20130809TRA to Staff 1-7.pdf

GwENs PURSLEYLLP i
A -O P11 .‘
LAWOFFICES ‘j
601 W.Bannock -...
P0 Box 2720,Boise,Idaho 63701
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Michael C.Creamer
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Gary G.len
Peter G.Barton
ChristopherJ.Beeson
Clint R.BoUnder
Erik J.Bolinder
Preston N.Carter
Jeremy C.Chou
William C.Cole
Michael C.Creamer
Amber N.Dma
Elizabeth M.Donick
Thomas E.Dvorak
Jeffrey C.Fereday
Martin C.Hendrickson
Steven J.Hippler Donald E.
Knickrehm
Debora K.Kristensen
Michael P.Lawrence
Franklin G.Lee
David R.Lombardi
Emily C.McClure
Kenneth R.McClure
Kelly Greene McConnell
Alex P.McLaughlin
Christopher H.Meyer
L.Edward Miller
Patrick J.Miller
Judson B.Montgomery
Deborah E.Nelson
W.Hugh ORiordan,LL.M.
Angela M.Reed
Robert B.White
Of Counsel
Kimberly D.Maloney
Retired:
Kenneth L.Pursley
James A.McClure (1924-2011)
Raymond D.Givens (1917-2008)
Ms.Jean Jewell -Secretary
Idaho Public Utilities Commission
472 W.Washington Street
Boise,ID 83702
August 9,2013
Re:Terracom Inc.‘s Response to the First Production Request ofthe
Commission Staffto Terracom Inc.
Case No.TRA-T-1301
Dear Ms.Jewell:
Please find enclosed for filing with the Idaho Public Utilities Commission the
Responses to the First Production Request ofthe Commission Staffto Terracom Inc.dated
August 9,2013.I am enclosing three copies for the Commission and one additional copy
to be conformed and provided to our runner.The original of these Responses has been
served on Mr.Price.
Please contact me should you have any questions concerning the attached
Response.Thank you for your assistance in this matter.
MCC:bb
Enclosures
1842774_i [11884-21 /
Michael C.Creamer [ISB No.4030]I?!3 iif[’—n-)GIVENS PURSLEY LLP ‘L Jb
601 West Bannock Street H
P0 Box2720 III -
Boise,Idaho 83701-2720
Office:[phone]
Fax:[phone]
mccgivenspursley.corn
Attorneys for Terra Corn,Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISISON
IN THE MATTER OF THE APPLICATION )
OF TERRACOM,INC.FOR DESIGNATION )
AS AN ELIGIBLE TELECOMMUNICATIONS )CASE NO.TRA-T-1301
CARRIER ON A WIRELESS BASIS (LOW )
INCOME ONLY))
TERRACOM INC.’S RESPONSE TO FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO TERRACOM INC.
TO:THE COMMISSION STAFF AND THEIR COUNSEL OF RECORD
COMES NOW,TenaCom Inc.(“TerraCom”),and in response to the First Production
Request of the Cornrnission Staff to TerraCom Inc.,dated July 22,2013,herewith submits the
following information:
REQUEST FOR PRODUCTION OF DOCUMENTS NO.1:On May 20,2013,
Commission Staff received an email from TerraCom that provided information regarding the
Company’s Scripps Howard security breach.The Company stated that a toll-free number was
established for Lifeline subscribers to call TerraCom with questions.Please provide an update of
this situation by answering the following questions:
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C
a.Are you aware of any issues with credit reporting or identity theft that may
have resulted from this security breach?
b.What,if any,action has law enforcement taken against Scripps Howard?
c.Do you have any additional information to report regarding your
investigation into this data breach?
RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS NO.1:To
the best of TerraCom’s knowledge,there have been no reports of any credit reporting or identity
theft issues associated with this incident.We are not privy to any law enforcement action;
however,we have notified and provided information to the following agencies:
The federal Bureau of Investigation
The Minnesota Office of the Attorney General
The Illinois Office of the Attorney General
The Texas Office of the Attorney General
The Nevada Office of the Attorney General
The Colorado Office of the Attorney General
The Maryland Office of the Attorney General
The Kansas Office of the Attorney General
The Missouri Office of the Attorney General
The Indiana Office of the Attorney General
The Indiana Utility Regulatory Commission
The Indiana Office of Utility Consumer Counselor
The New Mexico Public Regulation Commission
The Oklahoma Corporation Commission
The Idaho Public Utilities Commission
The Public Utilities Commission of Ohio
The California Public Utilities Commission
The Minnesota Public Utilities Commission
The Mississippi Public Service Commission
The New Jersey Board of Public Utilities
The Public Service Commission ofWisconsin
The Arkansas Public Service Commission
The Arizona Corporation Commission
The Nebraska Public Service Commission
The Colorado Public Utilities Commission
The Louisiana Public Service Commission
The Nevada Public Utilities Commission
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The Iowa Utilities Board
The Maryland Public Service Commission
The Public Service Commission of West Virginia
The Public Utilities Commission of Texas
The Virgin Island Public Services Commission
The Puerto Rico Public Service Commission
The Missouri Public Service Commission
The Kansas Corporation Commission
The Washington Utilities and Transportation Commission
The Illinois Commerce Commission
The Massachusetts Department of Public Utilities
The Nevada Public Utility Commission
The Vermont Office of Consumer Counsel
The Hawaii Public Utilities Commission
The Georgia Public Service Commission
The Pennsylvania Public Utility Commission
The Rhode Island Public Utilities Commission
The Maine Public Utilities Commission
TerraCom continues to monitor the situation and address any instances of misinformation
reported in the media.Customer response and interest has been low most likely due to the
proactive and open nature of TerraCom’s information.TerraCom has implemented changes to
prevent unauthorized persons from accessing confidential customer information in the future.
TerraCom is willing to provide details of these changes if the Commission desires;however,if
such information is desired,TerraCom requests that it be permitted to be provided on a
confidential basis to protect the personal information of TerraCom’s customers and avoid the
risk of facilitating future unauthorized access to customer information.
Person(s)who will be able to answer questions about or sponsor the answer at any
hearing:Dale $chmick.
REQUEST FOR PRODUCTION OF DOCUMENTS NO.2:On June 25,2013,the
FCC released Enforcement Advisory,DA 13-1435,which reminds Eligible Telecommunications
Carriers (ETCs)receiving federal universal service support from the Lifeline program that they
TERRACOM INC.’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
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are liable for any conduct by their agents,contractors,or representatives (acting within the scope
of their employment)that violates the FCC’s Lifeline rules.Please verify that TerraCom
understands and will comply with this requirement and explain if the Company has made any
changes to the Lifeline application process as a result of this advisory.
RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS NO.2:Our
order process,as described below,ensured that any agent who worked on behalf of the Company
was in compliance with the Lifeline rules.This process remains in effect.
To apply for TerraCom Lifeline service,a customer will fill out an application,provide
the necessary information that all prospective Lifeline customers must provide,and be taken
through successive screens,which clearly explain all relevant legal eligibility requirements.All
applications are handled electronically and subject to several layers of checks discussed below
before being approved for Lifeline service.Regardless of how the customer applies for Lifeline
service,each customer will end up supplying the same information via TerraCom’s standard
electronic customer certification process.
The first check occurs with each applicant undergoing an upfront identity check via Lexis
Nexis.The customer’s name,date of birth and social security number are verified using Lexis
Nexis’Flex ID service.Applicants who fail the identity check are not allowed to continue the
process of completing an application for Lifeline.The next check occurs on the customer
address.If the address is unable to be verified using the Melissa Data address database,once
again the process of completing a Lifeline application does not continue.A third check occurs
throughout the electronic application process by highlighting with an error message any
application field marked required but not completed.Again,an applicant is unable to submit a
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request for service unless all required fields,such as providing an electronic signature,are
populated.
If all of these upfront checks pass,the customer’s information is then electronically
entered into TerraCom’s 05$systems,where the information is then checked against available
databases (the duplicates database,and TerraCom’s list of existing customers).Duplicates are
rejected for service.In the case of multiple applicants at the same mailing address,the customer
must make the “one per household”certification required by §54.410(d)(l).In addition,with the
Lexis Nexis verification,all applicants can be checked against the existing customers to ensure
the same individual is not already receiving Lifeline service without the possibility of a
misspelled name flowing through on a live order.
In those states where TerraCom provides service that requires approval by a Lifeline
administrator (database),TerraCom interacts with that database (for those low-income programs
that make up the database information)to qualify applicants in compliance with §54.410(b)(A)
and (c)(A).Where direct connections to the database are available,TerraCom’s OSS system
approves or denies the applicant based on the response from the database.Where direct
connections to the database are unavailable,TerraCom’s group dedicated to verifying eligibility
queries the state database and either approves or denies the applicant based on the database
response.
For all states in which TerraCom provides service that do not have a Lifeline database,
TerraCom performs the same OSS application and certification checks along with verifying
correct and current proof before approving the applicant for Lifeline service.
TERRACOM INC.’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
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Only after this extensive eligibility process is completed is an eligible applicant given a
phone;the first call on which goes directly to TerraCom’s customer service department for final
authentication.
Despite having an application process that TerraCom believes is the gold standard in the
industry,TerraCom has recently terminated its direct sales agent distribution model.TerraCom
has been highly successful with sales representatives in the past,and its decision to depart from
this marketing channel was driven primarily by cost,by TerraCom’s desire to establish a lasting
presence in each marketplace,its priority to provide high quality service to consumers and to
ensure compliance with federal and state regulations in its participation in the federal Lifeline
program.
TerraCom has been and continues to be,in full compliance with the June 25,2013,FCC
revised order.Simply put,TerraCom verifies eligibility prior to activating Lifeline service
(FCC DA 13-1441,para.5)and again confirms that eligibility before seeking reimbursement in
accordance with the rules under §54.407.Despite TerraCom’s focus on quality customer service
and regulatory compliance,TerraCom did have the unfortunate experience of suffering
regulatory consequences as the result of unapproved and improper statements made by certain of
its former sales representatives in spite of comprehensive training and a clear code of conduct
and disciplinary action policy.Eliminating future use of commissioned sales agents is expected
to substantially reduce extraneous costs related to regulatory compliance and the potential
vulnerabilities created by a few sales agents who do not follow TerraCom’s policies and
procedures for the applicant enrollment process—thus further reducing unproductive costs.
Copies of TerraCom’s Lifeline Compliance Practices and Procedures manual and ETC
Compliance Presentation are provided with this response.
TERRACOM INC.’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
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Person(s)who will be able to answer questions about or sponsor the answer at any
hearing:Dale Schmick.
REQUEST FOR PRODUCTION Of DOCUMENTS NO.3:The FCC’s
DA 13-1441,released on June 25,2013 states that “despite the directives in the Lifeline Reform
Order,some ETCs may be activating phones that they represent enables use of the Lifeline-
supported service for consumers prior to fully verifying the eligibility of such consumers.ETCs
must determine eligibility and may not activate Lifeline service until completing the entire
enrollment process.”Please verify that TerraCom understands and will comply with this
requirement.
RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS NO.3:As
demonstrated by the previous response,TerraCom understands and will comply with this
requirement.
Person(s)who will be able to answer questions about or sponsor the answer at any
hearing:Dale $chmick.
REQUEST FOR PRODUCTION OF DOCUMENTS NO.4:In the above DA 1435,
the FCC reiterated the Conmiission’s rule that Lifeline is a “non-transferable retail service
offering.”This is a fact that must be disclosed to the consumer and included on the certification
form.Please confirm that the Company understands this requirement and explain how the
Company plans to comply.
RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS NO.4:Please
refer to the paper version of TerraCom’s Lifeline certification form for the State of Idaho
provided with this response.TerraCom’s certification form contains this language which the
customer must initial to prove acceptance and compliance.
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Person(s)who will be able to answer questions about or sponsor the answer at any
hearing:Dale Schmick.
REQUEST FOR PRODUCTION OF DOCUMENTS NO.5:In a June 19,2013
article in the UK’s Daily Mail,TerraCom was identified as the subject of a “sting operation”
regarding the misuse of the Lifeline program.The article reports that a TerraCom spokesperson
stated that “the behavior is not acceptable and swift action will be taken to address this situation,
including the employee’s termination from TerraCom.”Please provide your Company’s
explanation of what took place and explain the outcome of TerraCom’s investigation.If
TerraCom’s investigation determined that the employee was portrayed accurately,what
measures are being taken to avoid such behavior in the future?
RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS NO.5:James
O’Keefe,through his “Project Veritas”produced and released a video purportedly exposing
flaws in the “Obama Phone”program (Lifeline),a program that Mr.O’Keefe presumably does
not approve of The “story”was released to the UK Daily Mail.The video was a work of
political advocacy,that contained few,if any,“facts,”and creates the impression that the actors
were actually being enrolled in Lifeline.The video and resulting story documented actors
engaged in,essentially,monologues employing stereotypes of low income Americans and
attempting to elicit responses from Lifeline sales representatives suggesting the sales
representatives condoned abuse of the Lifeline program.No actor applied for Lifeline and no
actor ever received a phone.
Regardless,TerraCom takes seriously any unprofessionalism and the sales representative
shown in the video was terminated for responding to the actors’questions in a manner
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inconsistent with TerraCom’s policies and in violation of its Code of Conduct,a copy of which is
provided in response to this Production Request No.5.
Person(s)who will be able to answer questions about or sponsor the answer at any
hearing:Dale Schmick.
REQUEST FOR PRODUCTION OF DOCUMENTS NO.6:On page 9 of Exhibit D,
TerraCom states that “all 611 and 911 calls are free,and do not count against the customer’s
airtime.”Please confirm that 611 calls are calls made to the Company’s customer service center.
RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS NO.6:
TerraCom hereby confirms that 611 calls made by the customer are routed to its customer
service center.
Person(s)who will be able to answer questions about or sponsor the answer at any
hearing:Dale Schmick.
REQUEST FOR PRODUCTION OF DOCUMENTS NO.7:On page 17 of
Exhibit D,the Company states,“[t]he customer’s account is activated upon completion of an
outbound call.For purposes of enrollment in the Lifeline program,TerraCom will use the date
of this first completed outbound call from its call records as the customer’s effective start date.”
TerraCom must rely on the Lifeline customers who sign up via Internet sales or the inbound
telemarketing channels to self-initiate the activation process.Please explain how long the
service can remain inactive before the Company takes action.
RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS NO.7:
The service can remain inactive for 21 calendar days from date of delivery of the handset.
However,the phone is inactive until the customer makes the first call to TerraCom and that first
call can only go to TerraCom’s customer service department for final authentication.Thus,until
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that call is made,the service account is not claimed for reimbursement support,the only cost is
to TerraCom,and not the Lifeline program.If such a call is not made the account is deactivated.
Person(s)who will be able to answer questions about or sponsor the answer at any
hearing:Dale Schmick.
DATED this 9th day of August,2013.
Michael C.Creamer
Givens Pursley LLP
Attorneys for TerraCorn,Inc.
TERRACOM INC.’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
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CERTIFICATE OF SERVICE
I hereby certify that on this 9th day of August,2013,I served the foregoing discovery
response upon the person(s)listed below by the method indicated:
Neil Price
Deputy Attorney General
Idaho Public Utilities Commission
472 W.Washington
P.O.Box 83720
Boise,ID 83 720-0074
Attorney for the Commission Staff
LI U.S.Mail,postage prepaid
LI Email
Hand Delivery
LI Facsimile
TERRACOM INC.’S RESPONSE TO FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO TERRACOM INC.-11
Micael C.Creamer
1827619_7 t11884-21
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.TRA-T-1301
TERRACOM,INC.
RESPONSE TO COMMISSION STAFF’S
PRODUCTION REQUEST NO.2
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-1301
TerroCom Inc.’s Response to First Production Request ofthe Commission Staff
Page 1 of44
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-1301
TenaCom Inc.’s Response to First Pmduction Request ofthe Commission Staff
Page 2 of 44
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Page 13 of44
CONTENTS
INTRODUCTION 10 LIFELINF .2
NONCOMPLIANCE REPORTING PROCESS .3
CUSTOMER ELIGIBLITY 4
1.IFEI.INE POLICIES 5
Duplicate Address/One Per household 5
Duplicates 9
Wireless Non-Usage Policy 10
Wireless Device 10
LIFELINE CERTIFICATION FORMS 11
Addresses (Section 4)II
Slate Customer Identifying Numbers II
Bcneticiaiy Name (Section 5)II
VERIFICATK)N 14
1’ERRACOM SIAl’fl MATRIX 15
SAMPIR LTFEIJNE SCRIPT 16
LIFELINE COMPLIANCE TRAINING FAQS 1$
CERRACOM STATE ELIGIBLE PROGRAMS 22
ThRRACOM STATE ELIGIBLE PROGRAM DEFINIIIONS 27
TerraCain,Inc.
CONflDINTIAl.Dc)CUMENr I
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-130I
TerraCom Inc.’s Response to First Pmduction Request of the Commission Staff
Page 14 of44
INTRODUCTION TO LIFELINE
To help you understand,discuss and explain the Lifeline program,this manual has been created to serve as your
checklist to help ensure continued compliance with the rules of the Lifeline program.Employees who are
involved in TerraCom’s Lifeline business practices must USC this guide as a means to fulfill the requirement that
all eligible telecommunications carriers must implement policies and procedures for ensuring that their Lifeline
subscribers are eligible to receive Lifeline services.Employees should also be familiar with the TerraCom
employee handbook,which focuses on how all employees can contribute to compliance with applicable
communications laws.
What is the Lifeline Program?
Lifeline is a support program through the Universal Service Fund that make basic,phone service affordable for
low-income customers.This program is based on the principle in The Telecommunications Act of 1996 that
‘consumers in all regions of the nation,including low income consumers ..should have access to
telecommunications and information services.
how do customers qualify for a Lifeline credit and what is Certification?
Customers must be a participant in one of the qualifying state or federal assistance programs approved by the
state in which they reside.“Certification”means that by completing and signing a certification form and
showing proof of participation in a qualifying assistance program orhy income-based eligibility (or having that
participation verified through a state database if it is available to TerraCom)the customer is now eligible to
receive one Lifeline discount per household.
Who decides which assistance programs qualify for Lifeline?
The federal and state commissions decide which assistance programs qualif’an applicant for Lifeline.If there
are no state mandates,then the state defaults to federal requirements.Lifetine certification forms are particular
to each state.
What is verification?
Otir company is required by law to re-certify Lifeline customers each year.During this annual verification/re
certification process,customers must fill out another Lifeline certification form,and verify their continued
participation in a qualifying program or be verified via an available state database.This may also he done using
the company’s TPV Verification process.Presentation of proof is not required in the verification process.
If the customer no longer participates in a qualifying program,can they continue receiving Lifeline
credit?
No.As stated on the certification form,it is their responsibility to inform the company if they no longer qualify
for a Lifeline credit.
TerrsCom,Inc.
CONFIDENTIAL HOC :tJMENT 2
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TermCom Inc.’s Response to First Production Request of the Commission Staff
Page 15 of44
NONCOMPLIANCE REPORTING PROCESS
As an employee of TerraCorn,you share the responsibility to ensure that our company adheres to the Lifeline
rules,process and procedures contained within this Operations Manual.If you have any questions about this
material or Lifeline policies and procedures please ask your supervisor for clarification.In addition,the
TerraCom Audit and Compliance Departments are always available for questions and clarifications.
Any activity that threatens the integrity of these practices and thus TerraCom’s business practices and the
Lifeline Program cannot exist.It is your obligation to work to prevent any such occurrence.TerraCom’s
Compliance Officer is Dale Scbmick.If your questions or concerns are not being addressed you are required to
contact Mr.Schmick to discuss the situation.
If you discover a sirnation that is clearly one of noncompliance with Lifeline rules and practices,you are
required to immediately report the incident to Mr.Schmick.Please contact him at x7571 or [phone] and
be prepared to report the details.
Remember that at all times the company maintains an open door policy and should you ever have any concerns
regarding Lifeline you are always welcome to bring them to any member of management,senior management
or executive management.
TerrsCom,Inc.
CONFIDFZNTIAI.DOCUMEN’F 3
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-130l
TeimCom Inc.’s Response to First Production Request of the Commission Staff
Page 16 of44
CUSTOMER ELIGIBILITY
To help you understand,discuss and explain the Lifeline application with the applicant,we have put together a
checklist of items which can be used to help determine a ctistomcr’s eligibility as outlined below.Employees
who sign up new applicants must review this checklist with each applicant and answer any questions they may
have.
Applicants must certify and acknowledge that:
Li Lifeline discounts are strictly limited to one per household.No one at their household can be receiving a
Lifeline-supported service from any other provider.If someone is,then they must cancel that service before
starting service with our company.
Li They are the head of the household,not listed as a dependent on another person’s tax return (unless over the
age of 60)and the address listed is their primary residence.
Li They either participate in a qualifying low-income program listed on the certification form or meet the
income qualification to establish eligibility for Lifeline.Ifrequired to do so,they must provide accurate and
current documentation of eligibility.
Li They must inform us within 30 days ifthey no longer participate in a qualifying program,their annual
household income exceeds the Federal Poverty Guidelines,they discover that someone in the household is
receiving more than one Lifeline supported service or for any other reason they no longer satisfy the criteria
for receiving Lifeline support.
Li They understand that if they move,a new address must be provided to us within 30 days of the move.
Li They understand that Lifeline service is a non-transferable benefit,and that the service may not be
transferred to anyone else,including another eligible low-income consumer.
Li They may be required to re-certify their continued eligibility for Lifeline at any time,and that failure to do
so will result in the termination of the Lifeline benefits.
Li They consent to the use of name,telephone number,and address to be given to the Universal Service
Administrative Company (USAC)(the administrator of the program)for the purpose of verifying that they
do not receive more than one Lifeline benefit and that refusal to grant this permission will mean they are not
eligible for Lifeline service.They also must allow us to access any records required to verify and confirm
their Lifeline eligibility.
Li There can be significant penalties for anyone who violates these rules including removal from the program,
potential prosecution,being permanently barred from the Lifeline program,fines andlor imprisonment.
Remember,as a company representative,you are thefirst line ofresponsibility to ensure that the customer Lc an
eligible participant and that applications areJilted in accurately.
lerruCom,Inc.
CONFII)ENTIAI DOCUMENT 4
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-l3Ol
TerraCom Inc.’s Response to First Production Request ofthe Commission Staff
Page 17 of44
LIFELINE POLICIES
Certification
•An applicant for TerraCom Lifeline servicc must first pass an electronic identity check via the
Lcxis Ncxis database.
•A Lifeline applicant is not allowed to self-certify that they are a participant in a qualifying
program.They must show documented proof
•If thcir address is in a state where we are able to verify their participation through a state
database,then they do not need to provide proof.In the company state matrix that follows in this
guide,you will be able to determine states with databases by referring to the “Sec Notes”
indicator in the “Certification”column.The only exception to this is Nevada and Maryland,
where tite customer cciii subsequently provide proof f we arc unatile to verify them by initially
consulting the statepi’ovitied list.
a A complete,signed certification form must be received from the applicant in order to be
considered for qualification.
Duplicate Address/One per household
If a Litline applicant is identified as having the same address as au existing customer by checking
company records or via a database,they will then have to verify that they are part of a separate
household at that address.
Again,the rules of the Lifeline program only allow one Lifeline service per household.For example,
this means the customer can have either a Lifeline discount on one wireless or one wirelinc service,but
not both.
The definition of”househotcP’is “any individual or group of individuals who are living together at the
same address as one economic unit.”
An economic unit consists of adults connibuting to and sharing in the income and expenses of a
household.Below are a few examples ofthe one-per-household rule:
One economic unit examples:
1.Alice and Peter have been dating for lIve years and just moved in together.Because they
will share their living expenses,including rent,utilities,and food,they are a single household
and entitled to only one Lifeline service.
2.Jane lives with her mother and father in the home where she grew up.Jane works part-
time but she does not pay rent.Since Jane is dependent upon her parents for support,they arc a
single household and entitled to only one Lifeline service
TerriCom,Inc.
CONFIDENIIAL DOCUMENT 5
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-130l
TerraCom Inc.’s Response to First Production Request of the Commission Staff
Page 18 of44
More titan one economic unit examples:
I John rents a room in a group house.John and his roommates pay rent separately.Since
they do not share other expenses with each oilier John is a separate household at this common
address and thus entitled to his own Lifeline service.
2.Tony and his daughter live with Tony’s Aunt Pam.Although Tony helps out around the
house,he pays rent and utilities to Aunt Pam every month and since he is not sharing expenses is
thus entitled to his own Lifeline service.
Important rules to remember:
•“Adults”are persons eighteen years of age or older.
•Children living with their parents or legal guardians are considered to be part of their
patent or guardian’s household.
•A household may include related and unrelated persons.
•If a low-income consumer has no/minimal income,but lives with someone else who
provides financial support to him/her,the low-income consumer should be considered to
be part ofthat person’s household.
In the case where multiple households may be using the same address (i.e.,a shelter where people live)you arc
responsible for infonning the customer of these rules.In most cases there will be a unit number,bed number or
apartment number.These must be included in the address.
Upon receiving an application for Lifeline support,our company will be checking via TerraCom’s OSS system
and,where they are available,external databases to determine whether an individual at the applicant’s
residential address is currently receiving Lifeline-supported service,If nobody at the residential address is
currently receiving Lifeline supported service,we can initiate Lifeline service (after determining that the
household is otherwise eligible to receive Lifeline and obtaining all required certifications from the household).
If we determine that an individual at the applicant’s residential address is currently receiving Lifeline supported
service,or it is determined that multiple households do reside at an address,including in Tribal communities
and group living facilities,we must take an additional step to ensure that the applicant and the current
subscriber are part of different households.l’o enable applicants to make this demonstration,we must require
applicants to complete and submit to the company a Lifeline household Worksheet (below)and this form
becomes a part of their account record.
Program applicants must affirmatively certify that other Lifeline recipients residing at that address are part of a
separate household,(i.e.,a sel)arate economic unit that does not share income and expenses).
‘rcrrncon,Inc.
CONFIDENTIAL DOCUMENT 6
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-l3Ol
TeimCom tue’s Response to first Pmduction Request of the Commission Staff
Page 19 of44
Relection of an applicant’s request for Lifeline or de-enroilment will occur under this section as a result
of:
•any subscriber who indicates that he or she is receiving more than one Lifeline supported service
per household
•customer failure to complete the Lifeline Household Worksheet if it is determine an address may
he receiving more than one LiIblinc supported service
•a customer neglecting to complete the required one per household certification on his or her
certification or annual verification form
•dc-enrollment for this must take place within 5 business days.
IcrraCom,Inc.
CONFIDENTIAl.I)OCLJMENT 7
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TerraCom Inc.’s Response to first Pmduction Request of the Commission Staff
Page 20 of44
IerrCom
Lifeline Household Worksheet
Name
Address
Telephone_Number
Lifeline iso government program that provides a monthly discount on home or mobile telephoneserviceS.Only ONE Lifeline discount is allowed per household
Members ofa household are not permitted to receivetifnlinn service from multiple telephone companies.
Your household Is everyone who livestogether at your address as one economic unit (including children and people who are not related toyou).
The adults you live with ore pert al yvur economicunit if they contribute to and share in the income and expenses of the household,An adult is any person 18 years
of age or older or an emancipated minor(a person under age 18 who is legallyconsidered to be on adult).Hoatohold expenses include food,health care expenses
(such us medical bills)and the cost of renting or paving a mortgageon your place of residence (a house orapartment,forexample)andutilities (including water,heal
and electricity).income includes salary,public assistance benefits,social security payments,pensions,unemploynwnt compensation,veteran’s benefita,
inheritances,alimony,child support payments,worker’s compensation benefits,gifts,and lotterywinnings.
Spouses anddomestic partners are considered lobe part of the same household.Children under the age of 18 living with their parents or guardians are considered
to be part oftire same household as their parents orguardians.if an adult has no income,or minimal income,and lives with someone who providesfinancial support
to that adult,both people are considered part of the name household,
You have been asked to complete this Worksheet becauae someone else currently receives a t)fellne.aupporeed serviceatyouraddress.This
other person may or may not be a part of yourhousehold.Answer the questions below to determine whether there is more than one household
residing at youraddress,
1.Does your spouse or domestIc partner (that is,someoneyou are marriedto or in a relationship witis)already receives LIfeline-discounted
phone?(check nail you do nor have a apouse or partner)_YES _NO
iv If you checked YES,you may not sign up for Lifeline beceuse someone in your household already receives LifelIne.Only ONE Lifeline
discount is allowed per household.
iv If you checked NO,please answer questIon 112.
2.Other than a spouse or partner,do other adults (people over the age of 18 or emancipated minors)live with you at your address?
A.A parent __YES ,,,.,,.,,,,NO 0.An adult roommate .._......YES ................NO
B.An adult son or daughter _YES ..........NO E.Other,._YES _NO
C.Another adult relative (suds as a _YES NO
sibling,aunt cousin,grandparent,
grandchild,etc.)
iv Ifyou checked NO foreach statement above,you do not need to answer theremaining questions.Please initial line B,below,and sign
and date tire worksheet,
iv Ifyou checked YES,please answer question #3.
3,Do you share living expenses (bills,food,etc.)and thereincome (either your income,the other person’s income or both Incomes
together)with at least oneof theadults listed above in question 112?.................YES .................NO
iv ifyou checked NO,then your address includes more than one household,Please initial lines A and B below.and sign and date the
worksheet,
iv ifyou checked YES,then your address includes only one household.You may not sign up for Lifeline because someone in your household
already receives Lifeline.
CERTIFICATION
Please Initial the certifications belowandsign anddate this worksheet.Submit this worksheet to
____________________________(insert
company
L.ragencyname)along with your Lifeline application.
A._lcertify that I live at on address occupiedby multiplehouseholds.
B._lunderstand that violation ofthe one-per-household requkement is against the FederalCommunication Commission’s rules and
TerrCom,Wiy resultin melosing my Lifeline benefits,and potentially,prosecution by the United States government.
ONFIDENTIAI.Dt)CtiMINT 8
Signature____________________________________________________Date________________________
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TetmCom Inc.’s Response to First Production Request of the Commission Staff
Page2)of44
Duplicates
Our company is tasked with the rcsponsibility of not allowing customers to have mOre thami one 1)hone with
Lifeline service and ensuring we adhere to the processes that prevent that from taking place.The following tools
arc available to you,as a company representative,to allow you fulfill this duty.
The following is clearly indicated on the company certification and annual veritication fonn and
via the electronic application.This should be verbally reviewed with every applicant.
Lifelitte is a federal governmetit beiteti program that offers a discount from your monthly phone
service.Lifeline service is available for only one line per household;a household is defined as any
individual or group of individuals who live together at the same address and share income and
expenses.Households are not permitted to receive benefits from multiple providers aiid you jnay
not receive multiple Lifeline discounts.You may apply your Lifeline discount to either one
landline or one wireless iitnnber,but you cannot have the discount on both.
•Section 7 of the company certification and annual verification forms require the customer to
initial that they “...acknowlcdgc that,to the best of my knowledge,no one at my household is
receiving a Lifeline-supported service from any other provider.”Anyone who accepts
applications is reciuired to verbally review this with the customer.If the customer already has
Lifeline service from another provider they must disconnect it or you must reject their
application.
•Our internal customer support systems will flag any entry that it determines is a duplicate entry.
This will help prevent you from creating a second account at the same address.Should yoti have
an applicant that does not believe they are applying for duplicate service,see your supervisor for
the process to handle this for your department.
•If a new applicant is signing up in a state with a state database,we will also use that to verify the
applicant’s participation in a low-income program and,should the database have this capability,
verify we arc not providing service to duplicate addresses.
TcrraCom,Inc.
CC)NIIl)ENIIAL DOCUMENT 9
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-t3Ol
TemmCom Inc.’s Response to First Production Request of the Commission Staff
Page 22 of44
Wireless Non-Usage Policy
In all service areas,a customer will no longer be eligible for a Lifeline discount if they do not use their
Lifeline service for 60 calendar days.
Usage can bc:
•making a monthly payment
•purchasing additional minutes
•completing an outbound call
•answering a call from anyone other than us or one of our representatives
•affirmatively responding to direct contact (text included)from TcrraCotn confirming he
or she would like to continue service.
Once an account has been moved to a non-usage status,the subscriber has up to 30 calendar days to re
enroll by contacting the company.If a customer does not re-enroll or call a customer service
representative within 30 calendar days of the dc-enrollment,the phone service will be deactivated (any
airtime will be lost).Note:A subscriber must recertify and participation must again be verified to re
enroll in the wireless Lifeline program.
Wireless Device
Only upon successful completion of the certification process is the customer allowed to choose a service
plan and select a phone.In the case of a customer signing up for service over the phone,or at any point
of distribution where phones are not immediately distributed,TerraCom does not ship a phone to a
customer until it has verified the customer’s eligibility.The customer’s account is activated upon
completion of an outbound call.For purposes of “enrollment”in the Lifeline program,TerraCom uses
the date of this first completed outbound call from its call records as the customer’s effective start date.
Up until that time all phones regardless of distribution method are only capable of calling TerraCom
customer service.
1rraCoin,Inc.
CONFII)F.NTIAI,DOCt3MCNI’10
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TermCom Inc.’s Response to First Pmduction Request of the Commission Staff
Page 23 of 44
LIFELINE CERTLFICATION FORMS
Addrcsscs (Section 4 of the company certification form)
All addresses are verified via Melissa Data to ensure that all addresses are properly formatted and to
prevent fraud.Our customer management systems will not allow addresses that do not comply.Please
see your supcri’isorfht the proper procedure to handle shelter addresses.
State Customer Identifying Numbers
In all the areas we provide service at least the last four (4)digits of the Social Security Number and the
Date of Birth (DOS)are required.Some states will require a full social security number and these states
are indicated as such on the company matrix that follow in this document.If the customer lives on 1’dbal
Lands and does not have a Social Security Number,they should instead provide their Tribal ID Number.
Some states,for example those where we certify and verify a customer through a customer database,
may require another customer identifying number (i.e.,DSHS number).These are listed in each state’s
particular form and must be obtained.Please refer to the matrix below for the correct way to handle a
social security number and/or state specific customer identifying number in a particular area.
Beneficiary Name (Section 5 of the company certification form)
An applicant may use the benefits of a dependent to quaIi’for the Lifeline program should the
dependent be included as part of the household.Our form has a field for name of the Qualifying
Beneficiary and should be completed if this situation applies.
Below is an example of a paper company certification form.This form has also been recreated on the company
sign up portals to allow for electronic certification and application for Lifeline service while remaining within
certification requirements.
Applications must be filled out completely or the customer will not be able to receive Lifeline service,it’s as
simple as that.The information we collect on these fonns,such as the last 4 digits of a social security number
and Date of Birth,will also be used to establish and verit’the customer in the forthcoming National Lifeline
Accountability Database so collecting it correctly up front will enable us to continue to provide Lifeline
discounts in the future.(Days indicated on the form are in calendar days).Again,the customer certification
forms on the online portal and website will have the same sections and required certifications as in this
example.
‘rerrcm,Inc.
CONIIDENHAL DOCUMENT 11
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-t301
TetmCom Inc.’s Response to first Production Request of the Commission Staff
Page 24 of 44
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Icrr,Com,Inc.
CONY IDENIJAL IiOCUMENT 12
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-1301
TenaCom Inc.’s Response to first Production Request ofthe Commission Staff
Page 25 of44
.n:’tCIICf5TerraEom LIFELINE CERTiFiCATION FORM
STATE OF OKLAHOMA
SECTION 1—RULES
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IrrraCom,Inc.
1’FII)ltIIi.POUI’MENl 13
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TermCom Inc.’s Response to First Pwduction Request ofthe Commission Staff
Page 26 of44
VERIFICATION
•Verification is to be completed annually for all customers.
•Verification will be completed either via state databases or by contacting the customer and
having them complete a new certification form via our website or by calling and recording voice
verification.
•The customer does not have to provide a copy ofproof when annually verifying.
A customer will have 30 days to respond to an tmntial verification notification.If the company rcccivcd no
response from the customer that customer they will be dc-enrolled from the Lifeline program in 5 business days.
The matrix below is to he used as a quick reference guidefor the applietthle ru/ac by state:
‘ferrCon Inc.
CONFIDENTIAl.DOCIJMENY 14
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-130l
TenaCom Inc.’s Response to first Production Request of the Commission Staff
Page 27 of44
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15
SAMPLE LIFELINE SCRIPT
It is important that we explain to the customer up front,and in a manner in which he or she can
understand,the different aspects of the Lifeline program.
Please rcfer to (heJollowiug to help guide you through this procesx cindplease give the cus1oner
a sample copy ofthe form to read.
Hello,my name is.TerraCom has been authorized by the state of [YOUR
STATE]and the FCC to provide free or discounted wireless service to applicants
that qualify for the government assisted Lifeline program.Because of this
program TerraCom can provide a free cell phone along with 250 free minutes that
automatically renew every month.Are you interested in learning if you qualify for
this discounted phone program?
The first requirement is that you or someone in your household has to be
participating in a government assistance program.here is a list of the approved
programs for our state:
[SHOW CUSTOMER THE LIST ON THE CERTIFICATION FORM]
Are you receiving benefits from one of those services?(Make sure you are
speaking to person with the assistance).If so,in order to sign up for Lifeline
service today,I will need to see documented proof of your participation and a
government issued ID.Do you have that with you?
The second requirement is that no one else from your household can be taking
advantage of the Lifeline discount for a cell or home phone,while you are,either
now or in the future.It is strict/v one service per household.for example,if you
have Lifeline home phone service now either with our company or another
company and you want the cell phone,you will have to cancel the home phone
service.
How would you like you name to appear on the account?It has to match the name
and address you use to receive your government assistance.
Please tell me your address.Thank you.I need to let you know that if you move,a
new address must be provided to us within 30 days of your move.
ferracom,Inc.
CONFIDENTIAL DOCUMENT 16
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TeimCom Inc.’s Response to First Pmdoction Request ofthe Commission Staff
Page 29 of44
The next thing we need is to have you complete Sections 4-7 of this certification
fotm.It is very important that this be filled in completely and accurately so let me
help you through this.
[ASSIST IN TilE COLLEC1’ION Of JNFORMATIONJ
It is vciy important that you read the next section of the form,Section 8,closely
and in its entirety.It requires your initials in several places so let’s go thtough this
together make sure you understand what you are agreeing to and I can answer any
questions you might have,
[ASSIST THE CUSTOMER IN READING AND INTERPERTATION.POIN’f
OUT THE ITEMS REGARDING REQUIRED RE-CERTIFICATION,THE
NON-TRANFERABILITY OF BENEFITS AND THAT PERSONAL
INFORMATION WILL GIVEN TO USAC.]
Are there any final questions?
Please go ahead and sign and date the form.
Thank you.
TerruCom,Inc.
CONFIDENTIAL DOCUMENT 17
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TerraCom Inc.’s Response to First Pwduction Request ofthe Commission Staff
Page 30 of44
LIFELINE COMPLIANCE TRAINING FAQS
Qt]ESTION:for Texas,what is the process for signing applicants up for Lifeline,collecting
customer eligibility documentation upfront or after theyre declined?
ANSWER:In Texas,approval is via the Solix online portal for Medicaid,ChIP,SSI and TANF (all
others require proof documentation).If a customer is dcclined attempting to certify under one ofthese
programs,then they need to contact Solix at:
Calling from Inside Texas:866-459-8387
Calling from Outsidc Texas:806-741-8101
2.QUESrION:What happens to eligibility docutnentation that customers mail in?Is that shredded or
kept?
ANSWER:The document(s)are scanned and uploaded to Veare for verification mid ultimately
destroyed.My physical copy is destroyed immediately after processing.Originals are mailed back
to the customer,however we strongly discourage customer from sending originals for which we
cannot be responsible.
3.QUESTION:Arc applicants who are not U.S.citizens eligible for Lifeline if they have a work visa
[tax id or ING numberJ (mid are eligible under Lifeline rules)?If so,what identification number do
eligible customers with visas give?(There is no space for that on the current Lifeline Certification
Form.)SSN’s of children acceptable?
ANSWER:A subscriber should not use the social security number of a child to apply for service.
We should not place any substitute ID number (i.e.tax ID,ING number,DHS number)in the social
security field on the Certification Form.The subscriber is required to provide a social security
number.Invalid personal information will result in a failed identity check and the customer will not
he allowed to apply for Lifeline.
Social Security Number and identification are two separate issues.Most identification will not show
their SSN and we cannot discriminate nor assume someone is not a US Citizen.The requirement for
identification cannot be their social security card,as that document does not have a photo.
4.QUESTION:How does an Oklahoma customer show proof ofreceiving the Oklahoma Sales Tax
Relief Program?
ANSWER:The customer can show current tax returns.
5.QUESTION:If a customer moves,does that customer need to fill out a new Lifeline form?
ANSWER:No.However,the customer should notify us within 30 days with updated address
infonnation.
TerraCom,Inc.
CONFIDENTIAL DOCUMENT 18
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-130l
TerraCom Inc.’s Response to First Production Request of the Commission Staff
Page 31 of44
6.QUESTION:In Oklahoma,is there an activation Fee?
ANSVER:There is no activation fee for wireless subscribers in Oklahoma.‘l’hcre is a 530 activation
fee for both Lifeline and non-Lifeline wireline (home phone)customers.
7,QUESTION:Ifs customer goes through third party verification f’or certification,does the customer
receive the service immediately or must they wait until the company has verified eligibility
documentation?
ANSWER:Third party verification does not,by itself,make a customer eligible for I,ileline service.
Any customer who goes through the third party verification must subsequently then provide prootof
program participation.
8.QtJESTION —Regarding verification (re-certification),will customers be required to send eligibility
documentation even it they go through third-party-verification?
ANSWER:No.
9.QtJESTION:If a customer verifies eligibility for Lifeline but she/he verifies claiming assistance on a
different program than what was claimed the year before,what is the employee to do?
ANSWER:A customer who verifies only needs to indicate on the Lifeline Certification form which
program through which they are receiving assistance.It this program is different from the one they
originally used to certify,we do not need to collect proof.
10.QUESTION:Ifs Lifeline applicant provides an address that matches an address already in our
system,what does the employee do with the active Lifeline account;disconnect or suspend it?
ANSWER:No.Please have the applicant complete and turn in the Lifeline Household Worksheet.
Ifthe applicant determines in the process of completing the f’om that they are not a separate
economic unit,they cannot enroll in our Lifeline program.
11.QUESTION:What kind of identification do employees need to see?Is an expired,govcmment
issued ID acceptable or must customers provide a valid government-issued identification?
ANSWER:An unexpired ID is preferred,but any government issued picture ID is acceptable so we
can identif’that they are the applicant.
12.QUESTION:Released inmates typically have no identification when they exit prison.Cuirently,
these potential customers have only a letter from the Warden as ID.Is this acceptable identification,
as long as it has the state seal and is not a copy?
ANSWER:Yes.
TerraCom,Inc.
CONFIDENTIAL DOCUMENI’19
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-l301
TermCom Inc.’s Response to First Production Request ofthe Commission Staff
Page 32 of 44
13.QUESTION:If a customer fills the application form out but does not fill in the complete address
(forgets the apartment number or part of the apartment number),is it acceptable to contact the
customer over the phone to get the correct infonnation as long as it is noted in the custOmer’s account
or must the customer fill out a new application?
ANSWER:The correct address should appear on the copy of the government-issued ID.This
infnnnation can be added to the certification form and account.It is certainly acceptable to contact the
customer to clear up any questions regarding the information provided as accuracy is paramount.
14.QUESTION:What about proofof address?
ANSWER:It is important that the company capture accurate address infonnation and why we
perform electronic address verification using Melissa Data during the creation ofan account.
Therefore,employees should make all attempts to collect the correct and full address from the
customer upfront by carefully examining all presented documentation and talking with the customer
to clear up atiy discrepancies.
15.QUESTION:A customer provided an IRS document that stated his address was the car he was living
in.Is this an acceptable fonn of proof and address?
ANSWER:If such a document is presented,please forward it to Compliance for review 5011 can be
determined if this is acceptable.
16.QUESTION:A customer was adding minutes to a phone that wasn’t in their name and the re
certification reminder window popped up.What is the process in this situation?
ANSWER:Lifeline is a non-transferable benefit and may not be “handed off”to anyone.Lifeline
service,and thus the handset,may only he used by the qualifier.Please inform the customer ofthis
and ask if he or site would like to apply for their own Litèline service.Ifa positive response is not
forthcoming,please visit with your supervisor to initiate a change of this account to non-Lifeline
service.If they do apply and are eligible they can use that phone and number.The phone and
number is transferable,Lifeline is not.
18.QUESTION:We get a number of complaints in Oklahoma about other carriers breaking the rules
and/or providing poor service to their customers.Who can be contacted in these situations?
ANSWER:In Oklahoma,a customer can register a complaint regarding these carriers with the
Commission using the following contact infbnnation.
Oklahoma Corporation Commission
c/o Customer Assistance
P0 Box 5200
Oklahoma City,OK 73152
[phone]
In addition,please provide detailed information and examples to our Compliance Department.
TerraCom,Inc.
CONFB)ENTIAL DOCUMENI’20
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-130l
TermaCom Inc.’s Response to first Production Request of the Commission Staff
Page 33 of44
19.QUESTION —If customers are getting Social Security Income and their income falls under the 135%
Federal Poverty Guidelines,are they eligible for Lifeline supported service?
ANSWER:Yes.Income documentation provides proof ofeligibility like a form ofprogram
eligibility documentation.
20.QUESTION:What is the process for someone who has power of attorney (payee)for someone cisc
who is the applicant/program qualifier?
ANSWER:The person holding power of attorney should present documentation that verifies they
have been vested with this responsibility.The appropriate documented proof of program qualification
in the subscriber’s name can he presented by the person holding power of attorney and he or she can
assist the applicant in completing the Lifeline Certification with the subscriber’s personal
infonnation.the subscriber should be time one who signs the Certification.
If the customer is eligible AND is over 1 8 years old OR aim emancipated minor,s/he should be the
subscriber because we need to be collecting that person’s information (DOB,SSN,etc.)for the
National Lifeline Accountability Database.The power ofattorney can be an authorized user on that
account but shouldn’t be the subscriber.
21.QUESTION:Does a customer receiving Medicaid support for Medicare Part B qualify them for
Lifeline?
ANSWER:Yes.The FCC has clarified participants in Medicaid,a qualifying means-tested
assistance program,are eligible for Lifeline even if their Medicaid participation consists solely of
assistance in payment of Medicare Part B premiums.However,documentation that states that the
applicant is on Medicare Part B is not enough to qualify them for Lifeline.
If they are on Medicare Part B and getting help from Medicaid we can accept:
•A copy of a state document that shows that the person has Medicaid
•A printout from a state electronic enrollment file or from the state’s Medicaid system that
shows the person has Medicaid
•Any other document from the state that shows he/she has Medicaid
•A bill from an institution (like a nursing home)or a copy ofa state document showing
Medicaid payment
22.QUESI’JON:Does the name on the ID and the name on the proof have to match?
ANSWER:The new rules are such that Lifeline service is based on a household.The applicant is the
head of household,but not necessarily the holder ofthe benefits.Where the applicant and benefit
holder arc the same,proof will be in the same name.Where the benefit holder is not the applicant the
beneficiary information must be provided and the proof must match the beneficiary.
Example I:Ms.Smith lives with her family and receives SNAP benefits.She is the applicant and the
benefits are in her name.The beneficiary line on the Certification form will remain blank.
Example 2:Ms.Smith lives with her family and receives SNAP benefits but her daughter is a
beneficiary ofthe National free Lunch Program.Ms.Smith will be the applicant and her daughter is
lerraCom,Inc.
CONFIDENTIAL DOCUMENT 21
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-130l
TerraCom Inc.’s Response to First Pruduction Request of the Commission Staff
Page 34 of44
the beneficiary.Proof is in Ms.Smith’s name and her daughter is listed on the beneficiary line on
the Certification form.
TerraCom,Inc.
CONFIDENTIAL DOCUMENT 21
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-1301
TerraCom Inc.’s Response to First Production Request of the Commission Staff
Page 35 of44
TERRACOM STATE ELIGIBLE PROGRAMS
The following appendices contain current lists of eligible programs by state with some
corresponding examples followed by definitions.Please ensure that the documents presented to
yoti are ctirrcnt.Expired documentation or proof documentation that does not bear the correct
customer name will resull in the applicant being denied service.
It is also important to remember that a Bureati of lndian Affairs CDIB Card isn’t proof of low
income assistance but only proof of Indian heritage.It does not qualify anyone for Lifeline.
Please refer to tile separate and corresponding state proofdocumentation joI aid to assistyou in
identifying acceptabkforms ofproofehgththtyfor the listed programs.
TerraCom,Inc.
CONFIDENTIAL DOCUMENT 22
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-1301
TerraCom Inc.’s Response to first Production Request ofthe Commission Staff
Page 36 of44
ARKANSAS
Federal Public Housing Assistance
Medicaid
Low Income Home Energy Assistance Program (LIHEAI’)
Natiotial School Lunch Program
Supplemental Nutrition Assistance Program (SNAP)
Supplemental Security Income
Temporary Assistance for Needy Families
Transitional Employment Assistance (TEA)
Income Based -135%of the federal Poverty Guidelines
ARIZoNA
FederaJ Public Housing Assistance
Medicaid
Low Income Home Energy Assistance Program (LIIIEAP)
National School Lunch Program
Siipplemeiital Nutrition Assistance Program (SNAP)
Supplemental Security Income
Temporary Assistance for Needy Families
CHIP (State Child health Insurance Ptan/KIDCARE)
AHCCCS (Arizona health Care Cost Containment System)
Income Based -150%of the Federal Poverty Guidelines
COLORADO
Low Income Energy Assistance Program (U HEAP)
Supplemental Security Income (SSI)
Stipplemnemital Nutrition Assistance Program (SNAP)(f/k/a Food Stamps)
Medicaid
Federal Public Housing Assistance
Temporary Assistance to families (TANF)
National School Lunch Program’s Free Lunch Program
Income Based -135%of the Federal Poverty Guidelines
INDIANA
Low Income Energy Assistance Program (LIHEAP)
Supplemental Security Income (SSi)
Supplemental Ntitrition Assistance Program (SNAP)(f/k/a Food Stamps)
Medicaid
Federal Public housing Assistance
Temporary Assistance to Families (TANF)
National School Lunch Program’s Free Lunch Program
Income Based -135%of the Federal Poverty Giiiclelhies
TerraCom,Inc.
CONFIDENTIAL I)OCUMENT
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-l301
TerraCom Inc.’s Response to First Pmduction Request of the Commission Staff
Page 37 of44
IOWA
Low Income Home Energy Assistance Program (LIIIEAP)
Medicaid
National School Lunch Program’s Free Lumich Program
Supplemental Nutrition Assistance Program (SNAP)
Temporary Assistance for Needy Families
federal Public Housing Assistance
Supplemental Security Income
Income Based -135%of the Federal Poverty Guidelines
LOUISIANA
Medicaid
Supplemental Nutrition Assistance Program (SNAP)
Supplemental Security Income (SSI)
Temporary Assistance for Families (TANF)
Low Income Home Energy Assistance Program (LJIIEAP)
National School Lunch Program’s Free Lunch Program
Federal Public Housing Assistance
Income Based -135%of the Federal Poverty Guidelines
MARYLAND
Low Imicome Energy Assistance Program (LIHEAP)
Smippleniemital Security Income
Medicaid
Temporary Assistance for Needy Families (TANF)
Supplemental Nutrition Assistance Program (SNAP)
National School Lunch Program
Federal Public Housing Assistance
Maryland Energy Assistance Program (MEAl’)
Temporary Disability Program (TDAP)
PubJie Assistance to Adults (?AA)
Electrical Universal Service Program (EUSP)
Income Based -135%of the Federal Poverty Guidelines
MINNESOTA
Federal Public Housing Assistance
Medicaid
Low Income home Etmergy Assistance Program (LIII EAP)
National School Lunch Program
Supplemental Nutrition Assistance Program (SNAP)
Supplemental Security Income
Temporary Assistance for Needy Families
Minnesota Family Investment Program
Income Based -135%of time Federal Poverty Guidelines
TerraCom,Inc.
CONFIDENTIAL DOCUMENT 20
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-1301
TerraCom hic.’s Response to First Pmduction Request of the Commission Staff
Page 38 of44
NEBRASKA
Medicaid
Low-Income Home Energy Assistance (L1HEAP)
Supplemental Nutrition Assistaitce Program (SNAP)
Temporary Assistance for Needy Families (TANF)
Kids Connection (SAM,MAC or EMAC)
Federal Ptiblic Housing
National School Lunch Program Free Lunch Program
Supplemental Security Income (SSI)
Ijicome Based -135%of the Federal Poverty Guidelines
NEVADA
Supplemental Security income
Medicaid
Temporary Assistance for Needy Families (TANF)
Supplemental Nutrition Assistance Program (SNAP)
National School Lunch Program
Federal Public Housing Assistance
Low Income Home Energy Assistance Program (LIHEAP)
Income Based -150%of the Federal Poverty Guidcliiics
OKLAHOMA
Supplemental Security Income (SSi)
Food Distribution Program on Indian Reservations
Vocational Rehabilitation (including aid to the hearing impaired)
Tribal Administered Teniporary Assistance for Needy Families
Temporary Assistance for Needy Families
Oklahoma Sales Tax Relief
National School Lunch Program’s Free Lunch Program
Medicaid/Sooner Care
Low Income Home Energy Assistance Program
Head Start (must meet income qualifying standard)
Supplemental Nutrition Assistaiice Program (SNAP)
Federal Public Housing Assistajice
Bureau of Indian Affairs General Assistance
Income Based -135%of the Federal Poverty Guidelines
NOTE:No,i-TribaI areas in the State ofOklahoma include the counties of:Alfalfa,Harper,Jackson,Texas,Bcckhan
County,and South ofthe North Fork River and the western halfof Ellis County,Beaver,Cimarron,Greer,and Harmi
TEXAS
Supplemental Security Income (551)
Supplemental Nutrition Assistance Program (SNAP)
Low Income Home Energy Assistance Program (LIHEAP)
Medicaid
federal Public Housing Assistance
Health Benefit Coverage under Child Health Plait (ChIP)
Income Based -150%of the Federal Poverty Guidelines
Temporary Assistance for Needy Families
National School Lunch Program’s Free Lunch Program
TcrraCom,Inc.
CONFII)ENTIAL DOCUMENI’
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TemmCom Inc.’s Response to First Production Request ofthe Commission Staff
Page 39 of44
US VIRGIN ISLANDS
Aid to the Disabled
Aid to the Blind
General Assistance
Aid to the Old Aged
Low-Income Home Energy Assistance Program (LIHEAP)
Temporary Assistance for Needy Families (TANF)
Federal Public Housing Assistance
Supplemental Nutrition Assistance Program (SNAP)(f/k/a Food Stamps)
Medicaid
Income Based -135%of the Federal Poverty Guidelines
WEST VIRGINIA
Temporary Assistance for Needy Families
Supplemental Security Income
Supplemental Nutrition Assistance Program (SNAP)
School Clothing Allowance
Medicaid
Low-Income Home Etiergy Assistance Program tLIIIEAP)
federal Public Housing Assistance
National School Lunch Program’s Free Lunch Program
Income Based -135%of the Federal Poverty Guidelines
WISCONSIN
Federal Public Housing Assistance
Temporary Assistance for Needy Families
National School Lunch Program’s Free Lunch Program
Ilomestead Tax Credit
Badger Care
Supplemental Security Income (SSI)
Medicaid
Supplemental Nutrition Assistance Program (SNAP)
Low Income Home Energy Assistance Program (LIHEAP)
Wisconsin Works
Income Based -135%of the federal Poverty Guidelines
TerraCom,Inc.
CONFIDENTIAL DOCUMENT
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TermCom Inc.’s Response to First Pmduction Request ofthe Commission Staff
Page 40 of44
TERRACOM S’I’ATE ELIGIBLE PROGRAM DEFINITIONS
Temporary Assistaitce for Needy Families (TANF)is a block grant created by the Personal
Responsibility and Work Opportunity Reconciliation Act of 1996.as part of a tëderal effort to “end
welfare as we know it.”The ‘IANF block grant replaced the Aid to Families with Dependent Children
(AFDC)program,which had provided cash welfare to poor families with children since 1935.
lAid to Families with Dependent Children (AfDC)was the name of a federal assistance program in etfcct
from 1935 to I 997,[l J which was administered by the United States Department of Health and Human
Services.This program provided financial assistance to children whose families had low or no income.]
Medicaid is a federally-funded,state-ran program that provides medical assistance for individuals and
families with limited incomes and resources.It pays for your health care costs,including doctor’s visits
and eye care.
Supplemental Nutrition Assistance Program —This program provides support that enables recipients to
purchase foodstuffs with support funds.The 2008 farm bill (HR.2419,the Pond,Conservation,and
lnergy Act 01200$)was enacted May 22,2008 through an override of the President’s veto.The new law
increased the coimnitment to Federal food assistance programs by more than $10 billion over the next 10
years.In efforts to fight stigma,the law changed the name of the Federal program to the Supplemental
Nutrition Assistance Program or SNAP as of Oct.1,2008,and changed the name of the Food Stamp Act
of 1977 to the food and Nutrition Act of 2008.States maintained flexibility to name the program on their
own but were encouraged to change the name to SNAP or another alternate name.
The Sales Tax Relief Act provides a $40 sales tax refund or credit for Oklahoma residents who lived in
Oklahoma for the entire tax year iftheir yearly gross household income qualifies.
The Low Income home Energy Assistance Program (LIIIEAP)-provides winter heating,energy
crisis,summer cooling and/or weatherization and other energy-related home repair assistance to eligible
low-income households throughout each year during specific application periods.
The Oklahoma Department of Rehabilitation Services (DRS)-Vocational Rehabilitation Program helps
Oklahomans with disabilities join or rejoin the workforce through career counseling,education,job
placement and,when part of an approved employment plan,the purchase of specialized Iraining atid/or
equipment.
head Start Programs are administered locally by Community Action agencies,private nonprofit
agencies,American Indian Tribes,and a school district.At the federal level,thc Head Start Bureau is part
of the Administration for Children and families (ACF),United States Department of Health and lluman
Services (l)HHS).Ten regional offices oversee the grant administration of Head Start grantees.Oklahoma
is included in Region VI which is headquartered in Dallas.The grant administration of the 15 American
Indian gratuees is overseen by a separate branch of the ACF Head Start Bureau in Washington,t)C.
Public Housing was established to provide decent and safe rental housing for eligible low-income
families,the elderly,and persons with disabilities.Public housing comes in all sizes and types,from
scattered single family houses to high-rise apartments for elderly families.There are approximately 1 .2
million households living in public housing unit
Bureau of Indian Affairs General Assistance -The purpose of the Bureau of Indian Affairs General
Assistance f11L4-Q,.4.)program is to provide cash assistance fur certain specified basic needs of individual
Alaska Natives and American Indians,or families which include Alaska Natives and American
TerraCom,Inc.
CONFIDENTIAL DOCUMENT 27
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-130l
TerraCom Inc.’s Response to First Production Request of the Commission Staff
Page 41 of44
Indians.Covered needs include such items as food,clothing,shelter,and utilities;burial assistance may
also be included as no essential need.
The National School Lunch Program (NSLP)is a federally assistcd meal program operating in public
and nonprofit private schools and residential child care institutions,It provides nutritionally balanced and
free lunches to children each school day.The program was established under the National School Lunch
Act,signed by President Hany Truman in 1946.
Supplemental Security Income (SSI)is a federal income supplement program funded by general tax
revenues (not Social Security taxes):
•It is designed to help aged (those who arc 65 or older),blind,and disabled people,who have
little or no income;and
•It provides cash to meet basic needs for food,clothing,and shelter.
What is the difference between Supplemental Security Income (SSI)&Social Security Disability?
Social Security Disability:Those who receive Social Security Disability Benefits are those who have
been employed in the United States and Social Security was taken out ofeach paycheck.They qualify for
Social Security Disability because of their inability to work for a year or more because ofa severe
impairment.They are considered disabled if the administration decides that they cannot do the work they
did bet’ore and also cannot adjust to other work because of their medical conditions.Their disabilities
must also last or be expected to last for at least one year or to result in death.
This form of Social Security does not qualify a customer for the Lifeline service.
‘I’ransltional Employment Assistance Program (TEA)‘l’he TEA program is a state-administered
program that serves families in every political subdivision in the state.‘Ihe TEA program is funded by
federal funding from the U.S.Department of Health and Human Services under the l’emporaiy Assistance
for Needy Families (TANF)block grant and is administered by the Arkansas l)epartment ofWorkforce
Services.TEA provides thne-liinited cash assistance to needy families with (or expecting)children and
furnishes parents with work training and other supportive services they need in order to attain permanent
self-sufficiency.‘lhe welfare reform law changed the welfare system into one requiring participation in
activities leading to employment as a condition of receiving time-limited services.The TEA program also
provides assistance to children being cared for by non-parental guardians.
federal Poverty Guidelines —(100%,150%,and 135%)The poverty guidelines arc issued each year in
the Federal Register by the I)cparOnent of Health and Human Services (HHS).I’he guidelines are
simplification of the poverty thresholds for usc of administrative purposes-for itistance,determining
financial eligibility for certain federal programs.
health Benefit Coverage under Child health Plan-The principal objective ofthe state child health plan
is to provide primary and preventative health care to low-income,utsinsured children of this state,
including children with special health care needs,who are not served by or eligible for other state assisted
health insurance programs.
School Clothing Allowance (SC1)-Since the rnid-70s,The West Virginia Department of Health &
Human Resources has provided clothing vouchers for low-income school aged children.The program is
funded through the Temporary Assistance to Needy families (TANF)block grant.
TerraCom,Inc.
CONFIDENTIAL DOCUMENT 28
Response to Commission Staff’s Production Request No.2
CASE NO.TRA-T-130l
TerraCom Inc.’s Response to First Production Request ofthe Commission Staff
Page 42 of44
Mni’yland Energy Assistance Program (MEAP)-MEAP is a statc program that helps recipients pay
for the cost of heating their home,even if heat is included in the rent,MEAP will send mncy for the
heating bill directly to the energy supplier (if he or she pays their own heating bill)or to the landlord (if
heat is included in the rent).The amount received is based on income and energy usage.
The Temporary Disabilits’Assistance Program (TDAP),fonnerly called TEMHA,is available to help
low-income,disabled Marylanders with no other resources,to obtain cash,medical,and housing
assistance.The program is funded through the State of Maryland to provide help to individuals without
dependent children.
The Public Assistance to Adults (PAA)Program is available to help disabled Marylanders receive cash
assistance and can also help them to obtain Supplemental Security Income (SSI)from the Social Security
Administration,This program offers cash and medical assistance to needy adults without children who
live in Assisted Living,Certified Adult Residential Environment (CARE)Homes or Rehabilitative
Residences.
Wisconsin’s BatlgerCare Program is the program enacted by the Legislature and Govemor Thompson
in the fall of 1997 (1997 Act 27)to make health care coverage available for the working poor.It provides
family-based coverage for uninsured families with incomes between the current Medicaid limits and
185%of the federal poverty level (FPL).BadgerCare is financed with a combination of federal Title 19
and Title 21 funding,state revenue,and premiums (paid by families with incomes above 150%of FPL).
The necessary federal waivers for BadgcrCare were approved on January 22,I 999.
Wisconsin Works (W2)Payment.a Wisconsin Works (W2)payment is a payment received under the
Wisconsin Works assistance program for participating in a community service job or a transitional
placement,or a payment received as a caretaker of a newborn child.Note:Amounts received under the
program for trial jobs are taxable wages and are not included in the definition of Wisconsin Works (W2)
payment.Amounts received under the program for job access loans,health care coverage,child care
subsidies,and transportation assistance are also not included in the definition of Wisconsin Works (W2)
payment;these amounts are not includable in household income.
Wisconsin Homestead Credit Claim --The homestead is the Wisconsin home occupied,whether owned
or rented,and up to one acre of land adjoining it (or up to 120 acres of land if the homestead is part of a
farm).For example,it may be a house,an apartment,a rented room,a mobile home,a fann,or a nursing
home room.Unless the homestead is part of a farm,it does not include any part which is rented to others,
used for business purposes,or a separate unit occupied by others rent free.
Medical Assistance also generally lmown as Medicaid in most states.
United Tribal Food Distribution Program-is to provide assistance for certain specified basic needs for
individual Alaska Natives and American tndians,or families which include Alaska Natives and American
Indians.Covered needs include such items as food as an essential need.
Tribally Administered TANF-In 1996,Congress passed the t’crsonal Responsibility and Work
Opportunity Reconciliation Act (PRWORA),bringing an end to the Aid to Families with Dependent
Children (AFDC)Program.PRWORA replaced AFDC,Emergency Assistance,and the Job Opportunities
and Basic Skills program,with the ‘femporamy Assistance for Needy families (TANF)block grant to
States.Section 412 of the Act gave federally recognized Tribes the authority to independently design,
administer,and operate their own Tribal TANF programs.
‘ferraCom,Inc.
CONFIDENTIAL DOCUMENT 29
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
TerraCom Inc.’s Response to First Production Request of the Commission Staff
Page 43 of 44
Aid to the Disabled —An applicant/recipient must be 18 years or older residing in the U.S.Virgin
Islands.Resources such as saving/checking account and other property excluding the home in which you
live cannot exceed $2,000.Benefits arc paid the 1st day of each month on a cash debit card.The monthly
cash payment is $170.00.
Aid to the Blind -No age limit for assistance under the Aid to the Blind program.An applicant/recipient
must be a U.S.citizen or permanent resident residing in the Virgin Islands.Resources such as
saving/checking account,other property excluding the home in which you reside cannot exceed $2000.
Vehicle equity value cannot exceed $4,650.Benefits are paid the 1st day of each month on a cash debit
card.l’he monthly cash payment is $1 70.00.
Aid to tlic Old Aged -An applicanUrecipieiit must be 60 years or older residing in the U.S.Virgin
Islands.You must be a U.S.citizen or pennanent resident alien.Resources such as saving/checking
account,other property excluding the home in which you reside cannot exceed $2000.Vehicle equity
value cannot exceed $4,650.Benefits are paid the 1St day of each month ott a cash debit card.The
monthly cash payment is $170.00.
TerraCom,Itic.
CONFIDENTIAL DOCUMENT 30
Response to Commission Staffs Production Request No.2
CASE NO.TRA-T-1301
Tert-aCom Inc.’s Response to First Pmduction Request of the Commission Staff
Page 44 of 44
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.TRA-T-1301
TERRACOM,INC.
RESPONSE TO COMMISSION STAFF’S
PRODUCTION REQUEST NO.4
Response to Commission Staff’s Production Request No.4
CASE NO.TRA-T-1301
TermCom Inc.’s Response to First Production Request of the Commission Staff
Page 1 of3
SECTION 1 —RULES
IMI’ORTANT:Please read this form carefully and liii it out corr4bietely.If you have questions,please ask for help.FOrrnn that orenot completed accurately will be rejected rusutling In
a delay in your service or rejection of your uppllcation.By corrgrleting an application lr TerraCom Lifeline service,you cavity your eccoplunco 01 TerroCom’o Terms and Condilions
located at hltpihnww.TerraConrwirel000.comttermsl.
Liielate is a Federal government benefit program that otters a discount from your monthly phone service.Lifeline service ix available for only one line per household;a household is
defined as any individuat or group 01 IndIviduals who live together at the same adclr050 arid shwe Income end expanses.Housetrolds are not permitted 10 receIve benetits (mm
mutlipie providers and you may not reOolva multiple Lifeline discounts.You may apply your Lifeline discount to either one landline or one wireless number,but you cannot have the
discount on bolh.
Violufion of the one-per-household requirement is a violation of Federal floleu and wilt resuh In your removal from Ike program and potential praseculion by the United Slates
grrvernmant.Applicants who wililulty make false statements in orderto obluin Liteltne benefits con be punishedby hire or impnnonment or con bn burred from the Clfeine program.
You wilt be required to annually re.certity thatyou continue to qualify for Liteknebend to.
SECTION 2-ELIGIBILITY BY PROGRAM (completeeilherSec(lon2or3)
If you ore deponrtunt residing In your household are receiving benefits fromone or more 01 the programs listed below,please chockall fret apply.Proof of eligibility must be reviewed
by an authorized TerruCom employee In some cases we maybeabletodetermine elgibillyvIa a state database,please ask yourrepresentative foryet0110,
SECTION 3-ELIGIBILITY BY INCOME (complete either Soctlon2or3)
If yourilrcome to et or below 135%of the tederalpoverfy guidelines,an shown below,you can quality for Lifeline,
How many people are inyour Housxhokt7 fcumplnto onlyII qualifyIng underthis Section)1J
Nmbrof peoplefetrweelteld TaffitArmue ermine Il Nwrla*rety.epl.leIretHndid TeleMnawi fexaloeL Nerimberof people n heseakeld Isle ilomal krmrrme at
1 person $15,512 3people $26,366 S people $37,220
2 people 620,939 4 people $31793 Each additional peruon $5,427
TO QUALIFY FOR INCOME EUGIBILITY,YOU MUST PROVIDE COPIES OF ONE OR MORE OF TIlE DOCUMENTS LISTED BELOW.IF YOU PROVIDE DOCUMENTATION
THAT DOES NOT COVERA FULL YEAR (SUCH AS CURRENT PAY STUBS),YOU MUST SUBMITThREE (3)CONSECUTIVE MONTHS OF THE SAME TYPE OF DOCUMENT
WITHIN THE CURRENTCALENDAR YEAR.
Prioryear’sstale,federal or tribal teareturn •HetiremenuPenaiorm bevelIf ntatement
•Divorce decree orchild support document Social Security banalilsstatement
•Federal or tribal notice feller Dlparliclpution In Bureau01 Indian AffaIrs General AssIstance
Last 4 diglto of your Social Security Number Tribal ID Nmxnber
I 11 Ii I EmadAddress[
I I
SECTION 5-QUALIFYING BENEFICIARY (Complete if Section 2 benefits are In a name other Ihan appficant -in Free Lunch Program)
First Name Laid Name
beiaI
SECTION 6-STATE REQUIRED CUSTOMER INFORMATION
NotApplicable
irelessTerraCorn LIFELINE CERTIFICATION FORM
STATE OF IDAHO
SECTION 4-CUSTOMER INFORMATION
P1rt Name
RESIDEN17AIJPSRMANENT ADDRESS (P0Box not acceptable)
orreer
•UnemptoymentFNorknrs Comnponuatlon bandits statement
•Current Income stulamenl trom employer or paycheck stub
•VeteransAdministration benefits slutomertl
Street
BILLING ADDRESS (IF DIFFERENT FROM RESIDENTIAUPERMANENTADDRESS)
Middle LasI Name
Initial
Check hereIt this Is aTemporary Address []
______________________________
1 1Crty ]Stare I
I IDlY J 1$tate Zmp
Dote of BInh
Response to Commission Staffs Production Request No.4
CASE NO.TRA-T-1301
TenaCom Inc.’s Response to First Pmduction Request of the Commission Staff
Page 2 of 3
SECTION 7-ONE PER HOUSEHOLD
acknowledge that,to the best ofmy knowledge,rio one at my householdIs receIving aUlellne-ssppertad service Irom any other provider.
ICutlonivi 10b815)
SECTION 8-CUSTOMER SIGNATURE
PLEASE flEADAND INITIAL THE FOLLOWING.BY SIGNING &INITIALING BELOW,YOU ARE AGREEING TO THE FOLLOWING PROGRAM RULES:
D I certify under penally of perjury that I eithar participate in the Indicated quatfying federal program or I meal the Income qualitication to establish my
eligibility for Lifeline.If requIred to do so,I have provided accurate documentation of my eligibihty.
I certify I am head of fhe household,I am an adult 18 years or older (unless an emancipated minor),I am not listed as a dependent on anotherperson’s tax return (unless over the age of 60)and lhe address britad is my primary residence.
I confirm local voice service discounts under the low Income programs are limited to one per household end that my household is receiving no more
than one Lifeline supported service.If I am participating In another Cifetne program af the time I apply for TerraCom Lifeline service,I agree to cancel
D that Lifeline service wilh any other provider.I certify that I will only receive one Lifeline connection,wit not have simullanaous or multiple Lifeline
discounts wittr enolher provider,I understand that I must inform TerraCom within 30 days 111(1)no longer participate In a federal qualifying program
or programs or my annual household income eeceeds 135%of the Fedarat Poverty Guidelines;(2)1 am receiving more then one Liteilneaupportedserviceperhousehold;or (3)I,for any other reason,no longer satisfy the criteria for receiving Lifeline eupport.I attest under penalty of perjury thaI I
understand this notification requirement,end that I may be subject to ponaltleaif I tall to follow this rule.
D l acknowledge that I may be required to re’cartlly my continued eligibility for LIfeline at any time,end that failure to do so will result In the termination
of the my Liteline benefits.
D l understand that LIfeline service is a nen-treesfemiote refit iervlce offering,and that I may not transfer my setvtce to any otherIndMduel,lnckidlng
another e8lble low-income consumer.
I acknowledge and consent to the use of my name,telephone number,and address to be given to the Universal Service Administralive CompanyD(USAC)(the administrator of the program)end/ot its agents tot the purpose of verifying that t do not receive more than one Lifeline benahl,IunderstandthatrefusaltograntthispermissionwitmeanIemnotebgibleforLifelineservice.I also authorize TerraCom to access any records
required to verity my 5tatements herein and to confirm my continued eligibility for Lifeline assistance.
I undetstand that if I move,I must provide a new address to TerraCom within 30 days of my move.I understand that If I ptovided a Temporary
Address,I must verify with TerreCom every 90 days that I am using the same address,I understand that if I tail to do so,I will lose my Lifelinediscount.
By my signature below,I certity under penalty of perjury that I have read and understood this form end that t attest that the Information contained In Ihis
application that I have provided Is true and Correct to the best of my knowledge and that I acknowledge that providing false or fraudulent intormalion to receive
Lifeline benefits Is punishable by law.
Signature1 I Todey’s oateIJ/j{/F
SECTION 9-TRIBAL CERTIFICATION
BY CHECKING IIERE AND MY SIGNATURE ABOVE I CERTIFY THAT MY ADDRESS IS ON FEDERALLY RECOGNIZED TRIBAL LANDS
SECTION 10-INSTRUCTIONS
Mail or Fax completed form to:TerraCom,Inc.
Fax:1’877-221.Ooll Attention:Verlflcatlon/Recerttficatlon
5000 Atrium Way,Suite 8 Mount Laurel,NJ 08054 -3915
,
—
I hereby certify that I have followed the company’s procedures with regard to proof of eligibility.I also verify I have reviewed the necaosery documentation to verifyidentityandaddressoftheapplicant,and I am aware that talsillcalion of this is subject to termination or legal action by the company.
Company Representative -Print Full Name (No Initials)Company Representalive Signature
ESN Account Number
MoNte Number Dale
Response to Commission Staff’s Production Request No.4
CASE NO.TRA-T-1301
TerraCom Inc.’s Response to First Praduction Request ofthe Commission Staff
Page 3 of3
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO.TRA-T-1301
TERRACOM,INC.
RESPONSE TO COMMISSION STAFF’S
PRODUCTION REQUEST NO.5
Response to Commission Staffs Production Request No.5
CASE NO.IRA-T-1301
TenaCom Inc.’s Response to first Production Request of the Commission Staff
Page 1 of 3
V
‘irelessTerraom Yñiiñ7
/w i I I C U.v
Revised Agent Code of Conduct
TerraCoin /YourTcl have a commitment to provide the highest quality,most honest and professional
Lifeline service available.To ensure every aspect of our business is conducted with this goal in mind,the
Agent Code ofConduct sets forth the principles and practices to which Agents will adhere.
I.Agents and their employees shall conduct themselves in a professional business manner when
talking to customers,other Agents,other Agent employees,Agent Support Staff,Customer
Service and company Management.
2.Agents and their employees shall not engage in any deceptive,false,unethical,unfair,&/or illegal
consumer sales practices,marketing practices or recruiting practices.Agents shall ensure that no
statements,promises or testimonials are made that are likely to mislead consumers or prospective
Agent employees.
3.Agents and their employees must comply with all requirements of law,including the Federal
Communications Commission’s Lifeline rules.While this Code does not restate all legal
obligations,compliance with all pertinent laws and regulations by Agents and their employees is
a condition of acceptance and continuing partnership with TetTaCom /Yourfel.
4.Information provided by Agents and their employees to customers shall be accurate and
complete.Agents and their employees shall not make any representation to customers that cannot
be verified,or make any promise that cannot he fulfilled.
5.Agents and their employees shall educate all potential customers ofthe benefits and requirements
ofTenaCom /YourTcl’s l,ifelinc-supported products and services before having the consumer
complete an enrollment application for Lifeline-supported services.
6.Agents and their employees shall not abuse the trust of customers,or exploit a customer’s age,
illness,handicap,lack of understanding of the Lifeline program,or unfamiliarity with a language.
7.Any marketingmaterials created by the Agent must be approved by TerraCom /Yourl’cl’s
Regulatory and Agent Support departments and must clearly state that the service is Lifeline-
supported;that Lifeline benefits are limited to a single line of service per residence,no multiple
Lifeline benefits are permitted and the discount may apply to one landline OR one wireless
number,but not both;and that not all Lifeline services are marketed under the name Lifeline.
8.Agents and their employees will he required to complete the TerraCom/YourTel sales training
program that includes training on all Lifeline compliance requireTnents.Only upon completion of
the TeimCom /YourTcl Agent training can an Agent or their employees be certified to sell the
services ofTerraCorn /YourTel.
Initials TerraCom /VourTel Agent Code of Conduct
Response to Commission Staff’s Production Request No.5
CASE NO.TRA-T-130l
TermCom Inc.’s Response to First Production Request of the Commission Staff
Page 2 of 3
IreIe5sTerraom LVLTTrSr I
9.Agents and their employees must follow the steps outlined below,before accepting a Lifeline
form from a customer:
•See the customer’s photo ID
•Sec proof of the customer’s eligibility
•Confirm that identity matches that ofphoto ID
•Require the customer to confirm that they arc not currently receiving a Lifeline
subsidy from other provider and inform the consumer that not all Lifeline services are
marketed under the name Lifeline.
1 0.Agents must submit a valid ID to TerraCom /YourTel for all personnel selling or supporting
TerraCom I Yourlcl’s Lifeline service offerings,so that personnel can be formally registered and
then certified with TerraCorn /YourTel.
11.Agents are required to report,within 24 hours of discovety,atty waste,fraud and abuse identified
from any source,Discovery and confirmation of the fidlure to do so will result in immediate
termination.
12.Any returned orders that are identified as being potentially fraudulent will trigger an immediate
investigation.If Agent misconduct is confirmed,the Agent will be asked that the employee be
immediately terminated from all TerraCom /YourTcl-rclated activity and the fraudulent
account(s)will be a charge-back to the Agent.If the Agent/Dealer is found to be a repeat
offender,the Agent will be terminated.
13.Agents understand that ‘terraCorn /YourTel make the ultimate decision regarding certification
and verification to enroll a subscriber for Lifeline service or not.
14.Agents agree to cooperate and work fully with TerraCom /Your’l’el,state and federal law
enforcement authorities,the FCC,USAC and state public utility commissions to detect and
resolve duplicate and or fraudulent Lifeline claims.
Agent Company Name:
Rcprcscntativc Signature:
Printed Name:
Title:
___________________________________________________________________
InitIals TerraCom /YourTel Agent Code of Conduct
Response to Commission Staff’s Production Request No.5
CASE NO.TRA-T-1301
TermCom Inc.’s Response to First Pwduction Request of the Commission Staff
Page 3 of3
Date: