The Federal Communications Commission’s (FCC) Lifeline program provides a subsidy to qualifying low-income consumers to help them afford the monthly cost of phone and/or internet services.¹ Lifeline’s goal is to ensure that low-income households have access to essential communication services for many aspects of modern life, including employment, education, and healthcare. The Universal Service Administrative Company (USAC), which administers Lifeline for the FCC, estimates that over 38.5 million households are eligible for Lifeline support. But in 2024, Lifeline enrollment was just 8.79 million. [That's an enrollment rate of 22 percent, which is lower than the 44 percent enrollment rate that the Affordable Connectivity Program achieved when it ended in 2024.] Although Lifeline isn’t reaching many of the households it was designed to help, recent policy changes championed by the Trump Administration may mean millions of people who currently qualify for Lifeline support will lose their eligibility.

Legislation known as the “One Big Beautiful Bill,” signed into law July 4, 2025, is a sweeping tax-and-spending package that permanently extends and expands the temporary individual income and estate tax provisions enacted in the Tax Cut and Jobs Act (TCJA) of 2017. The law also introduces targeted temporary deductions for tip income, overtime pay, and senior taxpayers between 2025 and 2028; enacts large business tax cuts, most notably by providing permanent full expensing of many forms of investment; and increases spending on border security and defense. The law’s estimated $3.4 trillion cost over the next 10 years (and more than $4 trillion when accounting for additional interest on the national debt) are partially financed by cuts in clean energy incentives and Medicaid, the Affordable Care Act, the Supplemental Nutrition Assistance Program (SNAP—also known as "food stamps" or EBT), and other programs that serve low-income households.

This is the first of two articles looking at how Lifeline participation may be impacted by changes to Medicaid and SNAP, as well as proposed Lifeline rules changes recently proposed by the Federal Communications Commission (FCC).

Background: The National Lifeline Verifier

The National Lifeline Verifier (National Verifier) is a centralized, FCC-established system managed by USAC that determines an applicant’s eligibility for the federal Lifeline program. When a person submits a Lifeline application, the National Verifier first attempts to automatically confirm their eligibility by checking whether the applicant participates in other government programs, like Medicaid and SNAP. If yes, the National Verifier confirms the applicant’s eligibility for Lifeline. If no, National Verifier requests additional documentation from the applicant, and USAC undertakes a manual review of the applicant’s information. This process streamlines the Lifeline enrollment where possible while still ensuring that only eligible Americans participate.

By way of example, in the third quarter of 2025, USAC received 3,344,923 Lifeline applications. Nearly half (45.53%) of those applications qualified automatically, whereas under 5 percent qualified through manual documentation review. Of the remaining applications, 1,656,042 (49.51%) applications were determined to be “Not Qualified” because they did not meet Lifeline program criteria and were not resolved by the applicant within 45 days.²

How Do People Demonstrate that They are Eligible for Lifeline?

Consumers qualify for Lifeline by demonstrating low annual incomes or participating in a qualifying program, including Medicaid, the SNAP, Supplemental Security Income (SSI), Federal Public Housing Assistance (FPHA), or Veterans/Survivors Pension Benefits.

Income

Consumers may qualify for the Lifeline program if they have a gross household income at or below 135 percent of the Federal Poverty Guidelines. For 2026, that means:

Although Lifeline is designed specifically to help low-income households, only 2 percent (roughly 154,000) of Lifeline subscribers demonstrated their eligibility through this route.

Benefit Program Participation

Consumers may be eligible for the Lifeline program if they participate in a qualifying program. This is the most common path for Lifeline participants to demonstrate eligibility. In 2025, for example, nearly 41 percent of Lifeline subscribers (approximately 3.6 million households) verified their eligibility through Medicaid participation, and over 8 percent (743,000) did so through SNAP participation.

1. Medicaid

Medicaid is a joint federal-state program in the U.S. that provides free or low-cost health coverage to Americans with limited income and resources. The program covers eligible low-income adults, children, pregnant women, elderly adults, and people with disabilities. Eligibility and services vary by state. Medicaid covers roughly one in five Americans. As of early 2026, approximately 76 million people are enrolled in Medicaid and the Children's Health Insurance Program (CHIP) nationally.³ 

Medicaid eligibility is generally based on having low income, limited assets, and meeting specific criteria regarding age, pregnancy status, disability, or household size, with rules varying by state. In many states, adults under 65 with incomes at or below 138 percent of the federal poverty level qualify, while children and pregnant women often have higher limits.

Cuts to Medicaid

The One Big Beautiful Bill cuts Medicaid spending by changing the program and making the largest cut in the program's history (approximately $990 billion over 10 years). Starting in January 2026, the law eliminated enhanced federal funding for states that chose to expand Medicaid.⁴ This will likely deter additional states from expanding coverage, closing an avenue to increase Medicaid coverage and Lifeline eligibility.

Beginning in January 2027, states will be required to conduct eligibility checks for people covered under the Medicaid expansion every 6 months—up from the current 12-month requirement. The One Big Beautiful Bill also reverses course on a 2024 rule designed to make it easier for people to enroll in and maintain Medicaid coverage.

The new law conditions Medicaid expansion coverage on whether beneficiaries work, volunteer, or participate in work-related activities for 80 hours per month or are enrolled in school at least half-time.⁵ New Medicaid expansion applicants must demonstrate they meet this requirement before applying. Enrollees must demonstrate compliance between each eligibility redetermination.⁶ 

Taken together, these changes will disqualify current Medicaid enrollees and shrink the total Medicaid-eligible population. The Congressional Budget Office estimates that 11.8 million people will lose Medicaid coverage due to the bill's changes. This decrease will likely affect Lifeline participation, as Medicaid is the primary pathway to enrollment.

2. SNAP

The Supplemental Nutrition Assistance Program (SNAP) provides food benefits to low-income families to supplement their grocery budget so they can afford the nutritious food essential to health and well-being. SNAP is federally-funded and state-administered, and is designed to be “countercyclical,” that is, as the economy worsens, SNAP enrollment increases.

To get SNAP benefits, a person must apply in the state in which they currently live, and they must meet certain requirements, including resource and income limits:⁷

• Generally, households must meet federal income and asset tests, typically having a gross monthly income at or below 130% of the federal poverty line. ⁸
• Generally, households must have limited resources, such as $4,500 or fewer countable assets for households with elderly or disabled members, and $3,000 or less for others.⁹
• Households must also meet residency, citizenship, and work requirements. 
• Some categories of people are not eligible for SNAP regardless of their income or assets, such as individuals who are on strike, all people without a documented immigration status, many immigrants with lawful immigration statuses,¹⁰ some students attending college more than half-time, and certain people with drug-related felony convictions in some states.

As of 2025, the program was helping 42 million Americans buy food each month. Seventy (70) percent of those participants are elderly, disabled, or children. Looking at state-by-state participation, there tends to be a higher percentage of participants in the Southern and Southwest regions of the country, largely due to larger populations of families with lower incomes.¹¹

Cuts to SNAP

The One Big Beautiful Bill imposes stricter work requirements on SNAP participants.¹² For the first time, adults aged 55-64, as well as those with children aged 14 or older, are subject to these rules. They must work a minimum of 20 hours per week or they will receive benefits for a maximum of 3 months over 3 years. Previously, such requirements applied only to able-bodied adults without dependents aged 18 to 54. These expanded work requirements create a significant paperwork burden, as affected individuals must submit monthly documentation to the state, which must then review and process that information.

Research on existing work requirements suggests the new rules will create significant administrative attrition—not just for those who fail to meet the work standard, but for eligible people who get caught in paperwork. Earlier this year, the National Bureau of Economic Research found that SNAP Work Requirements for Able-Bodied Adults Without Dependents increase the likelihood of new applicants being denied benefits for procedural reasons. New applicants subject to the work requirements are 8 percentage points more likely to be denied for procedural reasons. Similarly, in 2025, the Urban Institute found that nearly one in four adults ages 18 to 64 in families receiving SNAP (24 percent) reported that their benefits were stopped or interrupted during the last year. This share included one in eight adults (13 percent) who lost benefits because of problems recertifying their eligibility on time. The most common reasons for benefit loss because of recertification challenges included not having enough time to recertify after getting a notice (40 percent) or not receiving a notice from the state (32 percent). Adults were more likely to experience benefit interruptions if they were working, living with children, or in younger age groups.

The One Big Beautiful Bill's SNAP work requirements and increased administrative pressures for states are expected to increase the risk of benefit loss for families nationwide.

Individuals aged 18 through 64 are limited to three months of SNAP benefits every three years unless they are working, volunteering, or in a work or training program at least 20 hours a week.¹³ Some individuals are exempt from this work-reporting requirement (also referred to as a time limit). They include people who are determined to be physically or mentally unfit for work, are pregnant, live with children under age 14 in the household, or are American Indian or Alaska Native, among others.

The Congressional Budget Office estimates that the provisions of the One Beautiful Bill will reduce participation in SNAP by roughly 2.4 million people in an average month over the 2025-2034 period. Of those people, about 800,000 will be able-bodied adults through age 64 who do not live with dependent children. Another 300,000 will be able-bodied adults ages 18 to 64 who live with children who are age 14 or older. And roughly 1 million will be able‑bodied adults ages 18 to 54 (or 18 to 49, starting in 2031) who do not live with dependents but who, in CBO’s projections, would have received a waiver from the work requirements.

Taken together, these changes will result in millions of people losing access to SNAP—and with it, one of the primary pathways into the FCC's Lifeline program.

The Shrinking Universe of Lifeline Eligibility

Although over 38 million households may be eligible for Lifeline support, the One Big Beautiful Bill could mean millions—up to 14 million people (roughly 11.8 million from Medicaid cuts and 2.4 due to SNAP cuts, with some overlap)—will soon lose their eligibility. These changes come as the prices of everyday essentials are at the top of Americans’ concerns.

In our next article, we'll look at changes to the Lifeline program championed by FCC Chairman Brendan Carr that may further limit Lifeline participation. 

Additional Reading

• How the Trump Administration is Narrowing the Path to Lifeline, Part II: The FCC
• FCC to Vote to Open New Lifeline Proceeding
• Chairman Carr Sees Dead People
• What the Inspector General Found Out About Lifeline
• What Did the FCC Just Do to California?

Notes

1. Eligible households receive up to $9.25 off their monthly bill (up to $34.25 on qualifying Tribal lands) to ensure access to essential communication services.
2. An applicant can have multiple applications. A qualified application does not equate to enrollment in Lifeline. The applicant must select and enroll in service with a participating Lifeline service provider.
3. While enrollment has declined by about 19% from its March 2023 peak due to post-pandemic eligibility redeterminations, it remains about 6% above pre-pandemic levels. 
4. The Affordable Care Act (ACA) expanded the number of Americans who are eligible for Medicaid and increased the federal government’s contribution toward covering these new enrollees. Starting in 2014, states became eligible for this additional federal funding if they expanded Medicaid eligibility for all adults up to 138 percent of the federal poverty level ($28,207 for a family of two, as of 2024). The ACA also made it easier for people to enroll in Medicaid, such as by eliminating the need for in-person interviews, reducing the amount of information applicants need to provide, and using data from other federal and state agencies to electronically verify eligibility information. So far, 40 states, along with Washington, D.C., have expanded Medicaid as allowed under the ACA. The federal government pays for 90 percent of the coverage costs for new enrollees under the expansion; states pay for the remaining 10 percent. See Akeiisa Coleman and Sara Federman, “What Is Medicaid’s Value?” (explainer), Commonwealth Fund, Jan. 14, 2025. https://doi.org/10.26099/nrxs-8q60 
5. Unless they qualify for and receive an exemption based on characteristics such as pregnancy, medical frailty, caring for a disabled family member, being a parent of a child under 14, members of federally recognized tribes, people who are incarcerated or were recently incarcerated, people living in counties with high unemployment or a declared disaster, and those participating in substance use treatment programs.
6. The One Big Beautiful Bill requires states to implement work requirements starting January 2027. States may request waivers that advance implementation or exemptions that delay the implementation deadline to January 2029.
7. SNAP income and resource limits are updated annually.
8. SNAP counts cash income from all sources, including earned income (before payroll taxes are deducted) and unearned income such as cash assistance, Social Security, unemployment insurance, and child support. Net income, or household income after deductions are applied, must be at or below the poverty line, unless they are working, volunteering, or participating in a work or training program.
9. Assets are resources that could be available to the household to purchase food, such as amounts in bank accounts. Items that are not accessible, such as the household’s home, personal property, and retirement savings, do not count. Most automobiles do not count. See Center for Budget Priorities, “A Quick Guide to SNAP Eligibility and Benefits” (October 3, 2025) https://www.cbpp.org/research/food-assistance/a-quick-guide-to-snap-eligibility-and-benefits
10. Under the One Big Beautiful Bill, only U.S. citizens, lawful permanent residents (after a five-year waiting period, if applicable), people granted Cuban or Haitian entrant status, and people who live in the United States under a Compact of Free Association (COFA) can qualify for SNAP. In some cases, the income and resources of the immigrant’s sponsor count toward the immigrant’s eligibility. For detailed information on non-citizens’ eligibility for SNAP, see https://www.fns.usda.gov/snap/recipient/eligibility/non-citizen
11. “Explainer: Understanding the SNAP program—and what cuts to these benefits may mean” John F. Kennedy School of Government, Harvard University (November 10, 2025) https://www.hks.harvard.edu/faculty-research/policy-topics/social-policy/explainer-understanding-snap-program-and-what-cuts
12. The new law will also reduce SNAP funding by approximately $186 billion over 10 years—a 20% cut that marks the largest reduction in the history of the program.
13. Prior to the One Big Beautiful Bill, only individuals aged 18 to 54 without children in the household were subject to the time limit, and veterans, former foster youth, people experiencing homelessness, and people living with someone under age 18 were exempt. 

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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