Disconnected: FCC proposals to reform Lifeline will hurt low-income consumers

Yesterday, we urged the U.S. Federal Communications Commission (FCC) not to pursue several proposed changes to the Lifeline program. You can read our comments here.

The Lifeline program plays an integral role in helping people with low income get online by addressing the need to make communications services more affordable. Access to the internet is a foundational issue. In today’s world, those without a connection are cut off from enjoyment of a broad range of human rights. The internet has become an essential tool for employment, education, communication, political engagement, and other aspects of our everyday lives. Yet nearly 20 million people in the U.S. lack access to a high-speed broadband connection (where “high speed” is defined as a paltry 25 mbps download and 3 mbps upload). In 2018, 9.5 million households subscribed to Lifeline to access phone and internet services.

We support Lifeline and also the FCC’s stated goal of removing waste, fraud, and abuse within the program. Unfortunately, the FCC is considering proposals that would saddle at-risk, low-income Lifeline customers with unnecessary burdens and privacy invasions, even when the goal is to address fraudulent behavior by providers, not the customers. These proposals will make it harder for people in need to get internet access through Lifeline, yet they are not likely to increase efficiency or prevent fraud and abuse. That’s why we are urging the FCC to reject these proposals.

We oppose a proposal for the FCC to focus on connecting consumers who, without Lifeline, would not subscribe to broadband. Such a focus would be contrary to or inconsistent with other parts of the program, particularly the requirement that funding should be predictable and stable. It is also inconsistent with the requirement that the FCC work to bring all low-income consumers online, not just those who would not otherwise be able to afford broadband.

It is not clear what problem this shift in focus is supposed to solve. Low-income consumers already have to make tough decisions about which necessities to purchase and this requirement would force the consumer to rank the importance of their broadband service against food, water, shelter, and other necessities. Instead of penalizing people who would benefit from the Lifeline program, the FCC should focus on expanding it.

As we note above, in some cases proposed changes would burden low-income customers, when the fraud the FCC is seeking to prevent is by Lifeline providers. For instance, if a Lifeline provider is faking usage data to comply with the 30-day usage requirement, the proper remedy is with the provider, not forcing people to install mandatory usage-tracking apps on their Lifeline phones. If a Lifeline provider is giving out free phones to people who are not eligible for them, the solution is to ensure they give them to the right people, not outlawing free phones.

If they are not designed the right way, government programs to benefit the poor can put this marginalized population at even greater risk. Lifeline subscribers should not be made subject to invasive practices that put their privacy at risk, nor should the FCC outlaw pro-consumer practices in the name of reducing fraud. Instead, the FCC should focus on its true goal: connecting all low-income consumers to the internet.