Advocates, Industry Back Efforts to Expand Lifeline, ACP to Domestic Violence Survivors

“Self-attestation of survivor status and financial hardship is essential,” said a coalition of advocacy organizations, including the Electronic Privacy Information Center, the Electronic Frontier Foundation, the National Coalition Against Domestic Violence, the National Consumer Law Center and the National Domestic Violence Hotline. The FCC "must accept self-attestation from survivors" because it could otherwise "jeopardize their privacy and safety in other ways by disclosing their abuse to more people," the groups said. If identification documentation is required, the FCC could allow survivors "more than 30 days to submit such documentation," they said.

Let survivors themselves and "qualified third parties" provide a signed affidavit to document a "covered act" when establishing eligibility for Lifeline or ACP, said the Network of Victims Recovery of DC. Third parties should include “shelters, advocacy organizations, or other groups working directly with survivors and providing them with other types of assistance,” the group said (see 2207110048).

The eligibility determination process "must allow people to disclose victimization at their pace, as well as re-apply even if initially denied," said the Asian Pacific Institute on Gender-Based Violence. The group said it "strongly discourages inclusion of an absolute requirement that an applicant must submit 'official documentation'" to qualify for either program. Consider eliminating the "use of alternative identifiers or allow applicants to omit identifier" and "unnecessary requests" for social security numbers, it said.

Lifeline and ACP eligibility "in all instances must be determined by the National Verifier, not service providers," said the National Lifeline Association. The FCC also can't expand eligibility for ACP "independent of Lifeline because ACP eligibility is set by the Infrastructure [Investment and Jobs] Act," the group said. "Lifeline is particularly important for survivors of domestic and sexual violence” because the plans “generally include bundles of broadband and voice service, which allows survivors to dial 911 when necessary and the ability to call shelters and other support services," NaLA said.

"Survivors often face significant challenges when establishing independence from an abuser," said CTIA: Mobile wireless services "are well-positioned to aid survivors seeking independence, safety and security." The group backed the Safe Connections Act, which would modify Lifeline and ACP rules to expand access to survivors. The FCC could "maintain important program integrity measures" by requiring that providers "continue to rely on" the national Lifeline eligibility verifier "even if specific new eligibility criteria are established for survivors," CTIA said. NVRDC cited concerns about survivors’ ability to obtain certain identification or financial documentation because it could “place the individual in contact with their abuser.”

Accepted documents cited in the Safe Connections Act "may take some time to receive or require steps that an individual may not yet be able to take if still in an abusive environment," NVRDC said: Waiting "would delay the survivor’s Lifeline or ACP application even while gaining access to voice/internet service is an immediate need.” The FCC “must clearly change its rules to reflect the eligibility standards” NaLA said, because it “cannot loosen eligibility documentation requirements, identity verification requirements and address information requirements and then blame service providers and seek repayments … if some ineligible subscribers are then approved by the National Verifier.”