal." The groups "support an interface that will clearly and easily direct consumers to the USAC eligibility verifier and easily redirect consumers back to the provider of their choice once their eligibility has been verified," they said. "An overly cumbersome enrollment system threatens the integrity of Lifeline and risks deterring eligible individuals."
Lack of an API "would have a severely negative impact on all Lifeline service provider business models (including in-person enrollments) and eligible low-income Americans," filed NaLA. Implementation of APIs will make the national verifier "more efficient and effective," said Sprint. "The NV will help minimize waste, fraud and abuse in the Lifeline program as well as reduce service provider liability for incorrect eligibility determinations."
"USAC’s inexplicable withholding of APIs ... will greatly undermine the policy objectives of the Verifier by erecting additional barriers for eligible consumers to obtain Lifeline services while increasing the administrative burdens on USAC as well as Lifeline service providers," said TracFone. "Without APIs, the roadblocks posed by the National Verifier to online enrollment will prevent deeper penetration of Lifeline wireless broadband services, particularly in rural America -- the exact opposite of the Commission’s goals for the Lifeline program," said Sage Telecom.
Lifeline Notebook
Comments are due Sept. 12, replies Sept. 27 on a TracFone emergency petition asking the FCC to direct USAC to expedite efforts to obtain access to key databases or postpone the national verifier's hard launch (see Notebook at end of 1808100027). Alternatively, "TracFone requests that the Commission 'direct USAC to accept documentation produced through third parties’ automated access to state databases as part of the Verifier’s manual process, including managed care organization ('MCO') letterhead proof of Medicaid eligibility,'" said a Wireline Bureau public notice Monday.