On September 10, USAC posted a Request for Information (RFI)—usually a precursor to an RFP—to prospective vendors of a third party “national Lifeline eligibility verifier” system, proposed in the FCC’s pending Lifeline Further Notice of Proposed Rulemaking as a replacement for the current process wherein Lifeline ETCs receive and review proof of Lifeline eligibility presented by applicants.  The RFI was posted without any kind of “news” announcement or other notice on the USAC homepage, but rather was simply posted on its “procurements” page.  Responses are due September 28.

While in some respects rather sterile, this RFI includes a surprising “Requirement” to be followed by a prospective vendor:

"Within 24 hours, the verifying firm shall review documentation to ensure it is legible, complete, and meets the eligibility standards.  What is the cost difference between 24 hours and faster turnaround increments (e.g. 12 hours, 6 hours, 4 hours, and shorter)?

In addition, the RFI states: “Potential methods for submitting eligibility requests include paper mail, email, fax, or electronic submission through a secure portal;” and, in discussion of the volumes of eligibility verifications to be handled by the vendor, it asks: “What are the benefits and challenges associated with ongoing eligibility request submissions versus an annual, limited eligibility request window with lower day-to-day volume for exceptions, revisions, or other ad hoc activity?

In sum, this USAC RFI clearly assumes that Lifeline eligibility verifications performed by a prospective third party verifier will not be processed in real time, but rather will have a 24-hour lag (or possibly less, subject to “cost difference” considerations), or possibly longer, inasmuch as it contemplates that proof documents could be submitted by regular mail, fax or other methods.  Even more surprising, the RFI explicitly raises the possibility of an “annual, limited eligibility request window” for consumers’ Lifeline service applications.

These parameters presumably would be strongly opposed by—and if adopted, extremely harmful to—Lifeline ETCs that now enroll Lifeline subscribers on a real-time, single-transaction basis. It is unclear the extent to which USAC’s FCC overseers had input in the drafting of this RFI, or whether such system parameters are favored by the FCC. Reply comments on the FCC’s pending FNPRM are due on September 30.