Safe Link Proposal for the New National Verifier

Safe. Link Proposal for the New National Verifier Presented by Gina Jasman – 07/03/18

Presentation Roadmap List of Major Issues with NV (National Verifier): 1) Lack of API (Application Programming Interface) between Service Provider (SP) and NV 1) Failing to streamline the process and creating waste in the system 2) Creating artificial barriers for those eligibility to complete the sign-up process 2) A two step eligibility verification (NV) and application process (carrier) rather than a one-step seamless process 1) Manual portal with a SP is the only channel available to the consumer for completing the application, removing website, customer service representative (CSR), fax and mail channels 2) High volume of incomplete or inadequate transactions will be sent to the NV since the service provider filtering process will be removed 3) New lengthy and complicated application and IEH (Independent Economic Household) forms TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 2

Lack of API - Executive Summary Key Points we will address for our recommendation, detailed in this presentation: • • • Falling Short of Goals • How the current implementation without an API falls short of the goals of the National Verifier Enacting New Barriers • The lack of API creates new barriers for low-income individuals, especially those who are disabled or living in more insular communities, to obtain lifeline services Simple Changes will Help advance the Goals of the National Verifier • How a small change to the Implementation can save significant administrative costs to the Universal Service Fund TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 3

Falling Short of Goals From the 2017 USAC Annual Report: “Looking forward, the Lifeline Program anticipates launching the National Verifier, which will deliver a streamlined, consistent verification process for potential Lifeline subscribers and will enable greater protection against program waste, fraud, and abuse. ” The current process without a real time API for carriers to request verification will not be meeting this objective by 1. Failing to achieve a more “streamlined” process, and 2. Incurring unnecessary waste due to dramatically increased administrative costs resulting from high volumes of manual checks TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 4

Enacting New Barriers Having duplicate entry of an application creates artificial barriers to obtaining the service while increasing the administrative cost: o Additional manual data entry for all parties involved since it requires the need to login to a manual NV Portal to validate Lifeline eligibity, with the additional administrative cost of maintaining thousands of credentials for each. o Mismatched data entries between records maintained by the NV and records maintained by SP for the service provision will lead to errors in NLAD o Longer and higher amount of paper applications as opposed to automated submissions, with significantly higher costs for the National Verifier to process applications. Applicant’s experience will be cumbersome since they will need to manually enter their PII (Personally Identifiable Information) multiple times: in the NV system and the SP’s enrollment system which will cause data entry errors. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 5

Enacting New Barriers Lack of API or “Real Time” connection with SPs increase costs and decrease efficiency: a. SPs need API interfaces with the NV to allow us to integrate with our system the same way we need to do it by using the SP Portal, nothing more. Only a faster and reliable way to process data and avoid duplication. b. API process will also allow SPs to submit personal information from the subscriber, similar to the SP Portal. c. SPs will need thousands of employee credentials for live agents to support consumer with the National Verifier to validate applicant’s eligibility. d. The NV team will be using internal API interfaces to communicate with the federal and state databases to check eligibility, they need to expose these APIs and make them public to the SPs. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 6

Simple Changes will Help Advance the Goals of National Verifier Service Providers need to have API to avoid duplication. • Through API call, a SP can receive the applicant’s information from the NV portal in real time, the SP can create an enrollment in their own enrollment platform, instead of applicant entering the same information for the second time. The SP can send the “Enrolled” transaction to NLAD for enrollment into NLAD after NV has approved the applicant for Life. Line eligibility. Such a process would be truly streamlined, allowing applicants to apply one time without the need to re-enter all of their information on two different systems, creating unnecessary delay and potential for mismatched duplications TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 7

Two Step Eligibility Verification & Application Processes Under USAC’s current plan, an applicant only has 3 ways to verify eligibility with the NV: 1. Online using the “checklifeline. org” web portal 2. In-person by going to a service provider and using the service provider portal though live interview 3. Snail mail that requires an applicant to print, affix stamp, mail then wait for a response from NV for eligibility determination Except for in-person interview with a live agent, USAC’s plan inexplicably removes carriers from the eligibility verification process, even though applicants must still go to a carrier to finish the application process after their eligibility is verified. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 8

Two Step Eligibility Verification & Application Processes This system is 1. Highly inefficient and requires duplicative entry from an applicant without NV’s API 2. Prevents carriers from aggressively marketing their services and products 1. No assurance that a SP’s marketing effort with lead to enrollment 3. Undermine partnerships between SPs and other organizations to facilitate Lifeline enrollment 1. MCOs and Medicaid-eligible applicants 2. Social services organizations such as the Salvation Army 4. Removes carriers from the pre-screening process it currently undertakes to reduce USAC’s administrative burden TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 9

Two Step Eligibility Verification & Application Processes – Cont. Safe. Link Proposed Enrollment Flow One stop process: the consumer will go to their SP of choice and use one of the SP’s channels to create an application ü The SP will run their internal validations to ensure service availability and detect fraud ü The SP will generate a unique ID and transmit it along with the Consumer’s collected PII (Personally Identifiable Information) to the NV ü if proofs are needed, the consumer can upload eligibility documentation to the NV via the SP channels ü The SP will use the ID to check the eligibility status and enroll the Consumer in NLAD when getting a positive answer from the NV TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 10

Two Step Eligibility Verification & Application Processes – Cont. Safe. Link Proposed Enrollment Flow Advantages • The Consumer will go to their SP of choice (one stop only) to apply and receive Lifeline service • The Consumer will only need to enter their application information in a single platform • If eligibility proof is required after the consumer started the enrollment process with SP, it will not be required to start the process all over again after getting the NV Lifeline eligibility approval • By having SPs doing a pre-review of supporting documentation, the NV will significantly reduce the number of documents to review since they will only receive documents with a high chance of being approved • This approach is suitable for omni-channel for the SP, facilitating the process for all consumers to get their Lifeline service TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 11

Safe. Link Major Issues with the NV – Cont. CONS: • SPs still depend on the NV SLA (Service Level Agreement) for reviewing documents, but this can be mitigated by decreasing the volume with the SP pre-review of supporting documentation TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 12

Safe. Link Major Issues with the NV – Cont. Safe. Link Proposal Flow Click icon to see proposed flow TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 13

Safe. Link Major Issues with the NV – Cont. Safe. Link Street Team Proposal Flow Click icon to see proposed flow TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 14

Two Step Eligibility Verification & Application Processes – Cont. Our system is reliable while treating customer’s PII: a. Lexis Nexis validations (additional to TPIV), that is usually more strict than NLAD, that allows us to validate PII and find: i. Duplicates by ADL (even when PII is purposely changed) ii. Deceased customers iii. PII wrongly entered iv. Address that does not belong to the customer b. CASS and Melissadata Address Validations that allow us to: i. have ONLY VALID residential addresses entered and solicit extra documentation when it is not valid ii. Identify Duplicate addresses even when NLAD might not detect it Having customers enter PII directly into a system that lacks any of these standards will endanger data integrity, duplication check and will delay and hurt the qualification process. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 15

Two Step Eligibility Verification & Application Processes – Cont. Service Provider Portal . • Mandatory for consumer to be in-person to apply for Life. Line a. Grass Roots channel with the use of the mobile app, that incentivizes SPs to utilize third party grass roots agencies – the venue most prone to waste, fraud, and abuse b. In-person requirement undermines the ability of seniors, disabled, or those living in rural communities from accessing the service TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 16

Two Step Eligibility Verification & Application Processes – Cont. The following SP channels will no longer be available to the consumer: . i. SP website: consumer goes to the website and creates an application, e-signs it and uploads all supporting documentation. ii. SP CSR: consumers call the 800# to enroll over the phone with the help of a live agent and recordings from the consumer accepting all certifications. iii. SP fax channel: consumer faxes a fully executed application along with copies of supporting documentation. iv. SP Mail Channel: consumer mail in a fully executed application along with copies of supporting documentation. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 17

Safe. Link Major Issues with the NV – Cont. Carrier Pre-screening: • Currently Trac. Fone filters the amount of enrollments sent to NLAD for approval due to our multiple system validations thus eliminating applicants that are not eligible and bad enrollments. • Last year we reduced the number of leads by 95%, without Trac. Fone conducting the pre-screening, the NV would have received 58 million leads instead of the two million records sent from Trac. Fone in 2017 • Without the carriers being the first stop, the NV will process about 56 million more records, and that is just for one carrier alone. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 18

Safe. Link Major Issues with the NV – Cont. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 19

Safe. Link Major Issues with the NV – Cont. 5. The new standard official National Verifier Form (FCC form 5629) is 8 pages long and provides lengthy information with multiple blank spaces; as opposed to have an application by state which can be only 2 -pages long. The new standard Recertification Form (FCC form 5630) is 7 -pages long as opposed to 2 -pages long and the IEH (Independent Economic Household) worksheet (FCC form 5631) is now 3 -pages long instead of one page. • No reason given as to why the spacing cannot be reduced to present the same identical information in a more streamlined fashion. TRACFONE WIRELESS, INC. PROPRIETARY AND CONFIDENTIAL 20