Questions from the FCC USAC Lifeline Broadband Pilot (Broadband Pilot Program) Kick-Off Meeting

Transcription

1 Questions from the FCC USAC Lifeline Broadband Pilot (Broadband Pilot Program) Kick-Off Meeting PILOT PROJECT TIMING ISSUES: 1. Can a company provide subsidized broadband service for more than 12 months as long as no individual consumer receives subsidized service for more than 12 months? No subscriber may receive more than 12-months of subsidized service. An ETC s project can run longer than 12 months if it chooses to begin enrolling subscribers prior to May 1, during the start-up period. ETCs, however, must enroll all new Broadband Pilot Program subscribers no later than October 31, 2013, and each subscriber can receive no more than 12 months of subsidized service. 2. Is it possible to launch service later than May 1 st? Yes. ETCs have until October 31, 2013 to enroll subscribers. The Broadband Pilot Program begins on February 1, ETCs have three months from that that date to launch service and must enroll all new subscribers on or before October 31, If an ETC is unable to launch service on or before May 1, 2013, it is still subject to the requirement that all new subscribers must be enrolled in the project on or before October 31, Any ETC that will have difficulty making this deadline should contact the Wireline Competition Bureau directly to discuss this further. PROJECT CODE IDENTIFIERS (PCIs): 3. How is a Broadband Pilot Project s treatment different from its plan? The treatment is the offer an ETC makes to a potential subscriber (customers cannot select their treatments). The plan is the choice made by the subscriber from available options. For example, a project might offer one group of consumers a $10 discount off of the retail price of broadband, and might offer another group of consumers a $20 discount. These are two separate treatments. The consumers offered a $10 discount might have the ability to choose to purchase 3/1 Mbps service for $15 or 10/2 service for $20. Theses options represent two plans within one treatment. 4. If an ETC is only offering one treatment per geographical group, can there be more than one plan? If the ETC is offering only one treatment to consumers in each geographic group, it could have one plan for that group, or it could have multiple plans within the single treatment, depending on whether the ETC is offering consumers within the treatment different options to choose from. 5. If a project offers a variety of equipment possibilities, would each service offering be its own treatment?

2 A project in which the carrier offers different equipment to separate groups of consumers has more than one treatment. However, if within a given treatment customers may choose their equipment then each equipment option constitutes a plan within the treatment (see next question). 6. If a treatment specifies that hardware is available for anyone who would like it, how does an ETC differentiate between the subscribers who choose to receive the hardware and those who do not? If the consumer can choose from among hardware options, the treatment includes more than one plan. If the customer automatically received the hardware without the option of choosing, the treatment consists of only one plan. 7. What if hardware is automatically offered to every potential subscriber, but the cost of that hardware varies? Offering hardware at different prices to different groups of consumers equals separate treatments. PROJECT KEYS: 8. Should customers that are not receiving a subsidy be included into the study/pilot? Some projects include a control group, but not all projects must include customers not receiving a subsidy in their reporting. 9. The examples in the presentation show that the treatment ID is only one digit, but what if a project has more than 10 treatments? If this is the case, please contact USAC to discuss. Customer ID: 10. Does the customer ID have to be numeric? Yes, the five-digit customer ID, which is assigned by the ETC, must contain only numbers. 11. Does the customer ID have to be random or can it mean something to the company? The customer ID should not reveal the consumer to USAC or any outside party, but the ETC may assign customer IDs based on its own logic. ETCs should retain accurate records of the subscribers that participate in the Broadband Pilot Program, including the ability to match subscriber names with customer IDs. DATA COLLECTION:

3 12. Will USAC provide templates for companies to submit data? Yes. All data should be submitted on a template, which can be found on USAC s Broadband Pilot Program page. 13. The Project Code ID has dashes in it. Does it need to be formatted this way? The template is formatted to automatically generate the ID with dashes. 14. On Block C, when a carrier offers treatments throughout every zip code in a state, is the geographical code the state or the zip code? The ETC only needs to list all zip codes on Block C if it is varying treatments by zip code (that is, making different service offerings to different groups of people based on their zip code). If the same treatment is offered throughout a state, the ETC can use the state for the geographic code in its PCI, rather than all the zip codes in a state. 15. What if a project uses unique geographical areas (such as apartment building) for purposes of offering consumers various treatments? USAC will work with ETCs to create a key that matches the geographic ID to each project s geographic area, whether it is census tract, apartment building or county. Projects that use zip codes as their geographic area should use the five-digit zip code as the geographic ID. 16. In Block B, should only zip codes be listed, even if the treatment is arranged according to census tract? Yes. Projects that use census tract as geographic area will record a Geographic ID that reflects census tract in Block C, but Block B should contain only zip codes for all projects. 17. How should ETCs complete the field titled Total number of Lifeline Eligible in study population in Block D? ETCs should provide an estimate of the Lifeline-eligible population within their project s geographic area. If an ETC is using mass media mechanisms to advertise the program, it should have an idea of how many potential Lifeline eligible customers are in the target population. 18. Can consumers who are not currently customers of the carrier accept the offered broadband treatment? It depends on the details of each carrier s pilot project, as approved by the Wireline Competition Bureau.

4 19. If an ETC uses mass mailings as a means of enrolling potential customers and sends more than one mailing to the same group of potential consumers, should each round of mailings be recorded as a separate offer? No. ETCs should report only the total number of potential customers to whom the offer was made. 20. When are the quarterly submissions due? ETCs will have until the end of the month following the last month of the quarter to be reported. For example, once quarter 2 ends on the last day of June 2013, each ETC will have until the last business day of July 2013 to submit Quarter 2 data to USAC. 21. What if a subscriber wants to change his or her broadband plan at some point during the 12 months he or she receives subsidized broadband service? A subscriber is permitted to change his or her broadband plan during the 12 months of subsidized service based on the terms offered in the project. This subscriber, however, will now have two subscriber IDs. When reporting data for this subscriber, the ETC is required to include all subscriber IDs assigned to that particular subscriber. The first subscriber ID will represent the original plan selected and the second subscriber ID will represent the second plan selected. The only difference between the subscriber IDs will be the plan code. Please see your individual Project Key for numbering sequence. For example, a customer originally selects a plan with 1GB data plan and decides to upgrade to 2GB data plan, mid-pilot. The original subscriber ID assigned to them ( ) would need to be changed to reflect the new plan ID, (see underline). If an ETC already submitted block E, it will need to submit another Block E with the updated subscriber ID. Also, no subscriber may receive more than 12-months of subsidized service in total regardless of whether they switched to a different plan mid-way through the Broadband Pilot Program. 22. What happens if a subscriber fails to uphold contractual obligations (e.g. nonpayment, failing to take required digital literacy training, etc.)? A subscriber may be de-enrolled for failing to fulfill an obligation under the terms of the broadband service offering made by the ETC. If a subscriber is de-enrolled, but later complies (that is, makes a payment or completes digital literacy training), they may be re-enrolled in the Broadband Pilot Program. If this situation occurs, the ETC must record and submit two entries for that subscriber ID in Block E. The first entry would record the original date subscribed. The second entry would record the re-enroll date in the same field, date subscribed. In addition to reporting in Block E, the ETC would submit two Block F entries. The first entry would record first de-enroll date in the field, date service ended. The second entry would record the last date the service ended. 23. Under what circumstances other than non-payment or failing to comply with specific terms of the service offering can an ETC de-enroll a subscriber from the Broadband Pilot Program?

5 ETCs should follow the same de-enrollment guidance place for the Lifeline program. Information regarding de-enrollment can be found on the De-Enrolling Consumers page of USAC s website. 24. How should an ETC report the number of subscribers who participated in the digital literacy offering on Block E if the carrier cannot ascertain whether a consumer will actually attend until after a digital literacy event has occurred? If a subscriber elects to participate in an upcoming digital literacy training event, the ETC should report on Block E that the subscriber is participating in digital literacy. Subscribers that elect not to participate, or say that they do not know if they will participate, should be recorded on Block E as not participating. CERTIFICATION 25. Will Block G (consumer survey) be available in Spanish? Yes. The consumers of ETCs that elect to use USAC to collect data via an on-line survey will have the option of answering the questions in English or Spanish. ETCs that collect data directly from consumers have the option of translating the survey into Spanish or any other language. The survey results must be submitted to USAC in English. 26. Can a carrier record the oral responses of its consumers to collect the survey information in Block G? Yes. Oral recordings, however, must be summarized by the ETC and submitted to USAC on the template created by USAC. 27. The question about the number of household members using broadband on the survey is not clear. Should consumers list everyone in the household? Consumers should total the number of individuals in the household who will potentially use the broadband service. 28. What is the process if an ETC opts to have USAC collect Block G survey responses from its subscribers? USAC will send the ETC a web link that the carrier will then provide to its Broadband Pilot Program subscribers. The carrier must provide each subscriber with his or subscriber ID, which is needed to begin the survey. Upon completing the survey, subscribers will see that their survey was successfully submitted. USAC will receive the survey results electronically and the ETC will not have to summarize and submit Block G data to USAC.

6 29. If an ETC elects to have USAC conduct the survey, is the ETC still responsible for follow-up and outreach with subscribers who have not yet completed it? How will the ETC know which subscribers have completed the survey? Yes. The ETC must follow-up with its own subscribers to ensure they complete the survey. USAC will provide ETCs with a report showing which surveys (by Subscriber ID) have been received. 30. The broadband consumer survey (Block G) asks the consumer to list the device, or devices, that will be used to access broadband service during the Broadband Pilot Program. If the ETC is only offering one type of device (a tablet, as an example), can it auto-fill or remove this field from the survey to prevent consumer confusion? No. ETCs should allow consumers to answer this question. The subscriber should list all possible devices that might be used to access broadband service during the Broadband Pilot Program. Although an ETC provides, for example, a tablet to its consumers, they may still be able to utilize the broadband service on other devices they already own (such as a computer or smart phone). 31. Are subscribers who report that they currently have broadband service, or if they have had broadband service within the past 60 days, ineligible to receive subsidized broadband service through the Broadband Pilot Program? Assuming they are ineligible, does an ETC have to make an offer to additional consumers upon finding that some consumers who received their marketing offer are currently receiving broadband in order to meet the project s target of making offers to a certain number of eligible consumers? Consumers who currently have broadband, or have had broadband service within 60 days prior to completing the survey, are ineligible to participate in the Broadband Pilot Program. If an ETC has committed to offering the discount to a specific number of eligible consumers, it should monitor the number of consumers who are deemed ineligible and offer service to additional consumers in order to meet this commitment. 32. Must subscribers confirm that they do not currently subscribe to broadband twice, both in a certification to the ETC and again when responding to the consumer survey (Block G)? If so, and the two responses differ, should the carrier contact the customer to confirm whether or not the consumer is currently receiving broadband service? Yes. Consumers must confirm in both places that they do not already subscribe to broadband service. If the responses differ, the ETC should then reach out to the customer to verify eligibility. Yes. 33. Is a mobile router considered a hot spot?

7 34. If a consumer has Lifeline discounted phone service, but pays for DSL out of pocket, is he or she eligible? No. Consumers who currently receive broadband service are not considered to be new adopters and, therefore, are ineligible to participate in the Broadband Pilot Program. 35. Can an ETC elect not to provide service to subscribers until they complete the survey? Yes. To ensure consumers provide the required information contained in the survey form (Block G), ETCs have the discretion to require consumers to complete the survey information (Block G) before the consumer accesses the broadband service. REIMBURSEMENT: 36. There is potential for an ETC to file a support claim that exceeds its budget. How would that be handled? The Broadband Pilot Program Order specifies a dollar amount for each project and, within that, a dollar amount for each ETC (for projects that include more than one carrier). USAC will be monitoring the amount disbursed to each project and ETC to ensure that spending caps are not exceeded. If an ETC believes it is in danger of exceeding its budget, it should contact the Wireline Competition Bureau as soon as possible; USAC will not disburse above spending caps without approval from the Wireline Competitive Bureau. 37. If an ETC exceeds its budget, can it continue to provide discounted broadband service, even though it cannot receive reimbursement from USAC? USAC will not disburse funds to an ETC after it reaches its funding cap, but the carrier can choose to continue to provide discounted service to the participating Broadband Pilot Program subscribers. Furthermore, if a subscriber participating in the Pilot Project has received any subsidized service then the ETC is expected to report all requested data for that subscriber through the completion of the Broadband Pilot Program even if some service was unsubsidized. 38. Should ETCs claim support on Form 550 for partial month subscribers? No. ETCs should report monthly subscriber numbers on Form 550 the same way they do on FCC Form 497. ETCs should take a snap shot of their subscriber base on the same day each month to report active subscribers. ETCs should retain a subscriber list that includes all the subscribers for which they are claiming support each month in order to validate their support claims.