Disability Advocates Letter to FCC

On February 10, 2016, American Association of People with Disabilities (AAPD), The American Foundation for the Blind (AFB), The Arc, The Association of Assistive Technology Act Programs (ATAP), Hearing Loss Association of America (HLAA), National Association of the Deaf (NAD), National Council on Independent Living (NCIL), Perkins School for the Blind, Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), United Spinal Association, and World Institute on Disability (WID) filed a letter with the FCC outlining:

  1. Lifeline’s critical role in connecting Americans with disabilities to their families, health care services, employment and educational opportunities, and emergency service providers
  2. Their support for the FCC’s positive program reforms
  3. Their opposition to the implementation of a voucher system, which would impose unnecessary burdens on Lifeline recipients facing physical, cognitive, or communicative challenges
  4. Their opposition to SNAP-only eligibility, which would exclude many consumers with disabilities who do not participate in SNAP or are excluded from SNAP by state laws prohibiting simultaneous enrollment in SSI and SNAP
  5. Their opposition to proposals that would result in a mandatory Lifeline copay, creating a barrier to participation for the many Americans with disabilities who cannot afford the copay or do not have bank accounts from which to pay the fee

Download the PDF version of the Disability Advocates Lifeline Letter here.

February 10, 2016

The undersigned organizations (together “Disability Advocates”) advocate for and represent the interests of millions of Americans with cognitive, physical, visual, hearing and other disabilities. Each of our organizations has been a leader in working for policies to help people with disabilities lead safer, healthier and more productive lives, including by supporting programs that facilitate wider access to telecommunications services that are necessary for Americans with disabilities to stay connected and participate in society. The Disability Advocates therefore have been strong supporters of the Federal Lifeline program and have actively participated in proceedings before the Federal Communications Commission (“FCC” or “Commission”) as it has sought to expand and reform the program.

People with disabilities have been one of the key intended beneficiaries of Lifeline from its inception. People with disabilities are often in lower income brackets due to unique challenges they face with educational access and employment opportunities. The services provided by Lifeline have been critical in allowing Americans with disabilities to stay connected with their families, access health care services, seek employment and educational opportunities and to have the peace of mind to be able to call for help in emergencies.

We thus applaud the Commission for its leadership in ensuring that millions of Americans with disabilities have been able to access this critical service. As the Commission looks to update and modernize the Lifeline program to enable low-income Americans to more fully participate in the 21st Century digital economy, we are further encouraged by the Commission’s proposal to expand the scope of Lifeline to include broadband. We believe the latest reform effort, if done correctly, will significantly improve the lives of people with disabilities who have heretofore not been able to afford broadband service.

We are concerned, however, that several of the reforms to the Lifeline program proposed by commenters in the proceeding would make it significantly more challenging for people with disabilities to participate in Lifeline. Specifically, we strongly oppose the use of a voucher system for the administration and distribution of Lifeline subsidies, whether it’s through a personal “Lifeline Benefits Account” administered by financial institutions utilizing a personal identification number, an Electronic Benefits Transfer (EBT) card, or any other instrument where the obligation to redeem the benefit in order to utilize and maintain the service rests with the consumer. In contrast to the current system where Lifeline customers receive their benefits automatically on their Lifeline phone for the duration of their enrollment period, a voucher system would require recipients to physically visit or otherwise actively contact a provider to be able to continue receiving service on a monthly basis. Such a requirement would impose unnecessary burdens on the significant segment of current program participants who are disabled and who face various physical, cognitive and communications challenges. For example, for many people with certain physical disabilities, having to travel to a Lifeline provider’s retail establishment to redeem a voucher in the form of an EBT card or other similar instrument would be a significant logistical and financial challenge. This is the case with deaf and hard of hearing Lifeline participants who would also have difficulty contacting their providers to continue receiving service on a monthly basis due to communications access barriers. For people with cognitive disabilities, the requirement of having to proactively engage a Lifeline provider monthly or to remember to use a PIN in order to maintain the service will impose significant additional barriers to participation. If the Commission were to adopt the use of vouchers, many qualified recipients with disabilities may be at the risk of losing this vital and affordable communications link. We therefore urge the Commission to maintain the current system of automatic deposit of benefits on a consumer’s Lifeline phone and ensure that the benefits remain easy to use and maintain for consumers with disabilities.

We are also concerned about proposals that may limit Lifeline eligibility to only the participants of the Supplemental Nutrition Assistance Program (SNAP). Although we believe that further coordination between Lifeline and other assistance programs could provide benefits in terms of increasing education about and awareness of the availability of Lifeline, eligibility for Lifeline should not be limited solely to those who participate in SNAP. While, as described above, people with disabilities generally have lower income levels than the average population, many consumers with disabilities who currently participate or who would otherwise be eligible to participate in Lifeline do not participate in SNAP. In fact, in some states including California, statutory laws prohibit SSI recipients from also receiving SNAP. As of December 2014, there were 1,304,400 people on SSI in California alone. Eligibility for Lifeline should continue to be determined by participation in a broader range of assistance programs including Medicaid, which is relied upon by over 8.8 million Americans with disabilities for critical health care services. Medicaid is also critical to enrollees in Lifeline with disabilities because healthcare providers are using Lifeline today to text Medicaid enrollees important information and reminders. The opportunity for Lifeline to be used to enhance healthcare for people with disabilities would be lost if Medicaid was eliminated as a qualifying program for Lifeline.

Finally, we are concerned with proposals that would result in Lifeline customers being required to contribute a mandatory co-pay each month in order to receive service. As noted above, many people with disabilities are often in low income brackets and a requirement to make even a modest monthly payment to ensure Lifeline eligibility would mean many otherwise eligible people would be forced to drop out of the program. In addition, many people with disabilities are “unbanked”, with no credit cards or checking accounts, so even if some of them could afford to pay a modest fee, they would be unable to remit payments. Finally, although a co-pay requirement has been proposed as a way to reduce incentives to commit fraud, no evidence has been introduced to demonstrate that such mandatory charges would have any impact on program integrity.

The Disability Advocates commend the Commission for its work over the years in establishing Lifeline as a vital tool to enable millions of Americans with disabilities to stay connected to society and for its proposal to extend the Lifeline program to broadband. As noted above, however, we urge the Commission to be mindful of the unintended consequences of certain proposals that, if adopted, would directly limit the availability of critical Lifeline services to people with disabilities.


American Association of People with Disabilities (AAPD)
Helena Berger
President and CEO
/s/ Helena Berger

The American Foundation for the Blind (AFB)
Mark Richert, Esq.
Director, Public Policy
/s/ Mark Richert

The Arc
Annie Acosta
Director of Fiscal and Family Support Policy
/s/ Annie Acosta

The Association of Assistive Technology Act Programs (ATAP)
Audrey Busch
Director of Policy and Advocacy
/s/ Audrey Busch

Hearing Loss Association of America (HLAA)
Lise Hamlin
Director of Public Policy
/s/ Lise Hamlin

National Association of the Deaf (NAD)
Howard Rosenblum
Chief Executive Officer
/s/ Howard Rosenblum

National Council on Independent Living (NCIL)
Kelly Buckland
Executive Director
/s/ Kelly Buckland

Perkins School for the Blind
Sara Rosta
Legislative Assistant
/s/ Sara Rosta

Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI)
Claude Stout
Executive Director
/s/ Claude Stout

United Spinal Association
Alexandra Bennewith
Vice President, Government Relations
/s/ Alexandra Bennewith

World Institute on Disability (WID)
Anita Shafer Aaron
Executive Director
/s/ Anita Shafer Aaron