Survey of State Public Utility Commissions on the Universal Service Fund Low Income Program

U.S. Government Accountability Office

Contents

• Introduction
• Survey Respondent
• Background Questions
• Important Instructions
• Enrollment Procedures
• Enrollment Procedures (Continued)
• Certification Procedures
• Certification Procedures (Continued)
• Verification Procedures
• Program Outreach
• Program Oversight
• Broadband Service
• Submit your responses to GAO

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Introduction

The U.S. Government Accountability Office (GAO), the evaluation arm of Congress, has been asked to review the administration and performance of the Universal Service Fund (USF) Low-Income program. As part of this study, GAO is surveying state public utility commissions in all 50 states and the District of Columbia. We realize that there are several components to the Low Income program, but for the purpose of this survey, please focus only on the Lifeline program.

The results of this survey, along with information we obtain from the Federal Communications Commission (FCC) and the Universal Service Administrative Company (USAC), will be presented in a written report to Congress. Your state's participation is essential for us to provide Congress with a comprehensive understanding of the Low-Income program. To this end, please feel free to work with your colleagues if you require their input to complete the questionnaire.

This survey should take approximately 60 to 90 minutes to complete and does not need to be completed in one sitting. Your responses can be saved and accessed at a later date.

Thank you in advance for your assistance and cooperation in taking part in our survey.

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Survey Respondent

1. Please provide the following information for the organization and the person primarily responsible for completing this survey in case we need to contact you to clarify a response.

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Name:

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Position title:

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Agency:

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Telephone (Include area code):

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E-mail address:

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Background Questions

2. Is there an add-on to the federal Lifeline benefit in your state? (An "add-on" refers to an intrastate discount in addition to the federal Lifeline support. It may be state-mandated Lifeline support or Lifeline support provided by the carrier, for example.)

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3. What is the funding source for the add-on to the federal Lifeline benefit?

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If you answered "Other" above,
please specify funding source here.

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4. What is the maximum total monthly benefit amount in your state? (Please enter the dollar amount of the maximum total Lifeline benefit - federal benefit and add-on, if applicable, combined. If the amount varies, please report the highest possible amount and provide an explanation.)

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If this amount varies,
please explain why.

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5. Which of the following types of service providers have been certified, either by the state or FCC, as an eligible telecommunications carrier (ETC) in your state? (Please select all that apply.)

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1. Wireline

2. Wireless

3. Cable Company

4. Voice Over Internet Provider (VOIP)

5. Other - Please specify below.

6. Do not know

If you answered "Other" above, please
specify other service providers here.

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6. A "federal default state" is a state that does not have its own Lifeline program or a state that has its own Lifeline program but elects to use the federal eligibility, certification, and verification requirements.

Is your state a federal default state?

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7. Does your state impose or enforce its certification and verification requirements on all of the ETCs operating in the state?

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8. If your state does not impose or enforce its certification and verification requirements on certain carriers, has the state informed the relevant carrier(s) that it must follow federal default procedures?

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9. If your state does not impose or enforce its certification and verification requirements on certain carriers, has the state informed USAC that it does not assert jurisdiction?

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10. For the purpose of this survey, a bundled service offering is one that allows consumers to subscribe to packages that combine telephone service with Internet access and/or television service.

Do ETCs in your state allow consumers to apply the Lifeline discount to a bundled service offering or package that includes telephone service?

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Important Instructions

PLEASE NOTE: The following three sections in this survey focus on enrollment procedures, certification procedures, and verification procedures. Please answer these questions only as they relate to the ETCs over which the state has imposed or enforced its enrollment, certification, and verification requirements.

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Enrollment Procedures

11. Which of the following entities process applications for the Lifeline program?
(Please select all that apply.)

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1. State public utility commission

2. Other state agency - Please name the other state agency below.

3. Third-party administrator

4. Eligible Telecommunications Carrier (ETC)

5. Other - Please specify below.

6. Do not know

If you answered "Other state agency" or "Other" above, please name the other state agency or specify any other entities here.

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12. Are the following methods available to consumers to apply for the Lifeline program?
(Select one answer in each row.)

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a. In-person

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b. Mail

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c. On-line

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d. Phone

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e. Other - Please specify below.

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Other methods available to consumers to apply.

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13. Can consumers qualify for the Lifeline program on the basis of enrollment in other public assistance programs?

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14. If yes to question 13, do the following public assistance programs qualify consumers for support?
(Select one answer in each row.)

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a. National School Lunch Free Lunch Program

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b. Temporary Assistance for Needy Families (TANF)

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c. Medicaid

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d. Supplemental Nutrition Assistance Program (SNAP)/formerly Food Stamps

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e. Supplemental Security Income (SSI)

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f. Federal Public Housing (Section 8)

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g. Low Income Home Energy Assistance Program (LIHEAP)

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h. Programs available to households on federally recognized tribal lands

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i. Other - Please specify below.

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Other qualifying public assistance programs.

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Enrollment Procedures (Continued)

15. Can consumers qualify for the Lifeline program on the basis of household income alone if they do not participate in a qualifying public assistance program?

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16. If yes to question 15, what is the income eligibility limit to qualify for the Lifeline program?

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If "Other," please specify the income eligibility limit.

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17. Does your state use an "automatic enrollment" system that uses an electronic interface between a state agency and ETCs that allows low-income households to automatically enroll in Lifeline following enrollment in a qualifying public assistance program?

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18. If no to question 17, does the state/program administrator have plans to development an automatic enrollment system?

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19. Does the state, program administrator, or ETC send "pre-approved" Lifeline applications to Lifeline-eligible households which, if returned to the state, program administrator, or ETC, result in the enrollment of that household in the Lifeline program?

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20. If no to question 19, does the state, program administrator, or ETC have plans to start this practice?

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21. In your opinion, to what extent, if at all, is each of the following a barrier to enrollment in the Lifeline program? (Select one answer in each row.)

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a. Eligible consumers are unaware of the program

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b. Eligible consumers find the certification and/or verification procedures too difficult

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c. Services for Lifeline support recipients are limited and eligible consumers forgo the benefit to access additional services

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d. Lifeline support is not available for wireless service

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e. Other - Please specify below.

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Other barriers to enrollment.

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22. If you have any comments related to any of your answers in this section on enrollment procedures, please enter them in the space below.

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Certification Procedures

For the purpose of answering questions 23-31 in this section, please refer to the following definitions.

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Program-based Eligibility - refers to eligibility based on participation in any of the public assistance programs identified in the previous section that qualify a household for the Lifeline program.

Income-based Eligibility - refers to eligibility based on proof of income below the threshold indicated in the previous section that qualifies a household for the Lifeline program.

Automatic enrollment - refers to a system that uses an electronic interface between a state agency and ETCs to allow low-income households to automatically enroll in Lifeline following enrollment in a qualifying public assistance program.

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23. Does your state have procedures in place to certify program-based eligibility for the Lifeline program?

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24. If yes to question 23, which entity is responsible for certification of program-based eligibility for the Lifeline program? (Please select all that apply.)

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1. State public utility commission

2. Other state agency - Please name the other state agency below.

3. Third-party administrator

4. Eligible Telecommunications Carrier (ETC)

5. Other - Please specify below.

6. Do not know

If you answered "Other state agency" or "Other" above, please name the other state agency or specify any other entities here.

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25. If yes to question 23, are the following certification procedures of program-based eligibility used? (Select one answer in each row.)

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a. Self-certification under penalty of perjury that the consumer is enrolled in a qualifying assistance program

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b. Presentation of documentation of enrollment in a qualifying assistance program

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c. Automatic enrollment of eligible consumers in the Lifeline program

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d. Other - Please specify below.

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Other certification procedures for program-based eligibility.

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Certification Procedures (Continued)

26. Does your state have procedures in place to certify income-based eligibility for the Lifeline program?

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27. If yes to question 26, which entity is responsible for certification of income-based eligibility for the Lifeline program? (Please select all that apply.)

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1. State public utility commission

2. Other state agency - Please name the other state agency below.

3. Third-party administrator

4. Eligible Telecommunications Carrier (ETC)

5. Other - Please specify below.

6. Do not know

If you answered "Other state agency" or "Other" above, please name the other state agency or specify any other entities here.

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28. If yes to question 26, are the following certification procedures of income-based eligibility used?
(Select one answer in each row.)

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a. Self-certification of income and the number of people in the household under penalty of purjury

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b. Presentation of documentation of income

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c. Automatic enrollment of eligible consumers in the Lifeline program

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d. Other - Please specify below.

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Other certification procedures for income-based eligibility.

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29. For question 28b, did you answer "Yes," indicating that it is necessary for a consumer to present some sort of documentation of income to certify for income-based eligibility?

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30. If a consumer must present documentation to certify income-based eligibility, are the following considered as accepted documentation? (Select one answer in each row.)

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a. Prior year's state, federal or tribal income tax return

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b. Current income statement from an employer or paycheck stub

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c. Social Security statement of benefits

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d. Unemployment or Workmen's Compensation statement of benefits

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e. Federal or tribal notice letter of participation in Bureau of Indian Affairs General Assistance program

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f. Divorce decree

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g. Child support documents

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h. Other - Please specify below.

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Other accepted documentation to certify for income-based eligibility.

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31. If you have any comments related to any of your answers in this section on certification procedures, please enter them in the space below.

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Verification Procedures

32. Which entity is responsible for verifying the continued eligibility of Lifeline support recipients?
(Please select all that apply.)

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1. State public utility commission

2. Other state agency - Please name the other state agency below.

3. Third-party administrator

4. Eligible Telecommunications Carrier (ETC)

5. Other - Please specify below.

6. Do not know

If you answered "Other state agency" or "Other" above, please name the other state agency or specify any other entities here.

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33. Does the responsible entity or entities (identified in Question 32) use the following procedures to verify the continued eligibility of consumers receiving Lifeline support?
(Select one answer in each row.)

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a. Random audits of Lifeline support recipients

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b. Periodic submission of documents (e.g. annual
re-certification or re-verification process requiring documentation of enrollment in a qualifying program or proof of income)

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c. Annual self-certification (e.g. annual re-certification process during which Lifeline support recipients certify that they are still enrolled in a qualifying program or earning income under a certain threshold, but no documentation is required)

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d. On-line verification system using databases of public assistance program participants or income reports

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e. Verification of a statistically valid sample of Lifeline subscribers

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f. Other - Please specify below.

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Other procedures used to verify continued eligibility.

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34. Does the entity responsible for verification of consumers' continued eligibility for Lifeline support have access to information that could help ensure that a household is only receiving one Lifeline subsidy?

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34a. If yes to question 34, what information is available?

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34b. If no to question 34, is there another mechanism in place to help ensure that a household
         is only receiving one Lifeline subsidy?

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34c. If yes to question 34b, what is that mechanism?

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35. If you have any comments related to any of your answers in this section on verification procedures, please enter them in the space below.

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Program Outreach

36. Are the following advertising and marketing activities used by ETCs in your state?
(Select one answer in each row.)

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a. Newspaper(s)

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b. Radio

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c. Television

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d. Other print advertisements (e.g. pamphlets, bill inserts, posters, billboards)

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e. Outreach to community groups

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f. Partnerships with non-profit organizations

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g. Press releases

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h. Other - Please specify below.

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Other advertising and marketing activities used by ETCs.

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37. In addition to the advertising and marketing activities used by ETCs, are the following advertising and marketing activities used (either through state funding or public service announcements/campaigns)
by your state for the Lifeline program? (Select one answer in each row.)

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a. Newspaper(s)

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b. Radio

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c. Television

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d. Other print advertisements (e.g. pamphlets, bill inserts, posters, billboards)

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e. Outreach to community groups

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f. Partnerships with non-profit organizations

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g. Press releases

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h. Other - Please specify below.

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Other advertising and marketing activities used by your state.

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38. How much did your state spend on outreach activities for the Lifeline program in fiscal year 2009?

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Dollar amount:

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Do not know

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1.

39. If you have any comments related to any of your answers in this section on program outreach, please enter them in the space below.

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Program Oversight

40. Does your state's commission or other involved state/program administrator conduct Lifeline-related audits of ETCs?

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40a. If yes to question 40, on average, how many audits are conducted annually?

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Number of audits:

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Do not know

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1.

40b. If yes to question 40, what types of audits are conducted? (Check all that apply.)

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1. Compliance with program rules

2. Review of internal compliance controls

3. Review of internal financial controls

4. Accuracy of disbursements

5. Other - Please describe.

6. Do not know

Other types of audits.

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41. Does your state have any additional internal controls for overseeing ETCs' compliance with Lifeline program rules?

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41a. If yes to question 41, what are these internal controls?

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42. Does the state/program administrator have a mechanism to identify if ineligible consumers received Lifeline support?

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Description of mechanism to identify if ineligible consumers received Lifeline support.

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42a. If yes to question 42, has the state/program administrator identified instances where ineligible
        consumers received Lifeline support?

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Circumstances and corrective actions, if any, that were followed.

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43. Does the state/program administrator have a mechanism to identify if consumers received more than one Lifeline subsidy per household?

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Description of mechanism to identify if consumers received more than one Lifeline subsidy per household.

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43a. If yes to question 43, has the state/program administrator identified instances where consumers
        received more than one Lifeline subsidy per household?

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Circumstances and corrective actions, if any, that were followed.

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44. Does the state/program administrator have a mechanism to identify other consumer misuse of funds from the Lifeline program?

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Description of mechanism to identify other consumer misuse of funds from the Lifeline program.

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44a. If yes to question 44, has the state/program administrator identified instances of other consumer
        misuse of funds from the Lifeline program?

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Circumstances and corrective actions, if any, that were followed.

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45. Overall, how concerned are you about consumer fraud and carrier fraud in the Lifeline program?
(Select one answer in each row.)

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a. Consumer fraud

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b. Carrier fraud

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46. If you have any comments related to any of your answers in this section on program oversight, please enter them in the space below.

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Broadband Service

47. In your opinion, what are the potential advantages and disadvantages of including broadband service as an eligible Lifeline benefit?

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a. Potential advantages of
    including broadband service.

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b. Potential disadvantages of
    including broadband service.

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Submit your responses to GAO

48. This completes our survey. Are you ready to submit your final completed survey to GAO?
(This is equivalent to mailing a completed paper survey to us. It tells us that your answers are official and final.)

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You may view and print your completed survey by clicking on the Summary link in the menu to the left..

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