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OTI and other groups submitted comments in response to the Federal Communications Commission’s proposal to impose additional procedural hurdles and administrative burdens on the Lifeline program.

They argue:

1. Many of the proposals before the Commission—particularly expanded identity verification, full SSN collection, and usage tracking—risk further lowering the program’s participation levels, which hovered between 19 percent and 22 percent over the last decade.
2. These proposed changes threaten to make enrollment more complex, cumbersome, invasive, and punitive, even though Lifeline is already chronically underutilized.
3. The proposed red tape could increase administrative costs for the Commission and reduce overall participation.

They conclude that the Commission should instead allocate its resources and time to identify why Lifeline remains underutilized and remedy those issues by better protecting consumers, expanding outreach efforts, and easing the enrollment process.