Bottlenecks in the Affordable Connectivity Program - Episode 522 of the Community Broadband Bits Podcast

Christopher Mitchell (00:07):

Welcome to another episode of the Community Broadband Bits podcast. This is the Gila River Edition in, I'm sitting here with a friend Ms. Jengle, <laugh>

Jessica Engle (00:21):

Jengle all the way Jessica Engle, who I met at our first Tribal Broadband bootcamp, the Tribal Wireless Bootcamp, and who is now with Althea?

(00:32):

Hi everybody. So I'm doing community outreach with Althea, getting the Affordable Connectivity Program, stood up and doing all kinds of fun stuff. And all of it is thanks to the connections made from that original bootcamp.

Christopher Mitchell (00:44):

Yeah. I'm sure you wouldn't have had any friends without us.

Jessica Engle (00:46):

No, I'm sure I wouldn't, not at least the cool ones that do all kinds of broadband stuff.

Christopher Mitchell (00:51):

So we want, we want to focus in, we have a kinda a tight window here. We can't me end or like my normal shows <laugh>. and Jessica, you have been on connect this. I know and I think we did a, a Broadband Bits podcast too, but probably but you, you have had a lot of close up experience with acp. Yep. You've lived to learn lessons and to talk about it and, and I think that's what we're gonna focus on here, the Affordable Connectivity Program.

Jessica Engle (01:16):

Yes. So started with the Emergency Broadband Benefit program back in the beginning of 21. And so that program was something that you had to like, sit through a bunch of webinars to learn how to do. It turned out though, because there was no allowance for administrative costs that I personally had to stay up till midnight every last day of the month in order to get folks enrolled. cuz on the first of each month there's a snapshot taken of your database and those are the only people you can claim for on the 15th of the month. If you miss your claim date, you cannot go back. There's no passing go or collecting any sort of dollars. And so with Affordable Connectivity program in March, not at the beginning of the program, but in March they changed that rule. So now you can go back up to six months, but only up to March and only claim what was in your snapshot for those individual months.

Christopher Mitchell (02:08):

So if you have someone that deserves the discount but may not have all their paperwork in order, is that what you're

Jessica Engle (02:14):

Yes. So that basically what that the FCC has told us as providers to just charge them. And that's wonderful because then you have a person who thought they went through all the trouble of applying, which is not easy, and they're still getting a bill and that is a big problem.

Christopher Mitchell (02:31):

So when you say charge them, this is a, let's let's sketch it out for, for people, right. I'm I'm a person living you know, on a reservation I'm eligible for the $75 a month, or at least let's say, I guess we believe I am. It's not always Yes, totally clear. Right, but Right. We believe I am. And and I, so I come to you and I say, Hey, I want this this discount. you're the service provider. What, what do you have to do?

Jessica Engle (02:56):

It depends <laugh>. if they're with me as a tribal representative, I highly recommend going with the alternative eligibility criteria program instead of the national verifier. So basically what that means is you as the provider have to write how you're going to keep track of all of the eligibility criteria yourself and prevent waste, fraud and abuse. It's like a 10 page paper of how you're gonna prevent waste, fraud, and abuse. And then they have to approve it. alternatively is a national verifier where the users can go to ac pure program.org or get connected to internet or there's a million different websites now to basically get you to the place where you log in and you create an account and you sign up that way.

Christopher Mitchell (03:42):

Wait, so, so the user, I mean, a lot of the people who are listening to this I think are, are sort of interested in just generally they may not themselves be people who are taking advantage of it or administering it. So, so it's on the user to register at the federal government in this this method?

Jessica Engle (03:55):

Yes, and I have actually. So there's an alternative way which is not used very frequently, especially with large providers, and that's having the provider themselves enroll them mm-hmm. <affirmative>. And so it's the same system minus creating an account and doing the verification process. I did a side-by-side comparison of time. It takes the user like a consumer 18 minutes longer to do the same thing than it would take me to do it.

Christopher Mitchell (04:22):

And it would take you about two minutes you told

Jessica Engle (04:23):

Me. Yes, that's correct. And, and that is like a very generous way because I already have an email account, I know how to verify an email. So those things, you know, increase the, the, you know, the speed of me being able to apply as a consumer that a lot of consumers that are low income and without internet wouldn't necessarily have. and there's this movement towards the digital navigators enrolling folks, but they don't have access to the system that I have access to because they're not a provider. Mm-hmm. <affirmative>, it just doesn't make any sense.

Christopher Mitchell (05:00):

And so, to be clear, I I feel like we have obscured this a little bit. When you have an experience when you were running the Yurok network Yes. That you are signing people up there, now you're signing people up on behalf of, of ISPs that are working with Althea.

Jessica Engle (05:13):

And I also created a signal, or sorry, not signal discord server called a c p provider support group because I saw a lot of other ISPs that are struggling with this lift. And so I've actually helped a few other people just generally with the process that way through the, through the Discord server. And so basically got Althea in the states that we are currently registered with, which are Washington, Oregon, and California, to be able to offer that service to all of our, our mini networks. And so the next step is getting people enrolled. There's multiple ways to do that, but once you get a user enrolled, then you have to enter them into a second database system. And that's called in lad and that's the National Lifeline Accountability Database. That's the one that's important. Once someone's in that database, that snapshot I referred to earlier, that's done on the first of the month. Those are the people that you can make a claim for reimbursement from.

Christopher Mitchell (06:16):

If you're one of the major telephone or cable companies, they are doing all the work for a person that's registering for service generally. But if you're not, then you sign up for a the service in terms of, of going through the national verifier, creating an account on a system which requires an email, which requires you to verify your email, which can be a challenge for a number of people that have not been using this in the past. And then you still have to then get into the NLA system.

Jessica Engle (06:47):

Yes. So in order to do that, it's everything. The same thing that you would have entered in for the national verifier minus the last four of your social if you have your application id. And so then that gets entered, the snapshot of the provider's database is taken on the first of the month for the month prior, and those are the only people that they can make a claim for. So that's where some of the problem wise is that if you don't get in their system for whatever reason, it could be data entry, it could be, you know, they couldn't get ahold of you and your application ID expired, whatever the case may be. but those are the only people that they can file a claim on. Those are the only people that will get that credit to their bill. And because it's done the month after on the 28th is when they get the deposit for the prior month. Sometimes those are delayed quite a bit.

Christopher Mitchell (07:44):

So one of the things that has come up is that if you don't get your claim in on the day that you're supposed to get your claim in Yes. Then you would not be able to get reimbursed for all those us we were talking about at the beginning of the conversation.

Jessica Engle (07:57):

Yeah. So the major dates are the first, when they do the snapshot, the 15th is when you do your claim. If you miss the 15th, you don't get to redo your claim until March. March. They change the rules. So you can go back up to March 1st up to six months and file a claim on the people that were in your snapshot. so you file your claim on the 15th if all goes well, and then you get a deposit and one lump sum on the 28th of the month. Now this is why the device component is kind of a big lift for a lot of folks because when you get your deposit includes all your subscriber fees, the $30 or $75 plus the a hundred dollars for those that got some sort of device reimbursement. And so that's the part that isn't really being thought of, like as how difficult it is to go back and re-enter or credit somebody's account when you have hundreds. Even if you have tens, it's still a lot of work to say we got $3,726, but where does those 300, you know, get entered?

Christopher Mitchell (09:02):

You don't have like a good record where the, you don't have like an itemized like receipt from the usac No,

Jessica Engle (09:07):

No. You get a claim check, that's it, and then an ACH deposit. That's it. And there's nothing to indicate that that deposit you've got was for ACP at all in your bank. Wow. It just says from the US Department of Commerce or something like that mm-hmm. <affirmative> something really random that doesn't refer to the FCC or Inlet or USAC at all. So

Christopher Mitchell (09:30):

You have, you, you could have an I S P in which you have, you're serving some people on non-tribal lands who are getting $30 a month credit. Yeah. Some are getting $75 a month if they're in an area. And we're gonna talk about the latitude longitude issued in a second. Oh yeah. And then you also have some people for whom you may have processed a $100, a hundred dollars device, but like, is it possible the FCC has re if you, if you submit 10 of those claims, could the FCC like rejects seven of them and not tell you Yes. <laugh>, come on.

Jessica Engle (09:58):

Yeah, no, totally true. And you know, speaking of that, like when you have a mixed customer base and you have mixed transactions doing the accounting component of it, going back and crediting those accounts and doing the documentation, there's nothing at all for you to indicate that that deposit referred to that transaction that you did in Inlet or USAC or any of those databases because they don't talk to each other at all.

Christopher Mitchell (10:28):

Right. So we are here at the National Tribal Telecommunications Association, we just have a couple of minutes left before you have to become a pumpkin. And and one of the things that came up earlier was that make sure your billing system can talk to your provisioning system and all this other stuff. Yeah. I don't think people realize that, like how hard it is to have a system that works well where you can keep track of all these different things and without having to do it yourself in spreadsheets or something. Oh,

Jessica Engle (10:52):

Yeah. Because spreadsheets, we all know they can get real messy real quick and there's nothing to tie them together with each other. And there's nothing to like give oversight or accountability. And so the thing that I'm really curious about later on, this is kind of like a rant, but the accountability of this, the auditing, what are they gonna do to audit it? They don't have a good process in place for getting you the funds. So what, what's the audit process look like? But I digress. The the device component. so you have an option as a

Christopher Mitchell (11:24):

Provider, there are the devices out there.

Jessica Engle (11:26):

Yeah, there are devices. You can't get one device from one provider providing that ACP and the, the subsidy from someone else. It has to be your service provider and you can only get one per household period. So if you're a service provider chooses not to provide devices, you just don't get that device. Now if they do thank them, because that is a very expensive and heavy lift. and, but I have you know, when I was doing it for the tribal government, I found a tablet that was $110. So you have to charge the consumer more than 10, less than 50. So they wouldn't let me charge 10. I had to charge $10 and 1 cent. Mm-hmm. <affirmative> as a copay for this tablet. It was a pretty decent tablet. But since then I've learned of PC Refurbishers. so there's a several and they're all over PCs for people is one of the bigger ones, and then compon and things like that. And they all have low cost refurbished laptops at a low price that can work with you on getting that as one of your device options.

Christopher Mitchell (12:33):

And they may even have like a marketplace for some of them, right?

Jessica Engle (12:35):

Yes. And so like, you know, for, for example, PCs for People has a online portal where you can go sign up for that device. You can select from several different choices, a desktop or a laptop or a Chromebook, and depending on the quality, it will depend on your copay. So they have a $11 copay or a $40 copay or something in the middle.

Christopher Mitchell (12:57):

Okay. So as a small provider, this audit issue, knowing that it may be beyond your control, and also knowing that, I mean just take our, take our word for it. You, you're Jessica, me that the FCC doesn't have a good handle of who's lying. How much, how much did it bother you knowing that you could be audited and even if you're head people on proper land tribal and the FCC might even come in to be like, no, you have to give back thousands of dollars. I think that's a big deal for an i p your size.

Jessica Engle (13:25):

Absolutely. And also it's a pass through benefit only. what really frustrated me about the ACP outreach grant final final report was that there, Jessica's Rosen, Al,

Christopher Mitchell (13:37):

S e C charm

Jessica Engle (13:38):

Yeah. She said specifically that no broadband provider or anybody that works with broadband providers can apply for that grant because broadband providers make money from being on the ACP program. And I am here to tell you, no, it's a loss, it's a loss of administrative time and it's a loss of shipping costs for devices. It's a loss of entering the information. And so if there were a situation where some of 'em were audited and having to pay back money, pay back what, you

Christopher Mitchell (14:09):

Know. Right. There's, there may be some ISPs that make money on it, the big cable and telephone companies, but most of the ISPs that are a part of it are smaller companies and they're not making money on it.

Jessica Engle (14:20):

Yeah. So in recent news, there was an article about the audit or found three different large providers, something like $450,000 worth of eligibility based on in one child who was four years old for every single one of those ISPs. And, and when I read the full article, that child's name was John Doe birthday 1118, and the last four was 1, 2, 3, 4. I know from my past life working for social services that that is a test user in a test environment for the Medicaid program. That tells me that the Medicaid program that is the test environment is live again and somebody needs to turn that off and it wouldn't be a problem. <laugh>.

Christopher Mitchell (15:07):

That's interesting insight <laugh>. Yeah.

Jessica Engle (15:09):

So I mean, like, if it were me and I was trying to get someone enrolled based on whatever eligibility and I'm sure that these bigger providers that were doing this had some sort of API in place. It wasn't a manual entry and they were just using a test dummy name, and because the system was broken, it was allowed to work. That's, to me, isn't fraud. That's an oversight on the federal government's part. Turning off the connection to the Medicaid database, that is for test use only. The thing that I do know about that database is every Sunday, all the information gets dumped because it's test should not be connected to the world.

Christopher Mitchell (15:45):

Mm-hmm. <affirmative>. Interesting. Well, thank you Jessica. You gotta run. It's been wonderful catching up with you.

Jessica Engle (15:50):

Thanks.

Ry (15:51):

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