CPUC May Soon End SSN Requirement for Calif. LifeLine

The CPUC decided a decade ago that California LifeLine eligibility should extend to people without SSNs but never changed forms to make that possible. Monday’s proposed decision would create a process where people could apply without entering the last four digits of their SSNs. Low-income advocates are “excited” that “finally, finally it does look clear that the application will be changed,” said Lena Silver, Neighborhood Legal Services of Los Angeles County director-policy, in an interview Tuesday. However, low-income advocates still have accessibility concerns, she said.

Most parties supported a previous CPUC staff proposal in comments in May, though T-Mobile’s Assurance Wireless argued that enrolling applicants without SSNs should be an option rather than a requirement (see 2405130044). Also, consumer advocates sought tweaks to the CPUC staff proposal to ensure maximum inclusion, while urging the CPUC to ensure that providers can’t refuse service to people without SSNs. T-Mobile declined to comment.

The proposed decision would create a “dual application pathway” so people could apply with or without SSNs. “Service providers that participate in California LifeLine must use the application offering the dual application pathway,” the draft said. The proposal would require CPUC staff to work with the program’s third-party administrator (TPA) to update the LifeLine application within three months of a final decision. At the same time, staff would work with the TPA to integrate identity verification software. When that software is ready, “service providers shall follow the directions provided by Staff for the implementation of identity checks for LifeLine applicants without an SSN.”

“Any applicant seeking income-based eligibility, whether with an SSN or without, must provide documentation … demonstrating that the applicant’s total household income does not exceed the program’s income eligibility limits,” the draft said. The CPUC won’t require a notarized affidavit from applicants claiming zero income, as staff had previously proposed, said the draft. “Staff will monitor for any abnormal increase in California LifeLine applicants seeking income-based eligibility and claiming zero income.” Additionally, some may be eligible based on their participation in other qualifying assistance programs, and staff may continue to update that list by resolution, the draft said.

The CPUC draft would decline providers’ request for a “safe harbor” so they don’t have to reimburse the program if an application is determined to be fraudulent. “Offering service providers a safe harbor would undermine a key protection against waste, fraud, and abuse,” the draft said. “Service providers must not be relieved of the duty to mitigate fraudulent applications as they enroll applicants in the program.” Also, integrating TrueID, a LexisNexis authentication software, provides “sufficient guardrails to reduce the program’s vulnerability,” it said.

With the FCC still requiring the last four digits of SSNs to apply for federal Lifeline, California LifeLine will make up for the lost federal support for SSN-less applicants, the CPUC draft said. “However, Staff will use the data it receives during the implementation of this process to monitor service providers’ claims for the federal makeup and the impact that providing a full federal makeup has on the California LifeLine Fund.”

It’s good that it’s “no longer under debate” whether California LifeLine providers must accept applications from people without SSNs, said NLSLA’s Silver. Low-income advocates would have liked to see faster implementation than three months, especially considering the initial policy decision was made a decade ago, she said. “But at least we have a very clear time frame.” Also, the group is glad that the draft requires participants to attest they aren't able to provide an SSN rather than to attest they were never issued one. That will open the program to people “who no longer have access to an SSN, which is a huge problem” for people who are homeless or were recently released from incarceration, among others, said Silver: Phones are critical for them to access healthcare, social services, calling police and more.

But Silver raised concerns with a proposed requirement that SSN-less applicants must provide a government-issued ID. People who are undocumented and lack an SSN aren’t eligible for a California-issued ID until 2027 under state law, she said. Some other California social service programs have more open identity verification requirements, she said. “We are disappointed that they’re continuing to have this very strict definition of ID documents.” In addition, requiring TrueID could be a barrier for some because the verification tool requires a digital device that can upload selfies and photos of ID documents, Silver said. “It’s hard to understate the irony of a free phone program requiring access to a phone to access the phones.”

The Utility Reform Network praised the draft. “For the last decade, immigrants and consumers who were issued SSNs but could not provide them, including people who struggle with housing insecurity and people fleeing domestic violence situations, were excluded from receiving essential phone services they may have otherwise qualified for,” said Ashley Salas, TURN telecom regulatory and policy attorney. “The CPUC’s proposed decision acknowledges telecommunications services are crucial for all members of our communities.”