New Track 2 Duplicates Resolution Process Announced: ETCs Have Until December 30, 2014 to Resolve Same Address Duplicates

Late yesterday, the FCC’s Wireline Competition Bureau issued a Public Notice announcing a new process for resolving “Track 2” duplicates, which involve multiple Lifeline subscribers residing at the same address but who receive service from different ETCs.  The Public Notice indicates that USAC will provide ETCs a list of Track 2 subscribers that they serve (although it does not indicate when such a list will be provided).  The ETC must then obtain a completed independent household worksheet (“IEH” worksheet) from the subscriber by December 23, 2014, or otherwise de-enroll the subscriber by December 30, 2014.  The next day, December 31, 2014, is the deadline for ETCs to update the status of these subscribers in NLAD by either setting the IEH flag or entering de-enrollment dates.  When sending the IEH form, the Public Notice also directs ETCs to provide an explanation of certain rules to the subscriber in a cover letter or similar communication.

The Public Notice directs ETCs to a sample cover letter, revised IEH worksheet and new guidance posted on the USAC website regarding the Track 2 process.  The Public Notice also explains in a footnote that while ETCs are not required to use the exact letter and form posted on USAC’s website, any ETC-created Track 2 cover letter (or similar communication) and form must convey the same information.  The IEH worksheet itself has been simplified, due in part, to advocacy on behalf of DWT clients whose subscribers found the prior form confusing.  It now contains simplified language and visual guides for subscribers that may otherwise be confused by the legalistic verbiage in the USAC sample cover letter.