FCC Record, Volume 27, No. 8, Pages 6653 to 6954, Supplement (February-March 2012) Page: 6,742
iii, 6653-6954 p. ; 28 cm.View a full description of this book.
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verification upon query from an eligible querying party whether a prospective subscriber is currently
receiving Lifeline support.'3 The database must also provide information necessary (e.g., error codes) to
the querying party to understand the result of a database response that the prospective subscriber is either
already receiving duplicative support, or if the database was unable, with the information provided, to
make such a determination.514 The database must permit ETCs to compare the subscriber information
attributable to that ETC (and only that ETC) housed in the database to the ETC's own subscriber list and
establish a process for doing so.s15 This feature will provide an additional check on the accuracy of the
database while protecting consumers.
200. Several parties have argued that the database must be capable of verifying the identity of
a subscriber through a third party identity verification service, prior to an ETC submitting for support for
that subscriber. TracFone estimates that such a "front-end" identity verification check, if done by all
ETCs, could save the Fund $192 million annually.5'16 An identification verification process would utilize
a subscriber's name, address, date of birth and the last four digits of the social security number, and
compare that information to publicly available databases, to determine if all of the information provided
by the subscriber is valid (e.g., Joe Smith really lives at 123 Main St., is 29 years old and the last four
numbers of his social security number are 4444). This check would reduce the possibility that applicants
and/or ETCs submit incorrect information either purposefully, in order to evade the one per household
rule or to seek reimbursement for non-existent subscribers, or inadvertently. Moreover, by validating a
subscriber's date of birth, minors will be prevented from signing up for service. We expect that this
functionality can be added to the database at minimal cost.'" We also note that several ETCs have
already been performing routine identification checks using subscribers' date of birth and social security
number even though they are not explicitly required to do so by our rules, indicating that the burden of
performing such verifications is low.518
(Continued from previous page)
AT&T Comments at 11-12; CGM Comments at 3 ("critical stakeholders including USAC, State regulators and
ETCs will all maintain access to the data for particular and managed purposes ... this can be set up [with] security
so that privacy is safeguarded").
513 GCI Comments at 3 (arguing that a database "would enable ETCs to ascertain whether an applicant for Low-
income Program service already subscribes with an ETC (which no ETC would currently know)."). id. at 27 ("[T]o
prevent duplicate subscriptions. [ETCs] must be able to access the database to ascertain whether any particular
applicant for Lifeline service already receives Lifeline service from another ETC (although the identity of the other
ETC should be masked) ..."); CGM Comments at 4 ("ETCs will want to access this database in real time to
authenticate new users ...").
514 See Emerios Database Proposal at 7 (arguing that the database should "'provide error codes and descriptions in
real-time...").
55See Cincinnati Bell Comments at 111 GCI Comments at 28 ("First to prevent duplicate Lifeline subscriptions,
[ETCs] must be able to access the database to ascertain whether any particular applicant for Lifeline service already
receives Lifeline service from another ETC (although the identity of the ETC should be masked). Second, they must
be able to review their own Lifeline subscriber lists as reflected in the database in order to assess whether it
accurately reflects their own records listing Lifeline subscribers.").
516See TracFone Nov. 10 ex parte Letter, Attach. at 6.
5s7See, e.g., Experian, Experian GSA Catalog, available at
http://www.experian.com/assets/government/brochures!gsa-catalog.pdf (noting that the cost of its Precise ID product
costs approximately 25 cents per query per the GSA schedule. depending upon volume).
518 See, e.g., TracFone Nov. 10 exparte Letter, Attach. at 6; Letter from Mathew S. O'Brien, Century Corporation,
to Marlene H. Dortch, Secretary, Federal Communications Commission. WC Dkt. No. 11-42 et al, at 1 (filed Jan.
23. 2012) (explaining that a number of carriers are using Century Corporation's products to standardize and
(continued....)6742
Federal Communications Commission
FCC 12-11
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United States. Federal Communications Commission. FCC Record, Volume 27, No. 8, Pages 6653 to 6954, Supplement (February-March 2012), book, 2012; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc111169/m1/100/: accessed April 25, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.