VI. Assignment of Proceeding
Dian M. Grueneich is the assigned Commissioner and Karen A. Jones is the assigned ALJ in this proceeding.
1. Many LifeLine recipients complained that they received their certification or verification notices too late to respond.
2. With standard mail, there is no guaranteed delivery, nor return to sender.
3. Standard mail, standing alone, is not satisfactory in a program based on time-sensitive, short-deadline mailings.
4. The proposed modifications to Appendix E of GO 153 are a key element in improving the response rates for both certification and verification.
5. The low response rate is multi-faceted, so the resolution will be multi-faceted as well.
6. When Solix gives carriers a data feed, the carriers have an obligation to correct incorrect date in this files.
7. There is a benefit to more than a single one-time true-up of data between Solix and the carriers.
8. The letter from carriers to new customers reminds customers of the respective roles of the telephone company and the certifying agent.
9. Staff needs to be informed of system problems - especially any that impact LifeLine customers - within 48 hours of when they are discovered.
10. Staff has identified problems that will require solutions beyond those that can be implemented in the short term.
1. In light of the problems with standard mail, it is critical that customers have additional time to respond.
2. In order to respond quickly to problems, staff should make use of the resolution process to present further changes to the GO for Commission approval.
3. The draft resolutions relating to the GO should have the same timeline as for a proposed decision so stakeholders have an adequate opportunity to review the draft resolution.
4. Since there is insufficient time for the customer to respond, the timeline for verification should be revised by issuing a "soft" denial on the 45th day, instead of the outright denial in the current process.
5. Pursuant to GO Section 5.4.4, there is no time limit associated with the backbilling of LifeLine discounts.
6. The additional reminders and notifications included in the contract amendment should encourage LifeLine customers to complete and return the required forms.
7. CD should take the steps necessary to implement first class mail for all aspects of the LifeLine program as quickly as possible.
8. LifeLine documents meet United States Postal Service requirements for standard mail.
9. The contract amendment provides that Solix provide information to carriers to facilitate the reconciliation of data between Solix and the carrier.
10. Staff should have the authority to interpret what specific documents can be included under the catchall phrase: "Other official document," with the caveat that the document in question should be one the purpose of which is to verify or establish income.
11. Carriers should send the reminder materials to new LifeLine customers.
12. Solix should identify and rectify problems impacting LifeLine customers as quickly as possible.
13. Solix should not implement routine system modifications from 7:00 a.m. to 7:00 p.m. Pacific Time.
14. The contract modification described in the Staff Report should help to increase the response rates.
15. Verizon should work with CD staff to develop workarounds for the problems it has with the required notice to new customers.
16. If any carrier is unable to implement the letter to new LifeLine customers within the timeframe established in this order, the carrier should file a request for extension of time pursuant to Rule 16.6.
17. The Certifying Agent should maintain a list of carrier contacts and provide three business days' advance notice via e-mail of any changes to its system of processing protocols.
18. The steps outlined by staff under their short-term strategies will help to increase response rates.
19. The suspension of those portions of GO 153 suspended in the November 1, 2006 ACR, as modified by D.06-11-017, should be lifted effective June 1, 2007.
20. A web-based system should streamline and expedite the certification and verification processes.
21. Some long-term strategies may require a more formal review than that of the resolution process.
22. Commission staff should ensure that Solix is in compliance with its contract and any subsequent amendments.
Therefore, IT IS ORDERED that:
1. The proposed changes to Appendix E of General Order (GO) 153 that appear in Attachment 1 of "Report on Strategies to Improve the California LifeLine Certification and Verification Processes" shall be adopted.
2. Staff is authorized to use the resolution process to present further changes to GO 153 for the Commission's consideration. Those draft resolutions shall be provided to interested parties 30 days before the Commission meeting when they will be considered. Opening comments are due in 20 days, and Reply Comments, five days later. Those draft resolutions shall be served on the Service List of this proceeding.
3. GO 153 shall be modified to include the proposed additional reminders and notifications to customers.
4. Staff is authorized to interpret what specific documents can be included under the catchall phrase: "other official documents." However, the documentation in question shall be one from a government agency or court the purpose of which is to verify or establish income.
5. The Communications Division shall take the steps necessary to implement first class mail for all aspects of the LifeLine program as quickly as possible.
6. All telecommunications carriers subject to the provisions of GO 153 shall send correspondence to existing LifeLine customers informing them of the new LifeLine verification process. The correspondence will be sent to coincide with the re-launch of the verification process. Carriers shall also send reminder materials to new LifeLine customers as described in this decision.
7. The Certifying Agent shall maintain a list of carrier contacts and provide three business days' advance notice via-email of any changes to its system or processing protocols.
8. The Certifying Agent shall not implement routine system modifications from 7:00 a.m. to 7:00 p.m. Pacific Time.
9. GO 153 shall be modified to add Section 4.1.3, as it appears in Attachment 6 of the Staff Report. Section 4.1.3 requires carriers to send reminder notices to new LifeLine customers.
10. The assigned Commissioner shall work with the Communications Division and Solix to ensure timely implementation of measures to correct future problems with the LifeLine processes.
11. We lift the suspension of the following sections of GO 153 which were suspended in the November 1, 2006 assigned Commissioner Ruling, as modified by Decision 06-11-017: Section 4.5, including Appendix C; 5.5; those portions of 6.3 and 6.4 as they relate to the annual verification process; 8.1.3 as it relates to customers who have not responded to the annual verification notice or returned it late; Appendix C; and the portion of Appendix E titled "Existing ULTS Customers (Verification)." Those sections of General Order 153 shall be reinstated effective June 1, 2007.
12. Initially, the verification process shall be resumed for a 20 percent random sample of customers. Once staff has reviewed the results and made any additional adjustments to the process, they shall require Solix to increase the percentage of customers included until the verification process is operating at 100%.
13. The assigned Commissioner shall commence a second phase of this proceeding to review long-term strategies requiring formal review.
14. The Executive Director shall report at the Commission's first regularly scheduled meeting of each month on the status of the LifeLine program. Those reports, which should include information on any problems encountered, and the status of steps taken to implement program improvements, shall continue until the assigned Commissioner determines that they are no longer necessary.
15. Commission staff shall monitor the process of implementation of the web-based system to ensure that Solix completes its development work in the time period established in D.05-12-013.
16. Commission staff shall perform an audit of the Solix contract to ensure compliance with contract requirements. The audit shall commence within 30 days of the effective date of this order.
17. Commission Staff shall continue to hold regular meetings of the Implementation Working Group and the Marketing Working Group to discuss issues relating to the low response rates for the LifeLine certification and verification processes. Consumer groups shall be represented on both working groups.
18. The rulings made in the February 28, 2007 and March 28, 2007 assigned Commissioner's Rulings are confirmed, and adopted as orders of the Commission.
This order is effective today.
Dated May 3, 2007, at San Francisco, California.
