In the February 20, 2026 edition of the ICORE Blog we reported on an FCC NPRM entitled “Lifeline and Link Up Reform and Modernization”. The NPRM seeks comment on reforms to the Lifeline Program to ensure that federal Lifeline funds go to eligible Americans, enhance program integrity, and ensure that service providers comply with the Commission’s rules and regulations. Comments in this proceeding have now been filed by the Small Company Coalition (Coalition), an alliance of rural telecommunications companies. The Coalition’s comments are discussed below.
The NPRM proposes that Lifeline Program support is a “federal public benefit” and is therefore only available to U.S. citizens and persons with appropriate qualified status and seeks comment on proposals to ensure that Lifeline support is used to benefit only legal, living, and eligible Americans consistent with Section 254 of the Act through enhanced qualification requirements. Further, the NPRM proposes reforms that seek to improve program integrity and efficiency, including reforms applicable to the states that have been permitted to opt out the program’s integrity verifications conducted by USAC and instead perform their own verifications. Finally, the NPRM seeks reforms designed to promote more principled service provider conduct to ensure compliance with all Lifeline Program rules and further seeks to streamline the Lifeline Program process to minimize stakeholder confusion.
The NPRM was adopted on February 18, 2026. FCC Chairman Carr and Commissioner Trusty voted to approve the NPRM while Commissioner Gomez dissented in part and concurred in part. Each Commissioner issued a statement at that time. In his statement Chairman Carr strongly supported the NPRM’s proposals sighting the nearly $1 billion-per-year of support through the Lifeline Program and the FCC’s responsibility to be a good steward of this USF Program. He cited a recent Inspector General report that identified serious integrity issues in the Lifeline Program, including benefits being claimed for dead people and others who are not lawfully eligible under federal law in particular in opt out states where the National Verifier was not used to determine eligibility. He concluded by stating that the proposed reforms would strengthen eligibility verification, close loopholes, and restore confidence in the Lifeline Program. In her comments, Commissioner Trusty pointed to the important role that the Lifeline Program plays in fulfilling the Commission’s statutory mission: to make communications services available to all Americans. She cites the Program’s past success in enabling countless households to afford communications services but states that the Program has faced persistent fraud, waste, and abuse challenges and welcomes stakeholder comment on the NPRM’s proposals to address these issues. Commissioner Gomez, in her comments, stated that connectivity should be treated as an essential service, not used as a political tool and points to the issue of affordability as the most important issue that needs to be addressed regarding the Lifeline Program. Further, she adds that $9.25 per month is not sufficient support and suggests that the Program should be expanded and provide greater support for affordability modeled after the success of the Affordable Connectivity Program (ACP). Commissioner Gomez does acknowledge the Inspector General’s report discussed above and agrees with the NPRM’s request for comment on the report’s specific recommendations for addressing instances of fraud due to the enrollment of deceased individuals and duplicate enrollment. She counters, however, the Inspector General’s report did not recommend raising eligibility thresholds or imposing additional burdens on consumers. She further adds that the Commission fails to demonstrate how narrowing eligibility for the Program and erecting barriers to enrollment will help to address the Inspector General’s findings of fraud.
The Coalition’s comments indicate broad support for the Commission’s efforts via the NPRM to address instances of abuse within the Lifeline Program but urges consideration of the administrative impact on small companies from additional oversight measures. In regard to the NPRM’s proposal requiring usage tracking and non-usage de-enrollment, the Coalition supports both items with the caveat that any potential increase in reporting requirements must be closely monitored and urges the Commission to be considerate of increasing administrative costs for small companies. The Coalition supports streamlining of the Lifeline Program rules including deleting rules related to the ACP and adds that if the ACP is ever reinstated, care must be taken to ensure that only those that are truly in need of such funding are eligible to participate in the program. Further, the Coalition supports the restriction that Lifeline benefits should only be available to U.S. citizens and qualifying non-citizens. Regarding whether opt out states should be permitted to continue to use their own verification processes, the Coalition cites the Inspector General report mentioned above and states that this should not continue. Finally, the Coalition addresses Commissioner Gomez’s comments discussed above. The Coalition expresses disagreement with Commissioner Gomez’s assertion that enhanced identity verification measures create unnecessary burdens for Program applicants and asserts that neither the current nor the proposed verification measures create an unnecessary burden for legitimate Lifeline applicants. In regard to Commissioner Gomez’s comments regarding affordability, the Coalition states that no consideration can be given to increasing the amount of Lifeline support while significant waste, fraud, and abuse exist within the program.
We expect that additional comments in this proceeding will be filed by interested Parties in the future and we’ll provide updates accordingly.
