On Feb. 15, 2013, the FCC Wireline Competition Bureau issued an Order granting the certification of the Vermont Department of Public Service to opt out of the National Lifeline Accountability Database (“NLAD”), which is intended to detect and eliminate duplicate Lifeline support provided to individuals and households.  The NLAD is expected to come online later this year, although the precise time frame is unclear.  The state of Vermont was permitted to opt out of the NLAD because it demonstrated to the FCC that it has adopted its own system to eliminate duplicate support that is comprehensive and at least as robust as the NLAD is expected to be.

In Vermont, to enroll in the Lifeline program, subscribers submit Lifeline applications to the Vermont Department of Children and Families (“VDCF”).  Carriers are not permitted to submit certifications on behalf of subscribers.  The VDCF performs a check of state systems to determine if the prospective subscriber (1) is receiving a benefit that qualifies the subscriber for Lifeline; and (2) is already receiving a Lifeline benefit.

In addition to Vermont, four other states (California, Oregon, Puerto Rico and Texas) have filed petitions with the FCC to opt out of the NLAD.  Those petitions remain pending.