Federal Communications Commission
Washington, D.C. 20554
December 6, 2011
D. Scott Barash DA 11-1986
Acting Chief Executive Officer
Universal Service Administrative Company
2000 L St., N.W., Suite 200
Washington, DC 20036
Dear Mr. Barash:
On June 21, 2011, the Wireline Competition Bureau (Bureau) provided the Universal Service 
Administrative Company (USAC) with guidance on the process USAC should follow in 
identifying and resolving duplicative Lifeline claims found through in-depth data validations 
(IDVs) (“Duplicate Resolution Process”).1 We provided this guidance letter at the same time the 
Commission issued the 2011 Duplicative Program Payments Order, which amended sections 
54.401 and 54.405 of the Commission’s rules to provide that no qualifying consumer is permitted 
to receive more than one Lifeline subsidy at a given time.2 The Duplicate Resolution Process has 
been a cooperative effort between ETCs, USAC, the ETCs’ third party vendor, and FCC staff.  To 
date, the Duplicate Resolution Process has involved USAC identifying duplicative Lifeline 
claims, notifying the duplicate subscribers and sending the ETCs lists of subscribers to de-enroll 
after the notice period.  The ETCs’ third-party vendor, 3PV, has handled the customer care 
function of the process to date.3  
The current three-phase process is expected to finish in January 2012.  Given the success of this 
process in reducing duplicative Lifeline support, we expect USAC to undertake additional phases 
to identify and resolve duplicative Lifeline claims in additional states.  We direct USAC to issue a 
request for proposals (RFP) by January 16, 2012, to procure customer care functionalities for the 
Duplicate Resolution Process so that it can continue with targeted IDVs in select states when 
directed by the Bureau.  The customer care functionalities include operating a toll free number to 
be equipped with an Interactive Voice Response (IVR) system capable of receiving customer 
feedback from multiple customers simultaneously, multiple live operators equipped to assist 
  
1 See generally Letter from Sharon E. Gillett, Chief, Wireline Competition Bureau, Federal 
Communications Commission, to D. Scott Barash, Acting Chief Executive Officer, Universal Service 
Administrative Company, 26 FCC Rcd 8588 (Wireline Comp. Bur. June 21, 2011) (June 21 Guidance 
Letter).  The Bureau directed USAC to coordinate with the ETCs involved in the state-specific IDVs to 
implement that process.  Id. at 8589.
2 Lifeline and Link Up Reform and Modernization, Federal-State Joint Board on Universal Service, Lifeline 
and Link Up, CC Docket No. 96-45, Report and Order, WC Docket Nos. 11-42, 03-109, 26 FCC Rcd 9022 
(2011) (2011 Duplicative Program Payments Order).
3 Tasks performed by 3PV have included: the placing of automated reminder calls to those subscribers who 
do not make a selection of a single Lifeline provider within a 30-day period (subscribers have also had the 
opportunity to connect to a live operator and select a single Lifeline provider as part of the automated 
reminder calls made by 3PV); tracking subscriber provider selections; and, after the 35-day period has 
expired, providing USAC with an updated allocation list to reflect subscriber-generated provider selections. 
2
subscribers with questions about the process, and automated calls to subscribers who have failed 
to make a selection within the notice period.
If you have any questions regarding this letter, please do not hesitate to contact me at 202-418-
1500.
Sincerely,
Sharon E. Gillett
Chief
Wireline Competition Bureau