TracFone Meeting with FCC: Supporting Lifeline Improvements, Avoiding Participation Barriers

TracFone Wireless, Inc. submitted a notice of ex parte presentation to the FCC regarding their meeting with FCC Chairman Tom Wheeler to discuss “Lifeline and Link Up Reform and Modernization.” TracFone emphasizes the improvements that the FCC is capable of making to the Lifeline program and cautions the FCC against changes that could create program participation barriers for the nation’s poorest individuals.

Download the PDF version of the notice of ex parte presentation here.

Dear Ms. Dortch:

On February 3, 2015, David Avila, Associate Vice President for Lifeline Services, TracFone Wireless, Inc. (TracFone), former Congressman Henry A. Waxman, and myself met with Chairman Tom Wheeler and with Jon Wilkins, Managing Director.

During the meeting, we discussed various issues before the Commission in the pending notice of proposed rulemaking in the above-captioned proceeding. We explained how TracFone shares the Commission’s overall objectives in rebooting the Lifeline program: increase competition and the number of service offerings for eligible Lifeline households; increase program participation; and continue safeguarding the program from waste, fraud, and abuse. We discussed TracFone’s support for the Commission’s effort to expand the program to cover broadband services and discussed our own proposal to make mobile broadband available to Lifeline households by requiring wireless Lifeline providers to offer at no charge to qualified consumers Wi-Fi-enabled smartphones that could utilize free Wi-Fi hotspots provided through public facilities. We also reiterated TracFone’s support for a national third party eligibility verifier and our opposition to proposals to implement a direct benefit transfer (i.e. “voucher”) system and to limit Lifeline eligibility to a single qualifying program such as the Supplemental Nutrition Assistance Program (SNAP).

We stressed that while TracFone strongly supports expanding the Lifeline subsidies to include broadband, the Commission must continue to ensure the availability of no charge voice services for consumers. We cautioned that minimum service standards that impose high costs on carriers would jeopardize Lifeline providers’ ability to offer no charge Lifeline services. It could become a backdoor way of imposing a “skin in the game” co-pay requirement on Lifeline customers that could greatly reduce program participation. While there may be a market for Lifeline plans that offer greater benefits along with a monthly fee, providers should have the option to offer such plans for those who can afford the co-pay, without requiring all low-income consumers to pay a monthly fee in order to participate in the program. Furthermore, many | | | 9700 NW 112th Avenue | Miami, FL 33178 existing Lifeline customers are “unbanked” (i.e., do not have checking accounts or credit cards) and would be unable to remit payments.

Finally, we discussed that if the Commission wishes to establish a time frame for phasing out Lifeline subsidy for voice services, it must do so gradually and carefully, taking into account the millions of existing Lifeline subscribers who rely on their voice services every day to connect with friends and families, employers, and emergency service providers. It should remain a consumer’s choice to decide whether to subscribe to a Lifeline provider’s voice or broadband service and whether they wish to subscribe to a no-charge service.

Pursuant to Section 1.1206(b) of the Commission’s rules, this letter is being filed electronically.


Mark Rubin, Senior Executive for Government Affairs TracFone