On February 11, 2013, the Wall Street Journal ran an article with the headline “Millions Improperly Claimed U.S. Phone Subsidies,” asserting that the results of the new annual recertification process revealed a large number of Lifeline subscribers were not able to prove their eligibility to receive support from the program. While the article mentions that many consumers did not respond to recertification requests, it underplays the important distinction between non-response and actual failed attempts to prove eligibility.

A better title for the article would have been “Millions Don’t Respond to Government Inquiry—Government Unsure Why.” Or “People Confused By Legalese in Government-Mandated Survey.” Instead, the article states that millions of people “improperly claimed” phone subsidies through the Lifeline program. This implies that the phone subscribers were not eligible when they signed up for service, which the new data simply does not show.

The data described in the article concerns efforts to verify whether Lifeline subscribers continue to qualify, not whether the person qualified when signed up. As part of recent changes to the Lifeline program, the FCC required phone companies to take a snapshot of their subscriber bases as of June 1, 2012, and attempt to contact all those subscribers. That was six months ago, and a lot can happen in six months. Many of these subscribers may have not gotten the letter in the mail. Lifeline subscribers are, by definition, poor. As a result, many lead very transient lives, leading to multiple moves per year. Many are homeless. If the phone company mailed a letter to the person’s address as of June 2012, the subscriber may not have received it because he or she is now living elsewhere or changed homeless shelters.

Another problem associated with poverty is illiteracy, and as a result, many Lifeline subscribers are illiterate. Will an illiterate person actually understand what is being requested when asked to “certify” to nearly a dozen lawyerly statements such as:

One Lifeline service is available per household, and that, to the best of my knowledge, no other person in my household is receiving a Lifeline service. For purposes of Lifeline, a household is any individual or group of individuals who live together at the same address and share income and expenses.

Or would the subscriber simply ignore the confusing notice?

Conversely, if the person’s fortunes had changed since June 2012, and he or she had gotten a job and was no longer poor enough to qualify, would that person bother to respond? Failure to respond means that the Lifeline subsidies cease. Unfortunately, the article mostly conflates non-response with the issue of whether the person was eligible in the first place, although it does, at one point, somewhat distinguish between these two concepts.

Non-response to a government survey tells us nothing about whether these subscribers were eligible when they signed up. That was not part of the survey, and to try to extrapolate such a finding from non-response rates is a futile task.