ACAP Letter to FCC on Lifeline Phone Program

August 31, 2015
Submitted electronically to the Federal Communications Commission’s website:
Re: [WC Docket Nos. 11–42, 09–197, 10–90; FCC 15–71]

Dear Commissioners:

The Association for Community Affiliated Plans (ACAP) thanks you for providing us with an opportunity to comment on the Proposed Rule “Lifeline and Link Up Reform and Modernization, Telecommunications Carriers Eligible for Universal Service Support, Connect America Fund.” The Proposed Rule was published July 17, 2015 in the Federal Register.

ACAP is an association of 60 nonprofit and community-based Safety Net Health Plans. Our member plans, located in 24 states, provide coverage to more than 15 million individuals enrolled in Medicaid, the Children’s Health Insurance Program, Medicare Special Needs Plans for dually-eligible individuals, and Qualified Health Plans. ACAP plans currently serve approximately one-third of Medicaid and CHIP enrollees who receive coverage through risk-based managed care, including around one-third of all enrollees in the Medicaid-Medicare demonstrations. ACAP plans are members of their communities, partnering with states to improve the health and well-being of their members who rely upon the Medicaid program.

A number of the ACAP health plans work with Lifeline wireless providers to provide phones to Medicaid beneficiaries. These phones are used to deliver critical health messages and provide support designed to address many of our nation’s key population health goals and health disparities for families with young children to the very frail elderly. These phones also help connect Medicaid beneficiaries to critical health services as well as the supports provided by their health plan.

The Lifeline program was enacted to ensure that telephone service is available to address the critical needs of the most vulnerable members of society. Making Lifeline mobile phone service available to validated Medicaid beneficiaries and leveraging those phones to deliver critical health education, monitoring and support that is proven to improve critical health outcomes for Medicaid families achieves that aim.

We believe that no longer allowing Medicaid recipients to qualify for Lifeline support would have a negative impact on health status. Therefore, we strongly encourage the Commission to preserve Medicaid as a qualifying program for Lifeline and allow this vital support to continue. If you have any questions concerning this response, please feel free to contact Deborah Kilstein at or by telephone at 202-341-4101.



Margaret A Murray

View the full comment letter here »