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The Honorable Thomas Wheeler 
Chairman 
Federal Communications Commission 
445 121h Street, SW 
Washington, DC 20554 
Dear Chairman Wheeler: 
June 18, 2015 
We write to share our thoughts regarding modernization of the Lifeline program supported by the 
federal Universal Service Fund. The Lifeline program was created in 1985 and has been 
invaluable in enabling millions of low-income households, including many minority households, 
to have affordable access to the nation' s telecommunications networks. 
Expansion of the Lifeline program to include wireless services in 2008 was a dramatic 
enhancement to the program since it brought the benefits of mobility and greater connectivity to 
low-income families for whom a working cell phone had been an unaffordable luxury. Further 
modernization of the program to include broadband will bring Lifeline recipients the connections 
they need to participate in the 21st Century economy. 
Opponents of the Lifeline program have claimed participation in the program had "ballooned" to 
over 18 million participants in 2012. Yet data compiled by the Universal Service Administrative 
Company show there were slightly more than 16 million participants in 2012 and 12 million as 
of March 2015. It is also important to note that the amount of Lifeline support has decreased 
from $2.13 billion in 2012 to a projected $1.44 billion in 2015. These sharp declines in program 
enrollment and disbursements demonstrate the effectiveness of the FCC's 2012 program reforms. 
We understand that the Commission will soon be considering additional reforms to the Lifeline 
program and that it has already received input from various stakeholders. To that end, we write 
to share our thoughts and suggestions: 
1. NO CAPS 
Under no circumstances should Lifeline be "capped" if the effect of such a cap would be 
to deny program enrollment to qualified low-income households once some arbitrary 
"cap" amount had been reached. The government would not deny SNAP benefits to low­
income consumers after a certain number of persons were enrolled, nor would it deny 
Medicaid benefits on that basis. With only about one-half of the nation's Lifeline­
eligible households currently enrolled, the program still is not reaching millions of 
economically-disadvantaged families, including many African American and other 
disadvantaged minority households. 
PRINTED ON RECYCLED PAPER 
Chairman Tom Wheeler 
June 18,2015 
Page 2 
2. NOMANDATORYCOPAYREQUIREMENT 
Participation in the Lifeline program should not be contingent on payment of a 
mandatory fee or co-pay requirement as there is no correlation between mandatory 
payments and fraud prevention. Even a "modest" monthly fee would negatively impact 
many of our constituents and force them out of the program. 
3. THIRD-PARTY ELIGIBILITY VERIFICATION 
Currently, providers participating in the Lifeline program are required to verify the 
eligibility of applicants for enrollment in the program. The process of having providers 
verify the eligibility of those participants can have a negative impact on program integrity 
and can lead to program abuse. In order to best protect the Lifeline program, its 
participating providers, and beneficiaries, a third-party eligibility verification system 
should be considered as an alternative or addition to the current system. 
4. UPDATE ELIGIBLE TELECOMMUNICATIONS CARRIER DESIGNATION 
PROCESS 
The Eligible Telecommunications Carrier designation process- a process mandated by 
federal statute- needs to be reformed and made nationally consistent. It is critical that 
Lifeline beneficiaries have access to all the tools of a highly technology-driven economy 
including access to broadband. Expanding, updating, and streamlining the ETC 
designation process to include non-ETCs will ensure the program has the ability to 
provide essential telecommunications services to the greatest number of qualified people. 
We appreciate the Commission recognizing the importance of the Lifeline program to millions of 
low-income American households and its commitment to reforming the program. We urge the 
Commission to proceed with reforming the Lifeline program in a responsible matmer that 
focuses on program integrity while ensuring the most vulnerable Americans, including many 
African Americans and other disadvantaged minorities, have access to services many of us take 
for granted. 
Thank you very much. 
Very truly yours,