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ACP Enrollment Challenges

Many States Still Unconnected to National Verifier, Says NARUC Member

NARUC should press states and the federal government to lower barriers, including through increased funding and awareness campaigns, to enrollment in the affordable connectivity program, Telecom Committee member Crystal Rhoades said in an interview Thursday. The Nebraska Public Service Commission’s lone Democrat said she doesn’t expect controversy over her proposed resolution, which is up for vote at NARUC’s July 17-20 policy summit in San Diego (see 2207060037). However, Next Century Cities Senior Policy Counsel Ryan Johnston raised concerns that the draft omits local governments’ key role in raising awareness.

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NARUC’s Telecom Committee plans to vote July 19 on the proposed ACP resolution. If adopted, it would go to the NARUC board for final OK July 20. The draft would seek to improve automatic eligibility verification by encouraging the FCC and Universal Service Administrative Co. (USAC) to "establish agreements with federal and state departments of agriculture and the health and human services, and other federal and state agencies implementing programs that establish consumers’ eligibility for Lifeline and ACP.” Also, it would urge state commissions, the FCC and USAC to "work collaboratively with federal and state agencies that implement programs whose target participants are eligible for Lifeline and ACP to promote awareness ... among eligible households.”

Connecting the national verifier to state databases for Medicaid and the Supplemental Nutrition Assistance Program (SNAP) has been a big challenge since the launch of the FCC and USAC’s system for checking consumer eligibility for Lifeline and now the ACP, said Rhoades. “Some states have been able to get that done, but about 28 states are still unable to connect, and it really is a barrier to entry for consumers.” The FCC declined to comment Friday.

Insufficient funding is a major reason states haven’t connected, said Rhoades. It doesn’t require new appropriations since there is much money available through federal and state USF programs, said Rhoades. “Those programs should consider an allocation to help fund these interfaces. If this a barrier to entry and to facilitating … a successful application or successful oversight of the program, it should be just as central to getting funding as the actual service.”

Another roadblock to more ACP enrollment has been raising awareness, said the NARUC Telecom Committee member. “If nobody knows about” the program or “how to access it, then it doesn’t really achieve its policy goals.” The ACP subsidy is high enough to incentivize carriers to work harder to help get consumers enrolled in programs, but some carriers could still do more, said Rhoades.

NARUC’s proposed resolution “highlights the incredible need for states to work in close partnership with the FCC and USAC to share the data that could reduce barriers for eligible recipients to sign up for service,” but “reveals one key stakeholder that is not at the table: local officials,” said Next Century Cities’ Johnston. “The NARUC resolution could have been the start of meaningful collaboration on advertisement” among federal, state and local governments, “but falls short of that goal.”

Often community leaders and municipal officials are on the front lines of advertising federal broadband subsidy programs,” said Johnston. “Without their insights, NARUC advertising strategies can easily miss targeted populations,” and “state and federal efforts have limited reach in disconnected communities,” said the Next Century Cities official. “We hope that, as the FCC finalizes its Outreach Grant Program, it will work closely with the community organizations and municipalities that apply for funding.”

Rhoades wouldn’t object to adding language about encouraging collaboration with local governments, “but it's awfully presumptuous … to assume that we’re not already doing that,” she responded. Rhoades said she has personally contacted school boards, city and county officials to promote enrollment in Nebraska.

The National Lifeline Association supports the NARUC draft, said counsel John Heitmann of Nelson Mullins. “Because the success of the ACP should be measured at least in part based on participation by eligible households, the resolution smartly calls for coordination to raise program awareness.”

Continuing NARUC diversity, equity and inclusion efforts, the state regulator association also plans to consider a draft resolution to commit the state utility regulator association to expanding DEI programming. NARUC invited commissioners and other conference attendees to a July 17 poverty simulation, an in-person event in which participants play the role of low-income family members and encounter typical daily obstacles.

Rhoades supported diversity efforts. “When I walk into those rooms, I’m often the youngest,” one of the only women, and one of the few with “any experience with poverty,” she said. “Anything we can do to increase diversity and perspective is positive in the policymaking world.”

The National Utilities Diversity Council applauds the draft's goal to expand DEI programming, said NUDC Executive Director Laurie Dowling: The state regulator association's continued focus on DEI "provides great benefits to the NARUC membership and the people they serve."