On Tuesday, January 28, 2020, the FCC Office of Inspector General (“OIG”) issued an Advisory Memorandum (“Advisory”) regarding eligible telecommunications company (“ETC”) compliance with Lifeline usage rule. The Advisory alerts Lifeline carriers, beneficiaries, and the public to the potential for widespread carrier non-compliance with the Lifeline rule.

The Advisory clarifies that ETCs shall only receive universal service support reimbursement for Lifeline service provided to subscribers who have used the service within the last 30 days, or who have cured their non-usage in accordance with the Commission’s rules. Further, when seeking universal service support reimbursement for providing Lifeline service, ETCs must certify compliance with all Lifeline rules, including the usage requirement. The Advisory also includes examples of usage rule violations, where ETCs sought and received Lifeline subsidies for accounts with no qualifying usage, such as treating incoming texts or voicemails to subscribers or data use not generated by the subscriber as qualifying usage. OIG warns all Lifeline carriers to examine their current usage monitoring mechanisms and take appropriate remedial measures if problems are discovered.

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