PUBLIC NOTICE Federal Communications Commission News Media Information 202 / 418-0500 445 12th St., S.W. Internet: http://www.fcc.gov Washington, D.C. 20554 TTY: 1-888-835-5322 ______________________________________________________________________ DA 07-3088 Released: July 10, 2007 DEADLINE FOR ANNUAL LIFELINE VERIFICATION SURVEYS Each year, eligible telecommunications carriers (ETCs) are required to verify the continued eligibility of a statistically valid sample of their Lifeline subscribers.1 Under the terms of the Lifeline Order, states that have their own state-based Low-Income programs are required to establish state- specific verification procedures.2 These state procedures should include how ETCs should verify continued eligibility and to whom the results should be submitted.3 States that do not have state-based low-income programs are designated “federal default states.” ETCs in federal default states must follow the certification and verification procedures set out in the Lifeline Order.4 In this Public Notice, the Wireline Competition Bureau announces that an ETC in a state with its own state-based Low-Income program must submit a certification, signed by an officer of the company to USAC by August 31, 2007, and on August 31 of each subsequent year thereafter, attesting that the ETC has complied with the state verification procedures.5 All ETCs in federal default states must also submit their annual Lifeline verification survey results to USAC by August 31, 2007, and on August 31 of each subsequent year thereafter.6 The Wireline Competition Bureau and the Universal Service Administrative Company (USAC) have received several inquiries concerning the Lifeline certification and verification procedures. In this Public Notice, we provide answers to frequently asked questions. The full text of this document is available for public inspection and copying during regular business hours at the FCC Reference Information Center, Portals II, 445 12th Street, S.W., Room CY- A257, Washington, DC, 20554. This document may also be purchased from the Commission’s duplicating contractor, Best Copy and Printing, Inc., 445 12th Street, S.W., Room CY-B402, Washington, D.C. 20554, telephone (202) 488-5300, facsimile (202) 488-5563, or via e-mail at FCC@BCPIWEB.COM. 1 Federal-State Joint Board on Universal Service Lifeline and Link-Up, WC Docket No. 03-109, Report and Order and Further Notice of Proposed Rulemaking, 18 FCC Rcd 8302 (2004) (Lifeline Order). 2 Id. at 8322, para. 33. 3 Id. at 8324, para. 37. 4 Id. 5 See 47 C.F.R. § 1.4(j) (providing that, when the calculated filing date falls on a “holiday,” the document is due to be filed on the next business day). See also 47 C.F.R. § 1.4(e)(2) (defining the term “holiday” as “Saturday, Sunday, officially recognized Federal legal holidays and any other day on which the Commission's offices are closed and not reopened before 5:30 p.m.”) 6 See 47 C.F.R. §§ 1.4(e)(2), (j). 2 People with Disabilities: To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty). For more information, contact Dana Bradford, Telecommunications Access Policy Division, Wireline Competition Bureau at (202) 418-7400, TTY (202) 418-0484. 3 Certification and Verification Procedures Frequently Asked Questions 1. Which states are “federal default states”? Delaware, Hawaii, Iowa, Indiana, Louisiana, New Hampshire, American Samoa, and the Northern Mariana Islands have identified themselves as “federal default states.”7 If your state is not included in this list, you should contact the state commission for its certification and verification procedures. If a state changes its designation, the state commission should notify the Federal Communications Commission. 2. What is the deadline for filing the results of the statistically valid sampling of Lifeline customers for purposes of verification and how should filings be made? For federal default states, all verification sampling results must be submitted to USAC by August 31, 2007 and on August 31 of each subsequent year thereafter. 8 ETCs in federal default states must submit a signed copy of the results by only one of the following methods: (a) Facsimile to: (202) 776-0080; (b) E-mail to: LiVerifications@usac.org; or (c) U.S. Mail to: USAC- Low Income Program 2000 L Street, NW, Suite 200 Washington, DC 20036 ETCs may confirm the receipt of their submissions on USAC’s website. If an ETC in a federal default state does not receive replies from all of its sample recipients, the ETC must list separately the number of those customers who have not responded to the survey and those found to be ineligible. The same customers should not be listed in both columns. The ETC must then update the verification results upon completing the survey. Updates must be submitted to USAC by October 31, 2007, and on October 31 of each subsequent year thereafter.9 An ETC should send a second submission only if it is updating verification results. ETCs need only submit one update. 3. How do ETCs in states that have their own state-based Lifeline and Link-Up programs comply with the verification survey deadline? ETCs in states that have their own state-based Lifeline and Link-Up programs must comply with their states’ certification and verification procedures, including any deadlines set by those states. ETCs must also send USAC a certification indicating that they have complied with state verification 7 Id. at 8355, Appendix G. Since the release of the Lifeline Order, additional states have notified USAC of the change in their status. The list in this Public Notice represents the most current information available. USAC will update its website as the list is updated. See . 8 Id. at 8323, para. 35. See also 47 C.F.R. §§ 1.4(e)(2), (j). 9 See 47 C.F.R. §§ 1.4(e)(2), (j). 4 procedures.10 These certifications must be submitted by August 31, 2007, and on August 31 of each subsequent year thereafter.11 USAC will post a sample certification letter to their website to assist ETCs. 4. My state has its own state-based Lifeline and Link-Up program. The state’s Lifeline verification procedures direct ETCs to submit their verification results to USAC. Is this permissible? Yes. States with state-based Lifeline and Link-Up programs may either (1) collect the verification results on a date that the state chooses or (2) direct ETCs in their states to send the verification results to USAC.12 If companies are submitting the results to USAC, they should do so by August 31, 2007, and on August 31 of each subsequent year thereafter.13 Results submitted directly to USAC will be processed in the same manner as those received from ETCs in federal default states. 5. How should the verification sample be taken? In federal default states, the verification sample should be drawn from the company’s Lifeline customers on a state-wide basis, not on a study area or nation-wide basis. ETCs should provide a separate list of the study areas, including the Study Area Code, within its territory on the sample letter. ETCs should also enter a “0” where appropriate, instead of leaving a column blank. USAC will post a sample verification letter to their website to assist ETCs. ETCs in states that have their own state-based Lifeline and Link-Up programs should consult the state verification procedures. 6. How do I determine the number of customers that constitutes a statistically valid sample? As explained in Appendix J of the Lifeline Order, the size of a statistically valid sample is based on (1) the number of Lifeline subscribers and (2) the percentage of Lifeline subscribers that inappropriately took Lifeline service in the immediate prior year. 14 Using these two numbers and the chart attached to Appendix J of the Lifeline Order (and attached to this Public Notice), ETCs can determine how many Lifeline subscribers should be surveyed.15 Values for the number of Lifeline subscribers are listed in the first column. Values for the percentage of inappropriate Lifeline subscribers are listed in the first row. By plotting the intersection of the two values, the ETC can determine the number of Lifeline subscribers that constitutes a statistically valid sample. 10 Lifeline Order, at 8324, para. 34. 11 See 47 C.F.R. §§ 1.4(e)(2), (j). 12 Lifeline Order, at 8322, para. 34. 13 See 47 C.F.R. §§ 1.4(e)(2), (j). 14 Lifeline Order, at 8365, Appendix J. In the first year of verification, all ETCs assumed that the percentage of subscribers inappropriately taking Lifeline was one percent or .01. Thereafter, ETCs use actual figures to determine the percentage of subscribers inappropriately taking Lifeline. 15 Id. Under the terms of the Lifeline Order, companies can calculate its sample size directly by using the formulas set out in footnote 13 of Appendix J. 5 To calculate the statistically valid sample size: a. Determine the current number of Lifeline subscribers: (a). ____________. b. Determine the number of Lifeline subscribers that were surveyed last year. (b). _____________. c. Determine the number of Lifeline subscribers that were surveyed last year that had their service terminated because they were found to be inappropriately taking Lifeline: (c)._____________. d. Divide line (c) by line (b), which is the percentage of surveyed Lifeline customers that were found to be taking Lifeline inappropriately: (d). _________________. e. Go to the chart in Appendix J (attached to this Public Notice). Using the figure in line (a), find the closest value, rounding up to the nearest value. For example, if the ETC has 730 current Lifeline subscribers, the ETC should use the row for 800 subscribers. f. Now find the appropriate column in Appendix J that corresponds to the percentage in line (d). If the percentage is less than .01, use the column for .01. If the percentage is greater than .06, use the column for .06. For percentages between .01 and .06, round up to the nearest half percent. For example, if the percentage in line (d) is .043, use the column marked “.045.” g. Find the number that is at the intersection of the row determined in step (e) and the column determined in step (f). This is the number of current Lifeline subscribers that the ETC must survey this year. 7. Last year, several Lifeline subscribers in my statistical sample did not reply. How should I account for that in determining the appropriate sample size for this year’s survey? If an ETC terminated Lifeline benefits because a consumer failed to respond, that subscriber should be included in the calculation of the proportion of those inappropriately taking Lifeline.16 By way of example: Last year, an ETC had 10,000 Lifeline customers. Its survey size was 43 Lifeline subscribers. There was one non-respondent, whose Lifeline benefits were terminated after the appropriate termination procedures were completed. In addition, there was one customer determined to be inappropriately taking Lifeline. The proportion of those inappropriately taking Lifeline would be: 2 / 43 = 0.047 or 4.7 percent. Under the directions included in Appendix J, the ETC should round up to the closest percentage listed in the chart, which would be 0.05 (or 5 percent) in the example above. This year, the ETC still has 10,000 Lifeline customers. The ETC should use the figure at the intersection of the row for 10,000 customers and the column for 0.05 percent, which is 202. This year, the ETC in the example should survey 202 current Lifeline customers. 8. Should I include in my statistical survey customers who received the special temporary Hurricane Katrina Lifeline support package? No. When determining the number of Lifeline participants and sending out surveys, only include those customers that receive the regular Lifeline support. 16 Id. 6 APPENDIX J STATISTICALLY VALID SAMPLE Eligible Telecommunications Carriers (ETCs) subject to the federal default criterion will be required to verify the continued eligibility of a statistically valid sample of their Lifeline customers. The size of a statistically valid sample, however, varies based upon many factors, including the number of Lifeline subscribers (N) and the previously estimated proportion of Lifeline subscribers inappropriately taking Lifeline service (P). For the first year that ETCs verify subscribers’ continued eligibility, all ETCs should assume that the proportion P of subscribers inappropriately taking Lifeline service is .01, if there is no evidence to assume a different proportion. In subsequent years, ETCs should use the results of samples from previous years to determine this estimated proportion. In all instances, the estimated proportion P should never be less than .01 or more than .06. For ETCs with large numbers of Lifeline subscribers (more than 400,000), a statistically valid sample size must be calculated pursuant to the following formula:17 Sample Size = 2.706 * P*(1 – P) / .000625. For ETCs with 400,000 Lifeline subscribers or less, the above formula could yield a sample size that is larger than needed to be statistically valid.18 To simplify the calculation of a statistically valid sample, a table of sample sizes based on two variables N (number of Lifeline subscribers) and P (previously estimated proportion of Lifeline subscribers inappropriately taking Lifeline service) is provided below. Various numbers of Lifeline subscribers N are listed in the left-most column. Various previously estimated proportions P are listed on the first row. To determine the sample size, find the box that matches your number of Lifeline subscribers N and proportion P. If the number of Lifeline subscribers is not listed and/or the proportion is not listed, ETCs should use the next higher number for N and/or P that is in the table, i.e. always round up to the next higher value for N and/or P. For example, if 3.8 percent of 9,500 Lifeline subscribers inappropriately took Lifeline service, the ETC would use a sample size of 164 (value using 17 Lifeline Order, at 8365-68. The values 2.706 and .000625 in this formula are mandated by OMB. See Office of Management and Budget, Memorandum M-03-13 (May 21, 2003). 18 Id. Sample sizes for ETCs with 400,000 Lifeline subscribers or less are calculated pursuant to the following formula: sample size = N/(1+{[N-1]/n}). N is the number of Lifeline subscribers and n = 2.706 * P*(1 – P) / .000625, where P is the previously estimated proportion of Lifeline subscribers inappropriately taking Lifeline service. ETCs may choose to calculate their sample sizes using these formulas. 7 10,000 customers and proportion .04). Because the adjustment for the number of Lifeline subscribers is de minimus above 400,000 Lifeline subscribers, ETCs with more than 400,000 Lifeline subscribers must use the above formula to calculate the sample size. All ETCs must provide the estimated proportion for their samples to the Administrator, i.e., the proportion of sampled subscribers inappropriately taking Lifeline service. Sample Size Table Previously Estimated Proportion of Subscribers Inappropriately Taking Lifeline Service (P)19 (N) Number of Lifeline Subscribers 0.01 0.015 0.02 0.025 0.03 0.035 0.04 0.045 0.05 0.055 0.06 400,000 43 64 85 106 126 146 166 186 206 225 244 100,00020 43 64 85 105 126 146 166 186 206 225 244 90,000 43 64 85 105 126 146 166 186 205 224 244 70,000 43 64 85 105 126 146 166 186 205 224 243 60,000 43 64 85 105 126 146 166 185 205 224 243 30,000 43 64 85 105 125 146 165 185 204 223 242 20,000 43 64 85 105 125 145 165 184 204 223 241 15,000 43 64 84 105 125 145 164 184 203 222 240 10,000 43 64 84 104 124 144 164 183 202 220 238 9,000 43 64 84 104 124 144 163 182 201 220 238 8,000 43 63 84 104 124 144 163 182 201 219 237 7,000 43 63 84 104 124 143 162 181 200 218 236 6,000 43 63 84 104 123 143 162 180 199 217 235 5,000 43 63 83 103 123 142 161 179 198 215 233 4,000 42 63 83 103 122 141 160 178 196 213 230 3,000 42 63 83 102 121 139 158 175 193 209 226 2,000 42 62 81 100 119 136 154 170 187 202 218 19 Id. For the first year of verification, ETCs should assume that this percentage is .01, if there is no evidence to assume a different percentage. In subsequent years, ETCs should use the results of samples from previous years to determine this estimated percentage. 20 Id. Sample sizes for ETCs with less than 400,000 Lifeline subscribers are calculated pursuant to the following formula: sample size = N/(1+{[N-1]/n}). N is the number of Lifeline subscribers. n is (2.706 * P*(1 – P)) / .000625, where P is the estimated percentage of Lifeline subscribers inappropriately taking Lifeline service. ETCs may choose to calculate their sample sizes using these formulas. 9 Sample Size Table Previously Estimated Proportion of Subscribers Inappropriately Taking Lifeline Service (P) (N) Number of Lifeline Subscribers 0.01 0.015 0.02 0.025 0.03 0.04 0.04 0.045 0.05 0.55 0.06 1,500 42 61 80 99 116 133 150 166 181 196 210 1,000 41 60 78 96 112 128 142 157 171 184 196 900 41 60 78 95 111 126 140 154 168 180 192 800 41 59 77 94 109 124 138 151 164 176 187 700 41 59 76 92 107 121 134 147 159 170 181 600 40 58 74 90 104 118 130 142 154 164 174 500 40 57 73 88 101 113 125 136 146 155 164 400 39 55 70 84 96 107 118 127 136 144 152 300 38 53 66 79 89 98 107 115 122 129 135 200 36 49 60 70 78 85 91 97 102 106 110 150 34 45 54 62 69 74 79 83 87 90 93 120 32 42 50 57 62 66 70 73 76 78 81 100 30 39 46 52 56 60 63 65 68 69 71 90 29 38 44 49 53 56 59 61 63 64 66 80 28 36 41 46 49 52 54 56 58 59 60 70 27 34 39 42 45 48 49 51 52 54 55 60 25 31 35 39 41 43 44 46 47 48 48 50 23 28 32 34 36 37 39 40 40 41 42 40 21 25 27 29 31 32 32 33 34 34 34 35 20 23 25 27 28 28 29 30 30 30 31 30 18 21 22 24 24 25 26 26 26 27 27 25 16 18 19 20 21 21 22 22 22 23 23 20 14 15 16 17 17 18 18 18 18 18 19 10 Sample Size Table Previously Estimated Proportion of Subscribers Inappropriately Taking Lifeline Service (P) (N) Number of Lifeline Subscribers 0.01 0.015 0.02 0.025 0.03 0.04 0.04 0.045 0.05 0.55 0.06 17 12 14 14 15 15 15 16 16 16 16 16 15 11 12 13 13 13 14 14 14 14 14 14 13 10 11 11 12 12 12 12 12 12 12 12 11 9 10 10 10 10 10 10 10 10 11 11 10 8 9 9 9 9 9 9 10 10 10 10 9 8 8 8 8 8 9 9 9 9 9 9 8 7 7 7 8 8 8 8 8 8 8 8 7 6 6 7 7 7 7 7 7 7 7 7 6 5 6 6 6 6 6 6 6 6 6 6 5 5 5 5 5 5 5 5 5 5 5 5 4 4 4 4 4 4 4 4 4 4 4 4 3 3 3 3 3 3 3 3 3 3 3 3 2 2 2 2 2 2 2 2 2 2 2 2 1 1 1 1 1 1 1 1 1 1 1 1