3060-0819 -Supporting Statement Revisions_final version

Bridging the Digital Divide for Low-Income Consumers, 3060-0819

Lifeline and Link Up Reform and Modernization, April 2020

Telecommunications Carriers Eligible for Universal Service Support

SUPPORTING STATEMENT

This submission is being made pursuant to 44 U.S.C. § 3507 to obtain the Office of Management and Budget (OMB) approval of revised information collection requirements.

1. Justification:

1. Circumstances that make collection necessary.

The Commission first adopted rules for the Lifeline program in 1997. On May 8, 1997, the Commission adopted rules establishing, among other things, that eligible telecommunications carriers (ETCs) offering Lifeline and Link Up to qualifying low-income customers would receive reimbursement from the federal Universal Service Fund (USF or Fund) for low-income support. On April 2, 2004, in its Report and Order and Further Notice of Proposed Rulemaking (Lifeline Order), the Commission directed ETCs to certify their Lifeline/Link Up subscribers’ eligibility for the program and to verify a portion of their subscribers’ eligibility on an annual basis. States that operate their own Lifeline/Link Up programs have been allowed to develop their own certification procedures (referred to as non-federal default states). The Lifeline Order also requires ETCs to submit to the Universal Service Administrative Company (USAC or Administrator) proof that they certified that their Lifeline subscribers are eligible for Lifeline, and proof that they verified a portion of their subscribers’ continued eligibility for Lifeline.

On March 4, 2011, the Commission released a Notice of Proposed Rulemaking (NPRM) (the Lifeline and Link Up NPRM) to reform and modernize the Lifeline/Link Up program in which it presented a comprehensive set of proposals to better target support to needy subscribers and maximize the number of Americans with access to modern communications services. In June 2011, the Commission adopted the Lifeline Duplicates Payment Order to address waste in the Fund created by duplicative claims. On September 23, 2011, the Commission issued an Inquiry into Disbursement Process for the Universal Service Fund Low Income Program seeking comment on a proposal for disbursing USF low-income support to ETCs based upon claims for reimbursement of actual support payments made, instead of projected claims for support. On February 6, 2012, the Commission issued its Report and Order and Further Notice of Proposed Rulemaking (2012 Lifeline Order). In the 2012 Lifeline Order, the Commission adopted the proposal to file the FCC Form 497 monthly and changed the low- income disbursement process from payments based on projected subscriber counts to payments based on actual subscriber counts. After the 2012 Lifeline Order, ETCs are required to recertify the eligibility of their entire subscriber base annually. Starting in 2013, ETCs could elect to have USAC conduct the annual recertification process on their behalf.

On June 22, 2015, the Commission released a Second Further Notice of Proposed Rulemaking, Order on Reconsideration, Second Report and Order, and Memorandum Opinion and Order (2015 Lifeline Order). The Commission adopted several rules in the 2015 Lifeline Order to: strengthen the document retention requirements; ensure that only ETCs directly serving low-income customers receive reimbursement under the Lifeline program; and require ETCs to use a uniform snapshot date to request reimbursement from USAC for the provision of Lifeline support.

On April 27, 2016, the Commission adopted the Lifeline and Link Up Reform and Modernization et al., WC Docket Nos. 11-42, 09-197, 10-90, Third Report and Order, Further Report and Order, and Order on Reconsideration, FCC 16-38 (2016) (2016 Lifeline Order), that imposed sweeping changes to the Lifeline program by introducing broadband internet access service (BIAS) as a supported service, as well as laying the groundwork for a National Verifier to determine Lifeline subscriber eligibility and annual recertification. The changes focused on combating waste, fraud, and abuse while extending coverage to include robust BIAS and voice services. The 2016 Lifeline Order changes included: adding BIAS as a supported service, phasing out support for voice-only service offerings over the next six years, requiring ETCs to certify compliance with the new minimum service requirements, laying a framework to develop a National Verifier, streamlining the eligibility criteria, creating a new ETC designation for Lifeline Broadband Providers (LBPs), updating the obligations to advertise Lifeline offerings, requiring ETCs to provide Wi-Fi and hotspot enabled devices, modifying the non-usage de-enrollment requirements within the program, moving to rolling annual subscriber recertification, streamlining the first-year ETC audit requirements, and eliminating the temporary address requirements.

The Commission’s decision to transition to a centralized National Verifier was outlined in detail in the 2016 Lifeline Order. The National Verifier was established to make eligibility determinations and perform a variety of other functions necessary to enroll subscribers into the Lifeline program. The National Verifier will verify Lifeline subscriber eligibility, check for duplicate Lifeline subscribers, conduct recertification of subscribers, and calculate support payments to ETCs. The National Verifier was soft launched over a period of several years from late 2017 through December 31, 2019, and the Commission is working to fully launch the National Verifier in all states (the “Transition Period”).

On November 16, 2017, the Commission adopted the Bridging the Digital Divide for Low-Income Consumers, WC Docket Nos. 17-287, 11-42, 09-197, Fourth Report and Order, Order on Reconsideration, Memorandum Opinion and Order, Notice of Proposed Rulemaking, and Notice of Inquiry, FCC 17-155 (2017) (2017 Lifeline Order), which limited enhanced Tribal Lifeline support to facilities-based carriers on Tribal lands to more efficiently utilize Universal Service funds. On February 1, 2019 the United States Court of Appeals, District of Columbia Circuit vacated the 2017 Lifeline Order. At this time, the Commission has not taken further action on the Tribal Lifeline support issues impacted by the court’s ruling. As such, this revision takes steps to remove the requirements related to the 2017 Lifeline Order’s actions regarding Tribal Lifeline support.

On October 30, 2019, the Commission adopted the Bridging the Digital Divide for Low-Income Consumers, WC Docket Nos. 17-287, 11-42, 09-197, Fifth Report and Order, Memorandum Opinion and Order and Order on Reconsideration, and Further Notice of Proposed Rulemaking, FCC 19-111 (2019) (2019 Lifeline Order). The 2019 Lifeline Order restores the states’ lawful role in designating eligible telecommunications carriers and eliminates the Lifeline Broadband Provider designation category and its associated designation procedures. The Order also implemented a number of administrative changes to improve the integrity of the Lifeline eligibility verification, enrollment, and recertification processes. This revision implements the requirements of the 2019 Lifeline Order.

In revising this information collection, the Commission seeks to:

• Update the number of respondents for most of the existing information collection requirements, thus increasing the total burden hours for some requirements and decreasing the total burden hours for other requirements.

• Revise the information collection to remove references to the LBP designation process.

• Revise the information collection to remove requirements related to the 2017 Lifeline Order’s actions regarding Tribal Lifeline support.

• Revise the information collection to reflect process changes for enrollment representative registration and ETC biannual audits.

No further revisions are proposed with respect to the other existing information collections subject to this control number, described below.

Revisions to Requirements in this Information Collection:

Lifeline ETC Reimbursement Process Using Snapshot Report (Revised to Update the Number of Respondents) (See 12a.):

ETCs will be reimbursed for low-income support based on the actual qualifying low-income consumers they serve directly as of the first day of the month. For all ETCs in all states and territories, payments will be made based on a snapshot report compiled based on the number of subscribers enrolled with an ETC in the National Lifeline Accountability Database (NLAD) for the previous month or, in NLAD opt-out states, based on data received either from the state or directly from the ETC (containing all fields described in the Lifeline ETC Reimbursement Data Fields). For ETCs receiving a snapshot report, ETCs will review the snapshot report they receive from USAC and validate subscribers for which they are requesting reimbursement. The snapshot report will contain pre-populated information with the reimbursement rate for each subscriber based on the prior month’s submission. ETCs will review the rate information and make all necessary corrections. Alternatively, ETCs can create their own file (containing all required fields as described in the Lifeline ETC Reimbursement Data Fields) and upload the file to seek reimbursement for the subscribers listed. The ETC-created file must contain the requested reimbursement amount for each subscriber and other data, as described in the Lifeline ETC Reimbursement Data fields. ETCs will also make required certifications as part of this payment process.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with the Lifeline ETC reimbursement process and also updates the number of respondents.

FCC Form 497 (Revised to Update the Number of Respondents) (See 12a.). In some limited cases, an ETC may need to continue to file FCC Form 497 for reimbursement and certify, pursuant to 47 C.F.R. §§ 54.403 and 54.407, that it has passed through the support received to the qualifying low-income consumer. ETCs must also state that they are in compliance with all of the rules of the subpart, and to the extent required, have obtained valid certification and recertification forms from each of the subscribers for whom they are seeking reimbursement. Carriers must file revisions or original FCC Form 497 submissions on a rolling twelve-month window basis.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with the Lifeline ETC reimbursement process and also updates the number of respondents.

FCC Form 555 - Annual Reporting of Subscriber Recertification (Revised to Update the Number of Respondents) (See 12b.).

Pursuant to 47 C.F.R. § 54.416(b), ETCs must annually provide the results of their re-certification efforts on the Annual Lifeline Eligible Telecommunications Carrier Certification Form 555 to the Commission, the Administrator and the relevant state commission or Tribal government (where applicable). To provide information to the Commission regarding the extent to which ineligible subscribers may have been receiving service, the Commission requires ETCs to separately report on the FCC Form 555 the number of subscribers that did not respond to the re-certification request and those that responded that are not eligible to receive Lifeline support. On that same form, pursuant to 47 C.F.R. § 54.416(a), an officer of the ETC must make annual certifications regarding its certification procedures and that the ETC has processes in place to ensure that its subscribers are eligible. In cases when ETCs cannot re-certify their subscribers by accessing a database, they must re-certify them on an annual basis or elect to have USAC re-certify them.

To assist in ETC audits, all ETCs are required to report on the FCC Form 555 the number of subscribers who de-enrolled each month pursuant to non-usage requirements and attest to whether the ETC is subject to non-usage requirements. The non-usage period is 30 days, consistent with reforms adopted in the 2016 Lifeline Order. The ETC will also report the number of subscribers who de-enrolled prior to recertification efforts each month.

The Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

FCC Form 481 – Carrier Annual Reporting Requirements (Revised to Update the Number of Respondents and to Remove the Lifeline Broadband Program (LBP) Designation from the Description) (See 12c.). All ETCs must include the information that is required by 47 C.F.R. § 54.422(a) in their annual reports to the Commission, specifically, the company’s holding company, operating companies, affiliates, and any branding (a “dba,” or “doing-business-as company,” or brand designation). Pursuant to 47 C.F.R. § 54.422(a), ETCs providing Lifeline services to low-income consumers must include this information in their annual reports to the Commission on the FCC Form 481.  In addition, the same rule requires every ETC receiving low-income support to annually provide to the Commission and USAC general information regarding their Lifeline plans for voice telephony service offered specifically for low-income consumers.

The Form 481 also requires certification by an ETC officer stating the ETC has complied with all Commission rules. 47 C.F.R. § 54.407(d). Specifically, the ETC has valid certification and recertification forms for all subscribers and the ETC’s services comply with the appropriate minimum standards and device requirements. 47 C.F.R. §§ 54.407(d), 54.416(a)(3), 54.422.

As part of this proposed revision the calculations for the burden hours associated with FCC Form 481 are modified based on updated estimates of the number of respondents, and the requirements related to LBP have been removed.

FCC Form 5629 – Lifeline Program Application Form and Certification of Eligibility Upon Enrollment (Revised to Update Number of Respondents) (See 12d.). Pursuant to 47 C.F.R. § 54.410(a)-(d), ETCs (or the state administrator, where applicable) are required to check the program-based eligibility of new Lifeline subscribers at enrollment by accessing available state or federal eligibility databases. If the Lifeline applicant is applying for enhanced Lifeline support, the ETC is required to independently verify and document the applicant’s rural Tribal residency and should obtain information from applicants sufficient to demonstrate that their address is on rural Tribal lands. Where underlying income-based or program-based eligibility data cannot be accessed, pursuant to 47 C.F.R. § 54.410(b)-(c), new Lifeline subscribers are required to provide documentation of income-based or program-based eligibility. The entity enrolling the subscriber must retain this documentation used to verify subscriber eligibility. ETCs must also retain documentation related to the NLAD dispute resolution processes, which require verification of identity, address, or age of subscribers. 47 C.F.R. § 54.404(b). ETCs must also retain all information and documents provided by the state Lifeline administrator or other state agency consistent with 47 C.F.R. § 54.417. ETCs are required to use the FCC Form 5629 Lifeline Program Application Form or an online form containing all information specified in the Lifeline Program Application data fields to inform subscribers about the program and require subscribers to provide information and make certain certifications, consistent with 47 C.F.R. § 54.410(d).

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

FCC Form 5630 – Lifeline Program Annual Recertification Form (Revised to Update the Process, Number of Respondents, and Annual Hour Burden Per Respondent) (See 12e.). The 2019 Lifeline Order modifies 47 C.F.R. § 54.410(f) to require ETCs to confirm the eligibility of all their Lifeline subscribers on an annual basis, except where the National Verifier or state administrator is responsible for the annual recertification. A subscriber’s continued eligibility may be recertified by querying an eligibility database that confirms the subscriber meets the Lifeline program’s income or program-based eligibility requirements. Otherwise, carriers or the National Verifier must collect signed certifications from subscribers attesting to their continued eligibility as well as provide the information contained in the initial certification form. The 2019 Lifeline Order also modified the self-certification process for a limited number of Lifeline subscribers. In instances where a subscriber’s Lifeline eligibility was previously confirmed via a database and at the time of rectification that subscriber is no longer in that database and cannot have their eligibility confirmed through another database, then that subscriber must submit supporting documentation to substantiate their continued eligibility to participate in the Lifeline program. Recertification may be conducted in multiple ways, including via an interactive voice response unit or texting as a means to collect the information necessary to satisfy 47 C.F.R. § 54.410(f). This rule, in conjunction with 47 C.F.R. § 54.405(e)(4), also requires that consumers who do not respond to annual re-certification attempts in 60 days be de-enrolled from the Lifeline program. ETCs are required to use the FCC Form 5630 - Lifeline Program Annual Recertification Form or an online form containing all information specified in the Lifeline Recertification data fields to recertify consumers.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

Lifeline Recordkeeping 47 C.F.R. § 54.417 (Revised to Update the Number of Respondents) (See 12f.). 47 C.F.R. § 54.417 requires ETCs and non-ETC resellers to maintain records to document compliance with all Commission and state requirements governing the Lifeline and Tribal Link Up program for the three full preceding calendar years and provide that documentation to the Commission or Administrator upon request. Notwithstanding the preceding sentence, eligible telecommunications carriers must maintain the documentation required in § 54.410(d) and (f) for as long as the subscriber receives Lifeline service from that eligible telecommunications carrier.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

Maintenance of National Lifeline Accountability Database (Revised to Update the Number of Respondents) (See 12g.). The Commission required the development of a national database to detect and eliminate duplicative Lifeline and Link Up support. Pursuant to 47 C.F.R. § 54.404, ETCs are required to verify and standardize the relevant data and transmit the relevant data to the database administrator in the format prescribed. The rule and other guidance requires ETCs to obtain consumers’ consent prior to transmitting the requisite information (subscriber’s full name, address of primary residence, information on whether the address is temporary and/or descriptive and whether it includes coordinates, mailing address (if different), information demonstrating whether the address is on Tribal lands, telephone number associated with the Lifeline service, the date Lifeline service was initiated/terminated, date of birth, last four digits of social security number, agent identification information (if an agent is assisting in completing the application), the amount of support being sought for the subscriber, the means of subscriber qualification proof, and the type of service being provided). In cases where documentation containing the individual’s full social security number is provided to USAC or the FCC, all but the last four digits of the number will be redacted by USAC or the FCC. (This applies to all references to social security number information throughout this document.) With respect to Link Up subscribers, ETCs must transmit to the duplicates database in a format prescribed by the Administrator each new and existing Link Up subscriber’s full name, primary residential address, telephone number associated with the Link up support, date of service activation, date of Link Up support, date of birth, and last four digits of social security number obtained from the subscriber. Pursuant to 47 C.F.R. § 54.404(b)(8), when notified of any change of subscriber information, ETCs are required to update the duplicates database within ten business days. In addition, pursuant to 47 C.F.R. § 54.404(b)(10), ETCs are required to update the database within one business day of de-enrollment of any consumer.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

FCC Form 5631 – Household Worksheet (Revised to Update the Number of Respondents) (See 12h.). When the NLAD duplicate check process flags that a prospective subscriber shares an address with an existing Lifeline subscriber, information will be collected to verify that the prospective subscriber’s household is only receiving one Lifeline benefit. This information will be collected using FCC Form 5631 or an online form containing all data fields specified in the One-Per-Household Worksheet data fields. The subscriber must provide their full name, last four digits of their social security number or their Tribal ID number, date of birth, address of primary residence, contact information, Lifeline subscriber identification number, security question and answer to security question, user name, password, and application identification number. The subscriber must also provide information on whether the prospective subscriber’s husband, wife, or domestic partner living at the same address has Lifeline-discounted service; whether another adult that lives with the prospective subscriber has a Lifeline-discounted service; and whether the subscriber shares expenses for bills, food, or other living expenses and shares income with the other adult that lives with them. The prospective subscriber will be required to sign and date that information request.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

Subscriber Usage (Revised to Update the Number of Respondents) (See 12i.). Pursuant to 47 C.F.R. § 54.405(e)(3), ETCs offering service that do not assess and collect a monthly fee from their subscribers are required to de-enroll subscribers who fail to use the service within 30 consecutive days, as defined in 47 C.F.R. § 54.407(c)(2) and update the duplicates database within one business day of such de-enrollment. ETCs must report the number of consumers de-enrolled on their annual re-certification filing.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

Marketing and Outreach (Revised to Update the Number of Respondents) (See 12j.). Pursuant to 47 C.F.R. § 54.405(c), all ETCs are required to include plain, easy-to-understand language in all of their Lifeline marketing materials to explain to consumers that the offering is a Lifeline-supported service; that Lifeline is a government assistance program; that only eligible consumers may enroll in the program; what documentation is necessary for enrollment; and that the program is limited to one benefit per household, consisting of either a wireline or wireless service. Additionally, ETCs are required to disclose the company name under which they do business and the details of its Lifeline service offerings in their Lifeline-related marketing and advertising. ETCs are required to explain that Lifeline is a government benefit program, and consumers who willfully make false statements to obtain the benefit can be punished by fine or imprisonment or can be barred from the program. To provide ETCs with the flexibility to market their Lifeline-supported services in creative and innovative ways that are the most efficient and cost effective for them, the Commission declined to mandate model language for ETCs to include on their materials.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

Audit Requirements (Revised to Update the Descriptive Language of the Process and the Number of Respondents) (See 12k.). Pursuant to 47 C.F.R. § 54.420(b), USAC is required to conduct audits of new ETCs selected by the Commission’s Office of Managing Director, which oversees all audits within the program. These new company audits must be conducted within the first twelve months of the company seeking federal low-income universal service support within any single state to ensure its compliance with the rules as well as assess the company’s internal controls regarding the regulatory requirements.

Pursuant to 47 C.F.R. § 54.420(a), ETCs identified by USAC must conduct biennial independent audits and present audit reports to the Administrator, the Commission, and any applicable state or Tribal government agency within 30 days of the issuance of the final audit report. If there are no material findings in a carrier’s first independent audit, the Wireline Competition Bureau has the authority to relieve the ETC of its obligation to perform the biennial audits going forward.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

Designation of ETCs (Revised to Update the Number of Respondents) (See 12m.). Pursuant to 47 C.F.R. §§ 54.201, 54.400, 54.401, and 54.407, only ETCs that provide Lifeline service directly to subscribers will be eligible for reimbursement from the Fund. 47 C.F.R. § 54.202 requires carriers seeking to be designated as a Lifeline-only ETC to demonstrate their technical and financial capacity to provide the supported services. Additionally, pursuant to 47 C.F.R. § 54.202, every ETC receiving low-income support must annually provide to the Commission and USAC general information regarding their Lifeline plans for BIAS or voice telephony service offered specifically for low-income consumers. Finally, a carrier seeking to be designated as an ETC must certify that it will comply with the service requirements applicable to the support that it receives.

The 2019 Lifeline Order removes the Lifeline Broadband Provider ETC designation. This information collection has been updated to show that revision.

Electronic Signature (Revised to Update the Number of Respondents) (See 12n.). Pursuant to 47 C.F.R. § 54.419, ETCs, state agencies, and the National Verifier are permitted to obtain Lifeline subscriber certifications electronically, including through the use of interactive voice response systems, in compliance with the requirements of the E-Sign Act and the Government Paperwork Elimination Act. The E-Sign Act allows the use of electronic records to satisfy Commission regulations requiring that such information be provided in writing, if the consumer has affirmatively consented to such use and has not withdrawn such consent.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

National Verifier (Revised to Update the Number of Respondents) (See 12o. - 12s.). In the 2016 Lifeline Order, the Commission established a National Verifier to make eligibility determinations and perform other functions necessary to enroll eligible subscribers into the Lifeline Program. Prospective Lifeline subscribers will submit their information to the National Verifier, which will then verify subscriber eligibility.

As of November 2019, forty-eight states or U.S. territories will have transitioned to the National Verifier. These 48 states and U.S. territories account for approximately 60% of the Lifeline subscriber population, based on subscriber data from August 2019. For purposes of the hour burden estimates below, for those information collection requirements where the National Verifier is assuming requirements previously performed by ETCs, we reduce the burden estimate by 60% for the ETC-based requirements and shift the burden estimate to the National Verifier by 60%, where applicable.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

National Verifier Eligibility Application and Certifications (Revised to Update the Number of Respondents) (See 12o.). The eligibility application information collected will include the subscriber’s full name, last four digits of social security number or Tribal ID number, date of birth, information on whether the subscriber resides on Tribal lands, address of primary residence, information on whether the address is temporary and/or descriptive and whether it includes coordinates, mailing address (if different), full name of the qualifying person (if different from the subscriber), the last four digits of the qualifying person’s social security number or their Tribal ID number, the qualifying person’s date of birth, information on whether qualifying person resides on Tribal lands, name of the federal assistance program from which qualifying person receives benefits (i.e. Medicaid; Supplemental Nutrition Assistance Program; Supplemental Security Income; Federal Public Housing Assistance; Veterans and Survivors Pension benefit; or Tribal eligibility programs), household income (if qualifying through income), documents demonstrating eligibility, subscriber contact information, Lifeline subscriber identification number, security question, answer to security question, user name, password, agent identification information (if an agent is assisting in completing the application), subscriber’s eligibility certifications, and the subscriber’s signature and date. Once the prospective subscriber’s information is submitted, the subscriber’s eligibility will be verified through an automated process by checking federal and state data sources or, if necessary, by completing a manual review of eligibility documents. Information will be submitted via the National Verifier online portal or using FCC Form 5629 – Lifeline Program Application Form via a manual (paper) submission.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

National Verifier Consumer Eligibility Status Check (Revised to Update the Number of Respondents) (See 12p). The National Verifier will enable subscribers to check on the status of their eligibility applications. To complete the status check, the subscriber must provide their full name, last four digits of social security number or Tribal ID number, date of birth, ZIP code, application ID, contact information, Lifeline subscriber identification number, user name, password, security question, and answer to security question.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

National Verifier Tribal Verification/Certification (Revised to Update the Number of Respondents) (See 12q). The National Verifier will enable subscribers residing on Tribal lands to demonstrate their status as Tribal lands residents if their initial eligibility application is not approved during the automated eligibility verification process. As part of this certification, the subscriber will be asked to provide their full name, last four digits of their social security number or Tribal ID, date of birth, information on whether they reside on Tribal lands, address of primary residence, contact information, Lifeline subscriber identification number, user name, password, application ID, security question, answer to security question, information demonstrating that their address is on tribal lands, a certification stating that the subscriber lives on Tribal lands, signature, and date. In cases where documentation containing the individual’s full social security number is provided to USAC or the FCC, all but the last four digits of the number will be redacted by USAC or the FCC. The information will be submitted using the National Verifier online portal or proposed FCC Form 5629 – Lifeline Program Application Form.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

National Verifier Consumer Dispute Resolution (Revised to Update the Number of Respondents) (See 12r.). The National Verifier will enable subscribers to dispute eligibility findings. Information that must be provided to dispute the findings will include the subscriber’s full name, last four digits of social security number or Tribal ID number, date of birth, information on whether the subscriber resides on Tribal lands, address of primary residence, information on whether the address is temporary and/or descriptive and whether it includes coordinates, mailing address (if different), Lifeline subscriber identification number, full name of the qualifying person (if different), the last four digits of the qualifying person’s social security number or their Tribal ID number, the qualifying person’s date of birth, information on whether the qualifying person resides on Tribal lands, name of the federal assistance program from which subscriber receives benefits or household income if qualifying through income, any documents demonstrating eligibility and/or identity, subscriber contact information, application ID, security question, answer to security question, user name, password, the reason for the dispute, the subscriber’s eligibility certifications, and the subscriber’s signature and date.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

National Verifier Manual Recertification (Revised to Update the Number of Respondents) (See 12s.). The National Verifier will automatically complete the annual recertification process for most subscribers without the need for additional information from the subscriber by referencing applicable databases for qualifying programs. If, however, the recertification process cannot be completed automatically, the National Verifier will initiate a manual review process, requiring the subscriber to submit either a certification or updated eligibility information. This information will include the subscriber’s full name, last four digits of social security number or Tribal ID number, date of birth, information on whether the subscriber resides on Tribal lands, address of primary residence, information on whether the address is temporary and/or descriptive and whether it includes coordinates, Lifeline account phone number, Lifeline subscriber identification number, mailing address (if different), full name of the qualifying person (if different), the last four digits of the qualifying person’s social security number or their Tribal ID number, the qualifying person’s date of birth, name of the federal assistance program from which subscriber receives benefits or household income if qualifying through income, any documents demonstrating eligibility, subscriber contact information, security question, answer to security question, user name, password, application ID, subscriber’s eligibility certifications, and the subscriber’s signature and date. Information will be submitted via the National Verifier online portal or using FCC Form 5630 – Lifeline Program Annual Recertification Form.

As part of this information collection, the Commission proposes revised calculations for the burden hours associated with this requirement based on updated estimates of the number of respondents.

Representative Accountability Database Registration (Revised to Remove Requirements Related to Tribal Support Vacated by the D.C. Circuit Court, Clarify a Process, and Update Burden Estimate Accordingly) (See 12t.). While the Commission believes that agent information can be collected under the previously approved information collection, it seeks to clarify the registration process as codified by the 2019 Lifeline Order. Enrollment representatives, as defined by 47 C.F.R. § 54.400(p), are required to register for a representative identification number provided by USAC. This is in accordance with 47 C.F.R. § 54.406. In doing so, USAC revised its processes to require enrollment representatives to provide personal information sufficient for USAC to confirm an individual’s identity. This allows USAC to track that enrollment representative’s activity within its systems.

Deletions to Requirements in this Information Collection:

Lifeline ETCs Required to Send Written Notice that Customers Are No Longer Eligible for Enhanced Lifeline Support (Revised to Remove this Requirement). The Order creating this requirement was vacated by the D.C. Circuit Court of Appeals. As such, it has been removed from this information collection. Section 12t below now provides the burden estimate for the Representative Accountability Database Registration process.

Currently approved requirements in this information collection (no revisions):

Facilities-Based Requirements (No Revisions) (See 12l.). Each carrier that seeks to take advantage of the Commission’s decision to forbear from applying the Act’s facilities requirement of Section 214(e)(1)(A) and seek limited ETC designation to participate in the Lifeline program, must (i) comply with certain 911 requirements; and (ii) file, subject to Bureau approval, a compliance plan providing specific information regarding the carrier’s service offerings and outlining the measures the carrier will take to implement the obligations contained in the Lifeline Reform Order.

Some of the requirements contained in this information collection affect individuals or households, and thus, there are impacts under the Privacy Act.

Statutory authority is contained in Sections 1, 4(i), 5, 201, 205, 214, 219, 220, 254, 303(r), and 403 of the Communications Act of 1934, as amended, and section 706 of the Communications Act of 1996, as amended; 47 U.S.C. §§ 151, 154(i), 155, 201, 205, 214, 219, 220, 254, 303(r), 403, and 1302.

2. Use of Information. All the requirements and burdens contained herein are necessary to implement the congressional mandate for universal service. These reporting and compliance requirements are necessary to ensure that only eligible subscribers receive support and that ETCs are in compliance with the Commission’s rules. The 2019 Lifeline Order is part of the Commission’s ongoing efforts to eliminate waste and inefficiency in the Lifeline program.

3. Technological collection techniques. The FCC Form 481 Carrier Annual Reporting Data Collection Form, FCC Form 497 Lifeline Worksheet, FCC Form 555 Annual Lifeline Eligible Telecommunications Carrier Certification Form, FCC Form 5629 Lifeline Program Application Form, FCC Form 5630 Lifeline Program Annual Recertification Form, and FCC Form 5631 Household Worksheet are available via the Administrator’s website (www.usac.org). Carriers will have the option to file FCC Form 497 electronically, by email, or by fax. The National Lifeline Accountability Database is accessed and updated via the Internet. Carriers may also provide subscriber data via a batch process. The electronic signature section of the rules will allow ETCs to communicate with subscribers not only on paper but by phone and text. The Commission also encourages ETCs to take advantage of electronic storage of documents to mitigate the additional expense of having to retain documentation demonstrating subscriber income-based or program-based eligibility, including the NLAD dispute resolution processes. In states where the National Verifier has launched, the National Verifier will collect information by Internet, phone, or mail. Consumers and ETCs may also submit information to the National Verifier and NLAD via a Consumer Portal, Service Provider Portal, or Application Programming Interface (API) link. The National Verifier will include the option to complete the Lifeline Program Application online in English or Spanish. Finally, enrollment representatives will submit their information via the Representative Accountability Database, which is built within the NLAD environment.

4. Efforts to identify duplication. There will be no duplication of information. The information sought is unique to each carrier or respondent and similar information is not already available. During the Transition Period associated with the National Verifier, subscribers and ETCs will provide information either using the existing information process or the National Verifier process, depending on whether the relevant state has transitioned to the National Verifier.

5. Impact on small entities. The collection of information may affect small entities as well as large entities. In conformance with the Paperwork Reduction Act of 1995, the Commission is making an effort to minimize the burden on all respondents, regardless of size. The Commission has limited the information requirements to those that are necessary to verify eligibility for Lifeline program support and compliance with the Lifeline program. Additionally, the Commission has encouraged ETCs to take advantage of electronic storage of documents to mitigate any burden on small and large entities of having to retain documentation demonstrating subscriber income-based or program-based eligibility, including the NLAD dispute resolution processes. The Commission anticipates that the launch of the National Verifier may benefit small ETCs to the extent they will no longer be responsible for conducting the eligibility determination process and retaining associated documents.

6. Consequences if information is not collected. Without the requested information, the Commission will be unable to determine that all subscribers are eligible to receive support and provide certainty in the industry regarding the documents that need to be retained in the event of an audit or investigation. By ensuring that only ETCs that provide Lifeline service directly to subscribers are eligible for reimbursement from the Fund, the Commission can also better promote transparency. Ultimately, with the requested information, the Commission can more efficiently and effectively protect the USF and prevent significant waste, fraud, and abuse in the Lifeline program.

7. Special circumstances. There are no special circumstances associated with this information collection.

8. Federal Register notice; efforts to consult with persons outside the Commission. Pursuant to 5 C.F.R. § 1320.8(d), the Commission published a notice in the Federal Register to solicit public comment on the revised information collection requirements on February 20, 2020 (85 FR 9765). No PRA comments were received.

9. Payments or gifts to respondents. There will be no payments or gifts to respondents.

10. Assurances of confidentiality. We note that USAC must preserve the confidentiality of all data obtained from respondents and contributors to the universal service support program mechanism, must not use the data except for purposes of administering the universal service support program, and must not disclose data in company-specific form unless directed to do so by the Commission. We also note that ETCs and the National Verifier must also preserve the confidentiality of all subscriber eligibility documentation. This documentation must be retained for as long as the subscriber receives Lifeline service from the ETC, but no less than three calendar years. Also, respondents may request materials or information submitted to the Commission or USAC be withheld from public inspection under section 0.459 of the Commission’s rules.

11. Questions of a sensitive nature. Some of the requirements contained in this information

collection affect individuals or households, and thus, there are impacts under the Privacy Act. The FCC’s system of records notice (SORN) associated with this collection is FCC/WCB-1, “Lifeline Program.” The Commission will use the information contained in FCC/WCB-1 to cover the personally identifiable information (PII) that is required as part of the Lifeline Program (“Lifeline”). As required by the Privacy Act of 1974, as amended, 5 U.S.C. § 552a, the Commission published a SORN, FCC/WCB-1 “Lifeline Program” in the Federal Register on August 15, 2017 (82 FR 38686).

12. Estimates of the hour burden of the collection to respondents. The following represents the hour burden on the collections of information:

1. Lifeline ETC Reimbursement Process Using Snapshot Report or FCC Form 497 (Revised to Update the Number of Respondents).

1. Number of Respondents: Approximately 750 ETCs.

2. Frequency of Response: Monthly and on occasion reporting requirements. The Commission estimates that it takes 1 hour to review and submit the NLAD database snapshot or complete the FCC Form 497.

3. Annual hour burden per respondent: 12 hours annually. 1 hour to prepare each monthly submission. Total annual reporting burden is 9,000 hours (750 ETCs x 12 mos. x 1 hour).

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $360,000.

5. Explanation of calculation: 9,000 burden hours for all ETCs x $40 per hour = $360,000.

2. FCC Form 555 - Annual Reporting of Subscriber Recertification (Revised to Update the Number of Respondents).

1. Number of Respondents: Approximately 750 ETCs.

2. Frequency of Response: Annual reporting requirement.

3. Annual Hour Burden per Respondent: 16 hours annually. We estimate that it will take each ETC 16 hours annually to compile the re-certification form and submit it to USAC. Total annual reporting burden is 12,000 hours (750 ETCs x 16 hours).

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $480,000.

5. Explanation of calculation: 12,000 burden hours for all ETCs x $40 per hour = $480,000.

3. FCC Form 481 – Carrier Annual Reporting Requirements (Revised to Update the Number of Respondents).

   1. Number of Respondents: Approximately 750 ETCs.

   2. Frequency of Response: Annual reporting requirement.

   3. Annual hour burden per respondent: 3 hours annually. Total annual reporting burden is 2,250 hours (750 ETCs x 3 hours).

   4. Total estimate of in-house cost to respondents for the burdens for collection of information: $90,000.

   5. Explanation of calculation: 2,250 burden hours for all ETCs x $40 per hour = $90,000.

4. FCC Form 5629 – Lifeline Program Application Form and Certification of Eligibility Upon Enrollment (Revised to Update the Number of Respondents).

1. Number of Respondents: 750 ETCs and 4,022,417 new subscribers. This certification requirement, along with documentation applies only to new subscribers. We estimate that there will be approximately 4,022,417 new subscribers. Whether a state is in the National Verifier or not, we estimate that 5% of new subscribers (201,121) will sign up by mailing in documentation and 95% (3,821,296) of new subscribers will be able to verify their eligibility electronically.

2. Frequency of Response: Once for new Lifeline service.

3. Annual hour burden per respondent: For subscribers whose eligibility can be verified through a database, we estimate that the ETC representative or a state (where applicable) will take no longer than .33 hours (20 minutes) to query any applicable database (3,821,296 subscribers x .33 hours = 1,261,028 hours) and the subscribers will take .25 hours (15 minutes) to complete the Proposed FCC Form 5629 Lifeline Program Application Form (3,821,296 subscribers x .25 hours = 955,324 hours). For subscribers whose eligibility must be determined through documentation, we estimate that it will take ETCs 45 minutes (.75 hours) to review and maintain a record of the proposed FCC Form 5629 Lifeline Program Application Form where applicable (201,121 x .75 hours = 150,841 hours). In addition, we estimate that it will take these subscribers approximately .25 hours (15 minutes) to fill out the proposed FCC Form 5629 Lifeline Program Application Form (201,121 subscribers x .25 hours = 50,280 hours). Therefore, the total annual burden is 1,005,604 (955,324 + 50,280) hours for subscribers and 1,411,869 (1,261,028 + 150,841) hours for ETCs. 1,005,604 + 1,411,869 = 2,417,473 total annual hours.

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $63,765,389.

5. Explanation of calculation: We estimate the cost to Lifeline consumers to retrieve and provide the required documentation and complete the FCC Form 5629 Lifeline Program Application Form is $7.25 per hour x 1,005,604 burden hours = $7,290,629. The $7.25 per hour burden amount for subscribers is appropriate because the upper bound of eligible income for Lifeline represents an hourly wage rate of $7.88 for a person working 40 hours a week (i.e., $16,389 divided by 2,080 hours).  Many Lifeline recipients, however, are unemployed or work for lower wages.  Moreover, they have the flexibility of signing up for Lifeline at any time during the week, allowing them to choose a time causing the least interference with their schedules.  We therefore believe that the current federally mandated minimum wage of $7.25 represents a more reasonable upper bound for the value of a consumer hour. In addition, we estimate to sign the subscriber up for Lifeline it will cost the ETC staff $40 per hour x (1,411,869 burden hours = $56,474,760). $7,290,629 + $56,474,760 = $63,765,389.

5. FCC Form 5630 – Lifeline Program Annual Recertification Form (Revised to Update the Process, Number of Respondents, and Annual Hour Burden Per Respondent).

1. Number of Respondents: 750 ETCs and 4,022,417 new subscribers. ETCs affected amount by the National Verifier transition (60%) transition: 450 (750 x .6). After the National Verifier (60%) transition: 300 (750 – 450). For new subscribers, affected by the National Verifier transition (60%) transition: 2,413,450 (4,022,417 x .6) leaving 1,608,967 new subscribers (4,022,417 – 2,413,450). ETCs are required to confirm the eligibility of all Lifeline subscribers on an annual basis. We estimate that there are approximately 7,335,951 Lifeline subscribers. Past experience has shown that 35% of the program de-enrolls prior to recertification and 10% of the subscribers are new and do not require recertification in the reporting year. This leaves 4,034,773 subscribers requiring recertification. (7,335,951 – 2,567,583 (35% de-enrolled) – 733,595 (10% new not requiring recertification in the reporting year) = 4,034,773. This number must then be adjusted to reflect the reduced number after the National Verifier transition: 2,420,864 (4,034,773 x .6) leaving 1,613,909 subscribers (4,034,773 – 2,420,864). We estimate 1,613,909 x .45 = 726,259 can be re-certified using a database or third-party administrator, leaving 887,650 to be re-certified through a paper, phone, or text process (1,613,909 – 726,259 (45% re-certified using a database or third-party administrator) = 887,650). There are approximately 750 ETCs to whom these requirements apply. 888,400 respondents (750 ETCs + 887,650 re-certified manual respondent subscribers).

2. Frequency of Response: Annual reporting requirement.

(3) Annual hour burden per respondent: ETCs may confirm eligibility of their

subscribers by querying a database maintained for that purpose. If such a database is not available, ETCs must collect signed certifications from subscribers attesting to their continued eligibility, which can be done by phone and text. If a subscriber was previously deemed eligible via database check and their eligibility can longer be confirmed via database, then an ETC must solicit additional documentation from a subscriber to confirm their eligibility to participate in the Lifeline program. We estimate that approximately 15% of subscribers that previously confirmed their eligibility via a database check will be unable to re-confirm their eligibility via a database check and will be required by new recertification requirements to submit additional documentation. This requirement will impact 108,939 subscribers (726,259 x .15). As the 45% database validation check tends to hold across all validations for this group, applying a 15% rate to that number gives us a reasonable estimate of who might fall into the group needing to provide additional documentation for re-certification. To avoid double counting, we remove this number from the prior subscribers (887,650) that need to re-certify through a paper, phone, or text process. This yields 778,711 subscribers that will need to re-certify strictly through a self-certification paper, phone, or text process (887,650 – 108,939) = 778,711. We estimate that it will take Lifeline subscribers .25 hours (15 minutes) to read and sign a certification (778,711 subscribers x .25 hours = 194,678 hours). We estimate that it will take Lifeline subscribers required to submit additional documentation to re-certify approximately .75 hours (45 minutes) to compile and submit their documentation (108,939 subscribers x .75 hours = 81,704 hours). Similarly, we estimate that the ETC officer will take no longer than 45 minutes (.75 hours) to contact all impacted subscribers and obtain and validate a response (.75 hours x 887,650 subscribers = 665,738 hours). In addition, we estimate it will take no more than 15 minutes (.25 hours) for ETCs to query eligibility databases to perform an initial database check and re-certify eligibility for all impacted subscribers 1,613,909 subscribers x .25 hours = 403,477 hours. The total annual burden is 194,678 hours for subscribers’ certification + 81,704 for subscribers’ document submission + 665,738 hours for ETC verification of subscribers’ certification + 403,477 hours to run subscribers through a database check = 1,345,597 hours.

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $44,772,370.

5. Explanation of calculation: We estimate the cost to Lifeline consumers to read, prepare, and sign the required documentation, if any, provided by the ETC is $7.25 per hour (194,678 + 81,704) = 276,382 hours x $7.25 = $2,003,770). In addition, we estimate it will cost the ETC staff $40 per hour to either query the necessary database ($40 x 403,477 burden hours = $16,139,080) + review the subscriber verifications ($40 x 665,738 burden hours = $26,629,520) totaling $42,768,600. Subscriber cost of $2,003,770 + ETC cost of $42,768,600 = $44,772,370.

6. Lifeline Recordkeeping 47 C.F.R. § 54.417 (Revised to Update the Number of Respondents).

1. Number of Respondents: Approximately 750 ETCs.

2. Frequency of Response: Annual reporting requirement.

3. Annual hour burden per respondent: 1 hour annually to maintain records. The total annual reporting burden is 750 hours (750 ETCs x 1 hour).

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $30,000.

5. Explanation of calculation: 750 burden hours for all ETCs x $40 per hour = $30,000.

7. Maintenance of National Lifeline Accountability Database (Revised to Update the Number of Respondents).

   1. Number of Respondents: 750 ETCs.

   2. Frequency of Response: Daily or monthly reporting requirement.

   3. Annual hour burden per respondent: 100 hours (we estimate it will take each ETC 8.33 hours to interface each month with the duplicates database x 12 months). Total burden hours for all respondents are 74,970 hours (8.33 hours x 12 mos. x 750 ETCs).

   4. Total estimate of in-house cost to respondents for the burdens for collection of information: $2,998,800.

   5. Explanation of calculation: We estimate it will cost ETCs $40 per hour to compile the requisite information and prepare the report. 74,970 burden hours for all ETCs x $40 per hour = $2,998,800.

8. FCC Form 5631 – Household Worksheet (Revised to Update the Number of Respondents).

   1. Number of Respondents: An estimated 18% of new subscribers will need to

file. 4,022,417 x .18 = 724,035 subscribers and 750 ETCs.

2. Frequency of Response: one-time.

3. Annual burden per respondent: 15 minutes (.25 hours) for subscribers to complete the proposed FCC Form 5631. 181,009 hours for subscribers (724,035 x .25). 15 minutes (0.25 hours) for ETCs to review and maintain record in states that have not transitioned to the NV. To determine the number of proposed FCC Form 5631 filings ETCs will need to obtain (which will only be necessary in areas that have not transitioned to the NV): 4,022,417 x .6 = 2,413,450. 4,022,417 – 2,413,450 = 1,608,967. 1,608,967 is the total of new subscribers in states that have not transitioned to the National Verifier. Of these 18% (1,608,967 x .18 = 289,614) are likely to need a Household Worksheet filing. It will take ETCs .25 hours per subscriber to review and maintain the one-per-household certification. 289,614 x .25 = 72,404 hours to review and maintain the Household Worksheet. Total burden hours are 181,009 + 72,404 = 253,413.

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $4,208,475.

5. Explanation of calculation: (181,009 burden hours for subscribers x $7.25 = $1,312,315) + (72,404 burden hours for ETCs x $40 = $2,896,160) = $4,208,475.

9. Subscriber Usage (Revised to Update the Number of Respondents).

1. Number of Respondents: Approximately 40 ETCs that do not assess and collect a monthly fee from its subscribers (serving approximately 7,000,000 pre-paid consumers).

2. Frequency of Response: Every 60 days (annualized reporting requirement for burden calculation purposes).

3. Annual hour burden per respondent: Fifteen minutes (.25 hours) to contact those subscribers who do not use their Lifeline service. We estimate that approximately 25% of the 7,000,000 pre-paid consumers do not use the Lifeline service (1,750,000 subscribers). Total burden hours for all respondents are 437,500 hours (.25 hours x 1,750,000 subscribers). (Note: costs associated with reporting requirements, updating the database, and de-enrolling subscribers for non-use are included in 12.a, above).

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $17,500,000.

5. Explanation of calculation: We estimate it will cost ETCs $40 per hour to contact their subscribers. $40 per hour x 437,500 burden hours for all respondents = $17,500,000.

10. Marketing and Outreach (Revised to Update the Number of Respondents).

(1) Number of Respondents: 750 ETCs.

(2) Frequency of Response: Once and on occasion reporting requirement.

(3) Annual hour burden per respondent: 20 hours once to update existing marketing materials. .5 hours (30 minutes) on occasion to include required language on new material. Total burden hours for all respondents are 15,375 hours (20.5 hours x 750 ETCs)

(4) Total estimate of in-house cost to respondents for the burdens for collection of information: $615,000.

(5) Explanation of calculation: We estimate it will cost ETCs $40 per hour to update their marketing materials. 15,375 burden hours for all ETCs x $40 per hour = $615,000.

11. Audit Requirements (Revised to Update the Descriptive Language of the Process and the Number of Respondents).

1. Number of Respondents: Approximately 40 ETCs (10 first-year ETCs must comply with new audit requirements; 30 ETCs, to be identified by a USAC-developed risk register).

2. Frequency of Response: For first-year ETCs, once; for ETCs identified by USAC’s risk register, biennially unless directed by the Commission.

3. Annual hour burden per respondent: 30 total hours for the 10 ETCs subjected to a first-year audit (3 hours per ETC); 3,750 total hours for the 30 ETCs conducting biennial audits every 2 years (250 hours per ETC per audit; 125 hours annualized). Total annual burden for all ETCs is 3,780 hours (10 ETCs x 3 hours = 30 hours) + (30 ETCs x 125 hours = 3,750 hours) = 3,780.

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $151,200.

5. Explanation of calculation: $151,200 = (3,780 burden hours x $40 per hour)

12. Facilities Based Requirements (No Revisions).

1. Number of Respondents: Approximately 5 ETCs.

2. Frequency of Response: One-time reporting requirement.

3. Annual hour burden per respondent: 250 hours annually. We estimate that ETCs who want to take advantage of blanket forbearance will take 50 hours to prepare and file their compliance plans. The total annual reporting burden for all applicable ETCs is 250 hours (5 ETCs x 50 hours).

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $10,000.

5. Explanation of calculation: 250 burden hours for ETCs x $40 per hour = $10,000.

13. Designation of ETCs (Revised to Update the Number of Respondents).

    1. Number of Respondents: Approximately 15 Lifeline-only ETCs and 10 non-ETCs.

    2. Frequency of Response: One-time, upon designation as an ETC.

    3. Annual hour burden per respondent: We estimate it will take a carrier seeking ETC designation 20 hours to compile the requisite information to demonstrate its technical and financial capacity to provide the supported services and that it will comply with the service requirements applicable to the support it receives. The total burden for all carriers seeking such designation is 500 hours (25 respondents x 20 hours). We included our estimate of the time it will take ETCs to compile the requisite information and report its Lifeline plans to the Commission and Administrator in the calculation for Annual Reporting Requirement, section 12.b. above.

    4. Total estimate of in-house cost to respondents for the burdens for collection of information: $20,000.

    5. Explanation of calculation: We estimate it will cost ETCs $40 per hour to compile the information and prepare the appropriate reports. 500 burden hours x $40 per hour = $20,000.

14. Electronic Signature (Revised to Update the Number of Respondents).

    1. Number of Respondents: We estimate that there will be approximately. 4,022,417 new Lifeline subscribers who sign up for Lifeline annually (201,121 (5%) who sign up by presenting documentation and 3,821,296 (95%) whose eligibility can be verified electronically). We estimate that subscribers whose eligibility is verified electronically will also use electronic signatures. ETCs are also required to confirm the eligibility of all Lifeline subscribers on an annual basis. After subtracting 35% for de-enrollment and 10% for new subscribers from the total number of Lifeline subscribers consistent with the explanation in 12.e. above, we estimate that 4,034,773 subscribers require recertification. 7,335,951 – 2,567,583 (35% de-enrolled) – 733,595 (10% new not requiring recertification in the reporting year) = 4,034,773. We estimate 1,815,648 (4,034,773 x .45 = 1,815,648) can be re-certified using a database or third-party administrator, leaving 2,219,125 to be re-certified through a paper, phone, or text process (4,034,773 – 1,815,648 = 2,219,125). Of those 2,219,125 subscribers, we estimate that approximately 51% (2,219,125 x .51 = 1,131,754) subscribers will recertify electronically and 49% (2,219,125 x .49 = 1,087,371) will recertify via paper submission. There are approximately 750 ETCs to whom these requirements apply. 4,953,050 respondents (1,131,754 subscribers recertify electronically + 3,821,296 new subscribers sign up electronically).

    2. Frequency of Response: Once per subscriber for new Lifeline service and annually per subscribers thereafter.

    3. Annual hour burden per respondent: For subscribers whose eligibility can be verified through a database, we estimate that the subscribers will take 0.0167 hours (1 minute) to electronically sign the certification form (3,821,296 subscribers x 0.0167 hours = 63,816 hours). For recertification, we estimate that it will take those Lifeline subscribers who recertify electronically 1 minute (0.0167 hours) to electronically sign a certification (1,131,754 subscribers x 0.0167 hours = 18,900 hours). Therefore, the total annual burden is 82,716 hours for subscribers using electronic signatures (63,816 hours + 18,900 hours = 82,716 hours).

    4. Total estimate of in-house cost to respondents for the burdens for collection of information: $599,691.

    5. Explanation of calculation: We estimate the cost to Lifeline consumers to electronically sign certification and recertification forms is $7.25 per hour (82,716 hours x $7.25 = $599,691).

15. National Verifier Eligibility Application and Certifications (Revised to Update the Number of Respondents).

    1. Number of Respondents: 4,022,417 new subscribers. Adjusting for the National Verifier (60%) transition means 2,413,450 subscribers (4,022,417 x .6).

    2. Frequency of Response: Once per subscriber for new Lifeline service.

    3. Annual hour burden per respondent: We estimate that 70% will be able to complete eligibility information intake electronically and 30% will follow a manual process. We estimate it will take 0.25 hours to complete the eligibility intake information electronically and 0.50 hours to complete the eligibility intake using a manual process. 1,689,415 electronically submitted subscribers (.7 x 2,413,450). 724,035 manual subscribers (.3 x 2,413,450). The total hour burden estimate is 784,372 hours (1,689,415 subscribers x .25 hours = 422,354) + (724,035 subscribers x .50 hours = 362,018).

    4. Total estimate of in-house cost to respondents for the burdens for collection of information: $5,686,697.

    5. Explanation of calculation: 784,372 estimated burden hours x $7.25 per hour = $5,686,697.

16. National Verifier Consumer Eligibility Status Check (Revised to Update the Number of Respondents).

    1. Number of Respondents: 4,022,417 new subscribers. Adjusting for the National Verifier (60%) transition means 2,413,450 subscribers (4,022,417 x .6).

    2. Frequency of Response: Estimated once per subscriber.

    3. Annual hour burden per respondent: We estimate it will take 15 minutes to complete the Eligibility Status check. The total annual reporting burden is 603,363 hours (2,413,450 subscribers x .25 hours).

    4. Total estimate of in-house cost to respondents for the burdens for collection of information: $4,374,382.

    5. Explanation of calculation: 603,363 burden hours for subscribers x $7.25 per hour) = $4,374,382.

17. National Verifier Tribal Verification /Certification (Revised to Update the Number of Respondents).

    1. Number of Respondents: 4,022,417 new subscribers. Adjusting for the National Verifier (60%) transition means 2,413,450 subscribers (4,022,417 x .6). Estimated percentage of tribal participants: 72,404 (3% of participants x 2,413,450). Estimated percentage that would require self-certification through a manual process: 7,240 (10% of 72,404 tribal participants).

    2. Frequency of Response: Once per subscriber.

    3. Annual hour burden per respondent: 1 hour per respondent. Total annual reporting burden is 7,240 hours (1 hour x 7,240 subscribers).

    4. Total estimate of in-house cost to respondents for the burdens for collection of information: $52,490

    5. Explanation of calculation: 7,240 burden hours for subscribers x $7.25 per hour = $52,490.

18. National Verifier Consumer Dispute Resolution (Revised to Update the Number of Respondents).

    1. Number of Respondents: 4,022,417new subscribers. Adjusting for the National Verifier (60%) transition means 2,413,450 subscribers (4,022,417 x .6).

    2. Frequency of Response: Once per subscriber.

    3. Annual hour burden per respondent: We estimate it will take no more than 30 minutes to submit the information for the Dispute Resolution. Total annual reporting burden is 1,206,725 hours (2,413,450 subscribers x 0.50 hours).

    4. Total estimate of in-house cost to respondents for the burdens for collection of information: $8,748,756.

    5. Explanation of calculation: The cost for subscribers is $7.25 per hour. 1,206,725 burden hours for subscribers x $7.25 per hour = $8,748,756.

19. National Verifier Manual Recertification (Revised to Update the Number of Respondents).

Automatic recertification will be possible in most cases (making 12.e above no longer

necessary for states/territories that have transitioned to the National Verifier), but we

estimate that about 20% will need to be conducted manually. For these 20%, we estimate that 90% can be recertified by submitting a certification and 10% will need to recertify by supplying additional documentation.

1. Number of Respondents: 7,335,951 Lifeline subscribers. Number of Subscribers based on the National Verifier (60%) transition: 4,401,571 (7,335,951 x .6). As discussed in 12.e above, 35% typically de-enroll and 10% are new and do not require re-certification. 4,401,571 subscribers - (.35 x 4,401,571 = 1,540,550) - (.1 x 4,401,571 = 440,157) = 2,420,864 respondents. We estimate 20% of the re-certifications as 484,173 respondents (.2 x 2,420,864) will need to be done manually. We further estimate that 15% of individuals who previously validated their eligibility via a database check will fail that database check on re-certification and will have to provide additional materials to confirm their eligibility in accordance with our new recertification requirements. This impacts approximately 363,130 subscribers (2,420,864 x .15). To avoid double counting, we remove that number from the total anticipated respondents for the manual process, to come up with 121,043 subscribers (484,173 – 363,130) that will need to complete their recertification via a manual self-certification.

2. Frequency of Response: Annual requirement.

3. Annual burden hour per respondent: We estimate that it will take Lifeline subscribers .25 hours (15 minutes) to read and sign a certification totaling 30,261 hours (121,043 subscribers x .25 hours). In addition, for those subscribers who need to be verified by providing additional documentation, we estimate it will take subscribers 45 minutes (0.75 hours) to obtain and submit their documentation for a total of 272,348 hours (363,130 respondents x 0.75 hours). Similarly, we estimate it will take ETCs 45 minutes (.75 hours) to contact and validate each manual subscribers’ submission for a total of 363,130 hours (484,173 x .75 hours). Additionally, we estimate that it will take no more than 15 minutes (.25 hours) for ETCs to query eligibility databases to perform an initial database check for all impacted subscribers in the re-certification pool. This results in a total of 605,216 hours (.25 x 2,420,864). The total number of burden hours is 1,270,955 (30,261 self-certification + 272,348 manual documentation submission + 363,130 ETC contact and validation + 605,216 ETC initial database check).

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $40,927,755.

5. Explanation of calculation: The cost for subscribers is $7.25 per hour (30,261 + 272,348 = 302,609 x $7.25 = $2,193,915). The cost for ETCs is $40 per hour (363,130 + 605,216 = 968,346 x $40 = $38,733,840). The total for subscribers and ETCs is $40,927,755.

20. Representative Accountability Database Registration (Revised to Reflect a New Requirement and Remove the Prior Requirement Detailed in 12t)

1. Number of Respondents: Approximately 10,000. Of this, we estimate that 15% (10,000 x .15 = 1,500) respondents, will have to complete the process manually and submit additional documentation.

2. Frequency of Response: One-time.

3. Annual hour burden per respondent: We estimate that it will take enrollment representatives 15 minutes (.25 hours) to complete the automatic registration process. This yields an initial hours burden of 2,500 hours (10,000 x .25). For representatives that have to complete the process manually, we estimate a further 45 minutes (.75 hours) to compile and submit documentation, yielding an additional 1,125 hours (1,500 x .75 = 1,125). Total annual reporting burden is 3,625 hours (2,500 automatic + 1,125 manually).

4. Total estimate of in-house cost to respondents for the burdens for collection of information: $145,000.

5. Explanation of calculation: 3,625 burden hours x $40 per hour for ETC staff time = $145,000.

The estimated respondents and responses and burden hours are listed below:

	Number of Respondents	Number of Responses Per Year Per Respondent	Number of Responses Per Year	Estimated Time per Response (hours)	Total Burden Hours	In-House Costs to Respondents
a. Lifeline ETC Reimbursement Process Using Snapshot Report or FCC Form 497	750	12	9,000	1	9,000	$ 360,000
b. FCC Form 555 - Annual Reporting of Subscriber Recertification	750	1	750	16	12,000	$ 480,000
c. FCC Form 481 - Carrier Annual Reporting Requirements	750	1	750	3	2,250	$90,000
d. FCC Form 5629 - Lifeline Program Application Form and Certification of Eligibility Upon Enrollment	4,023,167	1	4,023,167	.25-.75	2,417,473	$ 63,765,389
e. FCC Form 5630 - Lifeline Program Annual Recertification Form	888,400	1	888,400	.25-.75	1,345,597	$ 44,772,370
f. Lifeline Recordkeeping, 47 C.F.R. § 54.417	750	1	750	1	750	$ 30,000
g. Maintenance of National Lifeline Accountability Database	750	12	9,000	8.33	74,970	$ 2,998,800
h. FCC Form 5631 - Household Worksheet	724,785	1	724,785	0.25	253,413	$ 4,208,475
i. Subscriber Usage	40	43,7501	1,750,000	0.25	437,500	$17,500,000
j. Marketing and Outreach	750	1	750	20.5	15,375	$615,000
k. Audit Requirements	40	1	40	3 - 125	3,780	$151,200
l. Facilities Based Requirements	5	1	5	50	250	$10,000
m. Designation of ETCs	25	1	25	20	500	$20,000
n. Electronic Signature	4,953,050	1	4,953,050	0.0167	82,716	$599,691
o. National Verifier Eligibility Application and Certifications	2,413,450	1	2,413,450	.25 - .50	784,372	$5,686,697
p. National Verifier Consumer Eligibility Status Check	2,413,450	1	2,413,450	.25	603,363	$4,374,382
q. National Verifier Tribal Verification / Certification	7,240	1	7,240	1	7,240	$52,490
r. National Verifier Consumer Dispute Resolution	2,413,450	1	2,413,450	0.5	1,206,725	$8,748,756
s. National Verifier Manual Recertification	484,173	1	484,173	.25 - .75	1,270,955	$40,927,755
t. Representative Accountability Database Registration	10,000	1	10,000	.25 - .75	3,625	$ 145,000
Total:	18,335,775	43,791	20,102,235	0.0167-125	8,531,854	$ 195,536,005

Total Number of Respondents: 18,335,775

Total Number of Responses Annually: 20,102,235

Total Annual Burden Hours: 8,531,854

Total In-House Costs: $195,536,005

13. Estimates of the cost burden of the collection to respondents. The Commission estimates that there will be approximately 30 ETCs identified by USAC’s audit risk register as candidates for biennial independent audits, unless directed otherwise by the Commission. To fulfill this requirement, ETCs hire outside independent consultants/auditors at an hourly rate of $250 per hour to perform the audits on behalf of the ETCs.

Therefore, the annual cost to respondents is as follows: 30 ETCs x 125 hours² x $250 per hour = $937,500.

14. Estimates of the cost burden to the Commission. There will be few, if any additional costs to the Commission because notice and enforcement requirements are already part of Commission duties. Moreover, there will be minimal cost to the Federal government since an outside party administers the program.

15. Program change or adjustment. The Commission is reporting program changes to this information collection as a result of the 2019 Lifeline Order.    The total number of respondents increased by 787,932 (from 17,547,843 to 18,335,775 respondents), the total number of annual responses decreased by -5,043,268 (from 20,317,788 to 15,274,520 responses), and the total annual burden hours decreased by -5,385,594 (from 10,972,641 to 5,587,047 hours).

The Commission also has adjustments to this information collection which are due to the Commission re-evaluating the previous figures used in this collection to better reflect experience in administrating the collections.  For these adjustments, the total number of annual responses increased by +4,827,715 (from 15,274,520 to 20,102,235 responses), and the total annual burden hours increased by +2,944,807 (from 5,587,047 to 8,531,854 hours, of this 8,531,854)(of the +2,944,807 hours adjustments of +36 hours are due to a miscalculation in the burden hours from the 2018 submission to OMB).

16. Collections of information whose results will be published. Non-confidential information may be made public through reports from the universal service Administrator for the Commission.

17. Display of expiration date for OMB approval of information collection. The Commission seeks continued approval not to display the expiration date of OMB approval on all of the forms. Display of the expiration date would not be in the Commission’s interest because we would have to update the electronic copy each time this collection is submitted to OMB for review and approval. This would constitute waste and would not be cost effective.

18. Explain any exceptions to the statement certifying compliance with 5 C.F.R. § 1320.9 and the related provisions of 5 C.F.R. §1320.8(b)(3). There are no exceptions to the Certification Statement.

B. Collections of Information Employing Statistical Methods:

The Commission does not anticipate that this collection of information will employ statistical methods.

1 This number was calculated by taking the Number of Responses per year and dividing by the Number of respondents: 1,750,000 ÷ 40 = 43,750.

2 It takes approximately 250 hours every two years to conduct the audits. The Commission annualized this figure which is 125 hours annually to conduct the audits.

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