Lifeline

FCC Form 555 FAQs

Questions About Specific Lines

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Q1: For Line A, who is counted in the "total number of subscribers"?

A1: Enter the number of subscribers you had with anniversary dates in that month. There is flexibility in the number you report here, but you must be able to support/document your claim. Many filers choose to use the number of subscribers recorded in the NLAD Subscriber Snapshot Report.

For example, for July anniversary dates, if a service provider started the recertification process on March 15, they can populate Line A with the NLAD Subscriber Snapshot Report from March 1. Users will need to filter the Subscriber Snapshot Report by anniversary date to see how many subscribers have anniversary dates in July.

Do not enter the total number from the NLAD snapshot, or the number of subscribers from your FCC Form 497 reimbursement claim.

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Q2: For Line B, what is the starting point for "de-enrolled prior to recertification attempt"?

A2: Line B shows any discrepancy between the number of subscribers you listed on Line A, and the number of subscribers that you included in your recertification process.

For example, if your company based its recertification process for July anniversary dates on the March 1 NLAD Subscriber Snapshot Report, but you didn't start the recertification process until March 15, anyone who de-enrolled between March 1 and March 14 would be counted on Line B.

The "recertification attempt" is whenever you started the recertification process; it is not necessarily the beginning of the 150-day period or the first day of the 60-day period. For example, if you first used a database query, the date of the query is the beginning of your recertification attempt. If you did not use a database query and began the recertification process using direct contact (written notice), Day 1 of the notice is the beginning of your recertification attempt.

Also use Line B for cases when a subscriber de-enrolls after the recertification attempt begins, but it was for reasons not related to recertification. For example, if the subscribers transferred their Lifeline benefit to another company, or were de-enrolled for non-usage after the recertification attempt began, you can count them on Line B.

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Q3: Is non-usage only for certain types of ETCs?

A3: Yes. Only ETCs that do not assess or collect a monthly fee from its Lifeline Program subscribers need to report de-enrollment for non-usage. Most ETCs subject to non-usage are wireless service providers who offer a specific allotment of pre-paid minutes per month without a monthly fee. For more information pertaining to the de-enrollment requirements of pre-paid ETCs, refer to 47 C.F.R. Section 54.405(e)(3).

Other types of service providers should select "no" to the question "Is the ETC subject to the non-usage requirements," and then the fields will be inactive/greyed out.

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Q4: How do we report a situation where a subscriber is recertified through a database dip, and then they de-enroll prior to their anniversary date?

A4: If they passed a database check, that's considered a successful recertification. If your company performed the database query, the subscriber should be counted on Line D (Subscribers recertified through access to state or federal database).

If a third party recertified the subscriber through a database check, the result should be reported in Block L (Subscribers that recertified through a request from a state administrator, third party, or USAC.

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Q5: What's considered a state database (Lines D-E) vs. a third party (Lines I-L)?

A5: A "state or federal database" means your company queried a database to determine the subscriber's eligibility.

A "third party" means the subscriber's eligibility was reviewed by a state administrator, third-party administrator, or USAC. For example, results from Texas, California, and USAC-elected recertification should be reported in the "third party" section. If a third party performed the recertification, the results should always be reported in Blocks I – L, even if they used a database.

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USAC-Elected Recertification

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Q6: If USAC did our recertification for us (with USAC-elected recertification), should we use the monthly batch results to fill out FCC Form 555?

A6: Yes, use the batch results that USAC provides via email to complete your FCC Form 555. Use the "ETC Recertification Subscriber Snapshot Report" from NLAD as the number for Block A.

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Q7: How do we report subscribers who we recertified in our local office, outside of the USAC-elected process?

A7: List them in the "direct contact" section of the form (Lines F – H), not the 3rd party section

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Online Filing

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Q9: How do I set up user entitlements?

A9: To learn more about establishing and updating user entitlements in E-File, review the Establishing User Entitlements instructions. For questions about existing entitlements, please contact us at (888) 641-8722.

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Q10: Can the "497 Officer" certify the FCC Form 555 online?

A10: Yes. 497 Officer entitlements allow the user to certify both the FCC Form 497 and the FCC Form 555 online.

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General Questions

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Q11: Which subscribers are counted in each month?

A11: Report subscribers by the month of their anniversary date. Do not report them in the month when their recertification period starts or ends. You can see each subscriber's anniversary date in NLAD.

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Q12: What if a company uses two month batches? How does this affect our reporting?

A12: It doesn't. You always need to report the subscribers by anniversary month, even if you chose to batch them into 2-month groups.

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Q13: If my company has had no Lifeline Program subscribers, and didn't file any FCC Form 497s this year, are we is the company still required to file FCC Form 555?

A13: Yes. All ETCs that have a SAC assignment from USAC that has not been relinquished, must complete and file FCC Form 555 with USAC and the FCC.

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Q14: Do we always file one form per SAC?

A14: Yes. One FCC Form 555 is required per SAC. Recertification results are no longer aggregated at the state level.

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Q16: Are third-party administrators required to provide FCC Form 555 data to service providers? What should we do if they don't?

A16: No, it is the solely the service provider's responsibility to file FCC Form 555. If you do not have the data needed to complete your filing, submit the filing with whatever data you have by the deadline, then submit a revision once the data is available. If a third-party working on behalf of the state is not providing the information you need, contact your state administrator.

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Q17: When we file online with USAC does this cover the requirements to file with "USAC, state commissioners, and the FCC"?

A17: No, it does not. After filing with USAC via E-File, service providers need to file a copy in the FCC's Electronic Comment Filing System, Docket 14-171. Please check with your state public utilities/service commission for state requirements regarding your annual recertification.

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Q18: What is the revision deadline for areas affected by hurricanes in 2018?

A18: There is no hard deadline. Please file your original filing on the regular deadline (January 31), and file a revision as soon as the recertification process for the impacted subscribers is complete.

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Q19: Are there instructions? Where can I go for help?

A19: Yes. FCC Form 555 instructions are available, "tool tips" are available inside E-File (click the question mark icon to view the tool tip), and more information is available on the FCC Form 555 web page. If you need further assistance, contact us.

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