The Universal Service Administrative Company (USAC), which administers Lifeline for the Federal Communications Commission (FCC), estimates that over 38.5 million households are eligible for Lifeline support. But in 2024, Lifeline enrollment was just 8.79 million. 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 currently eligible for Lifeline support will no longer be.

In a proceeding launched in February 2026, the FCC proposed new rules that could further decrease Lifeline enrollment. While some of these proposals, which are championed by FCC Chairman Brendan Carr, target fraud, others introduce new eligibility requirements and administrative burdens that could reduce enrollment among legitimate subscribers. For proposal after proposal, the FCC lacks or has not published data needed to estimate enrollment impacts.

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. The National Verifier automatically enrolls and recertifies Lifeline subscribers by checking eligibility against government databases (like Medicaid and SNAP). If automatic verification fails, applicants must submit documentation manually. The purpose of this system is to ensure that only eligible consumers participate in Lifeline, reducing mistaken and fraudulent enrollments.

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.

FCC Proposals That Could Reduce Lifeline Enrollment

On February 18, the FCC adopted a notice of proposed rulemaking (NPRM) aimed at ensuring eligible Americans receive support, that program integrity is upheld, and that service providers are complying with the Commission’s rules and regulations. Specifically, the NPRM considers ways to:  enhance program integrity to ensure Lifeline services are actually used to benefit lawful low-income Americans; optimize and improve Lifeline program processes, including possible reforms to the National Lifeline Accountability Database (NLAD) opt-out process to prevent fraud; and promote principled service provider conduct and updates to the Lifeline program rules and other affordability program rules that are no longer necessary.  

The NPRM states that the FCC seeks to ensure the Lifeline rules reflect current and best practices to support low-income Americans while ensuring efficiency, transparency, and accountability. However, many of the NPRM's proposals could well lead to decreased Lifeline enrollment.

1. Changing Lifeline From a One-Per-Household Benefit to a One-Per-Residence Benefit

The FCC is seeking comment on revisiting Lifeline's "one-per-household rule" and changing it to a "one-per-residence rule." Changing the benefit unit from "household" to "residence"—or capping the number of enrolled households per address—could eliminate benefits for residents of multi-family housing, group homes, shelters, and transitional housing where multiple independent households share a single address. This is a structurally significant change that could disproportionately affect the most vulnerable Lifeline subscribers.

No one has published a direct count of how many current Lifeline subscribers live in multi-unit housing or shared-address situations where a one-per-residence rule would displace an otherwise eligible household. The FCC's NPRM itself does not provide an enrollment impact estimate for this proposal—it asks for comment on the idea rather than proposing a specific rule with a quantified effect. The FCC does not appear to have modeled the enrollment impact before floating the proposal.

The question is how many addresses currently have two or more legitimately enrolled independent households. USAC has address-level enrollment data but has not published this breakdown publicly. According to Census Bureau data, roughly 44 percent of U.S. renters live in multi-unit buildings (with 2 or more units). Low-income households rent at significantly higher rates than the general population—approximately 70-75% of households below 135% of the federal poverty line are renters. That suggests a large majority of Lifeline subscribers are renters, and a substantial share of those live in multi-unit buildings where multiple eligible households could share a street address.

The proposal would most directly affect residents of:

• Public housing developments (approximately 900,000 HUD-assisted households)
• Section 8 and Housing Choice Voucher holders in multi-family buildings
• Group homes, transitional housing, and shelters
• Rooming houses and single-room occupancy buildings
• Multi-generational households where adult children maintain separate finances

These populations overlap heavily with Lifeline's core eligible population.

2. Secondary Consent Verification

The FCC proposes requiring subscribers to confirm enrollment or benefit transfers via text or email. While this directly addresses the instances of providers enrolling consumers without their knowledge, it also creates a technology barrier: applicants without a working phone number or email address at the time of enrollment could be unable to complete verification, raising particular concerns for domestic violence survivors who may not want enrollment confirmation sent to a shared device.

Lifeline exists precisely to help people afford phone and internet service, yet the verification requirement assumes applicants already have a working phone number or email address. The people most likely to lack both at the moment of application are exactly the people most in need of the program.

Some data points that help bound the estimate:

• The FCC's own E-Rate and Lifeline program data, combined with Pew Research Center surveys on internet and smartphone adoption among low-income Americans, consistently show that roughly 15-20 percent of adults below the poverty line do not have a smartphone. Among the 38.5 million households USAC estimates are eligible for Lifeline, the share lacking both a phone and email at the moment they would apply is likely higher than among current subscribers, because current subscribers already have phone service.
• A conservative estimate would suggest that somewhere between 5-15 percent of new applicants could face a meaningful barrier to completing secondary verification, which, against a program with 8.79 million current subscribers and millions more potentially eligible, represents at least hundreds of thousands of households.

For the domestic violence population, the National Domestic Violence Hotline estimates there are approximately 12 million domestic violence survivors in the U.S. annually. Research consistently shows that domestic violence survivors are disproportionately low-income—the National Network to End Domestic Violence estimates that financial abuse occurs in 99% of domestic violence cases. A verification text or email sent to a shared device, a monitored account, or an address known to an abuser could create genuine safety risks. The specific number of current or potential Lifeline subscribers in this situation is unknown, but the population is not trivial.

Among Lifeline's voice-only subscribers (over 160,000 households) many are elderly users who may not have email addresses at all and whose phone service is what they are applying for. This population overlaps directly with the secondary verification barrier.

3. Universal Usage Tracking and De-enrollment 

The FCC's current Lifeline usage requirement—use service at least once every 30 days or face de-enrollment—applies to free plans (in which the subscriber does not make a co-payment for service). Non-usage de-enrollment is one of the primary reasons subscribers leave the Lifeline program—providers are required to report non-usage de-enrollment results to USAC annually via FCC Form 555, and USAC's NLAD system tracks every de-enrollment transaction by reason code. However, USAC has not published a program-wide breakdown of de-enrollment by reason, making it impossible to quantify the current baseline without access to USAC's administrative data. That baseline matters, because the key question is: how much higher would de-enrollment be if the usage requirement extended to paid plans—and right now, neither the public nor policymakers have the data to answer it.

Extending the existing usage requirement to all plans—including paid plans—means any subscriber who fails to use their service at least once every 30 days could be automatically de-enrolled. This change could particularly impact elderly subscribers, people with episodic rather than continuous service needs, and those who pay for service but use it infrequently. The unintended de-enrollment risk is meaningful given that the current rule only applies to free plans.

The FCC has been tracking usage-based de-enrollment under the existing rule for free plans, and there is substantial research on usage patterns among elderly and low-income populations. However, the FCC has not published a breakdown of usage patterns across paid versus free Lifeline plans.

The NPRM specifically identifies the problem it seeks to solve: some providers have structured paid plans—annual lump-sum payments decremented monthly, or "digital wallet" arrangements—to evade the usage requirement. Extending the rule to all paid plans includes legitimate subscribers who pay for service but use it infrequently. 

The key unknown is how many current paid-plan subscribers fall into the low-usage but legitimate category versus the provider-constructed evasion category. USAC has this data by plan type, but has not published it.

Three groups face disproportionate risk:

1. Elderly subscribers are the most quantifiable. AARP research consistently shows that adults over 65 use mobile phones significantly less frequently than younger adults—a meaningful share use their phones primarily for emergencies or occasional calls rather than daily communication. Among Lifeline's voice-only subscriber population, which skews elderly, a 30-day usage requirement could trigger de-enrollment for subscribers who genuinely have the service but simply do not use it every month. With over 160,000 voice-only subscribers, this population is not trivial.
2. People experiencing homelessness face episodic usage patterns by the nature of their circumstances—phones get lost, stolen, or damaged; charging access is intermittent; and a subscriber may go more than 30 days without using service, not because they abandoned it but because of circumstances beyond their control. The U.S. Department of Housing and Urban Development estimates approximately 770,000 people experience homelessness on any given night, a population with significant overlap with Lifeline eligibility.
3. Rural subscribers in areas with poor coverage may have service nominally but face conditions—travel, seasonal work, hospitalization—that interrupt usage for more than 30 days without any intent to abandon the benefit.

If USAC's existing data shows that non-usage de-enrollment affects, say, 5-10 percent of free-plan subscribers in any given year, and if paid-plan subscribers use service at similar or lower rates, extending the rule could put somewhere between 400,000 and 800,000 additional subscribers at risk of de-enrollment annually—though this range is speculative without the underlying plan-type usage data from USAC. The more defensible framing is that the existing de-enrollment rate under the current rule provides a reasonable lower bound, and the actual impact on paid plans could be higher, given that paid plans were specifically structured to avoid usage tracking.

There is a meaningful difference between a subscriber who is not using service because a provider structured a plan to evade oversight, and a subscriber who is not using service because they are elderly, hospitalized, or in a rural area with spotty coverage. The FCC's stated rationale targets the first category, but the proposed rule catches both equally.

4. Full Social Security Number Requirement

Currently, Lifeline applicants need only provide the last four digits of their Social Security numbers (SSN). Requiring the full nine-digit SSN would strengthen identity verification but also create an enrollment barrier, particularly for households that are eligible but lack easy access to documentation or who have privacy concerns about providing a full SSN to a telecommunications provider.

This is the hardest of the FCC’s proposals to quantify because the barrier is not a single measurable condition—like lacking a phone number or not using service—but rather a combination of documentation access, institutional trust, and privacy concern that varies across populations and is not directly tracked in any administrative dataset.

The most quantifiable barrier is straightforward: some eligible households do not have their Social Security card or a document showing their full SSN readily available at the time of application. Research on benefits enrollment barriers consistently identifies documentation requirements as one of the primary reasons eligible households do not complete applications for programs like Medicaid, SNAP, and housing assistance. A November 2022 Urban Institute study found that more than one in ten adults in immigrant families reported not applying for safety net programs specifically because they were asked to provide a Social Security number, while more than one in four who did apply reported trouble providing required documentation or completing paperwork—findings that bear directly on the full SSN proposal's likely impact on eligible immigrant households. Applied to the roughly 30 million eligible but unenrolled Lifeline households, even a fraction of that percentage represents millions of households.

Among specific populations, the barrier is more acute. People experiencing homelessness frequently lack access to identity documents. A 2024 Government Accountability Office report documented that people experiencing homelessness routinely lose identity documents to theft, weather, and encampment sweeps—and face significant barriers to replacing them, including the inability to provide a residential address or pay associated fees. The consequences are severe: a national survey by the National Law Center on Homelessness and Poverty (2004) found that more than half of people experiencing homelessness were denied food stamps due to lack of photo ID, and half were denied Supplemental Security Income benefits. Requiring a full nine-digit SSN from Lifeline applicants adds another documentation hurdle for a population that already struggles to meet existing requirements. 

The documentation access problem extends beyond people experiencing homelessness: Elderly subscribers who have never needed to produce their full SSN for a phone plan may not know where their card is. Recent SNAP or Medicaid enrollees—who qualified for Lifeline through program participation—may have provided their SSN to a state agency but not retained documentation they could produce to a telecommunications provider separately.

A meaningful share of low-income households—particularly immigrant households, households with prior negative experiences with data breaches, and households in communities with historically fraught relationships with government data collection—may decline to provide a full SSN to a private telecommunications company even if they possess the documentation and are fully eligible. This concern is not irrational: telecommunications companies have experienced significant data breaches, and the aggregation of full SSNs with name, address, and contact information in provider databases creates a meaningful identity theft risk if those systems are compromised.

Qualified immigrants who have SSNs may nonetheless have complicated SSN histories—including SSNs originally issued with work authorization restrictions—that create uncertainty about whether their full SSN will trigger eligibility flags in USAC's verification systems. This uncertainty, even if ultimately resolvable, may deter applications from eligible immigrant households who cannot afford the risk of having their immigration status scrutinized by a federal database in the process of applying for phone service.

Although hard to quantify, the full SSN requirement would create a meaningful additional barrier for three identifiable populations—people experiencing homelessness, elderly subscribers with documentation access challenges, and households with privacy or trust concerns—each of which numbers in the hundreds of thousands when measured against Lifeline's eligible population. The cumulative effect across all three populations could plausibly affect millions of eligible households, though the share who would be deterred versus merely delayed is unknown.

The question here is not whether the goal is legitimate but whether the design of the requirement—specifically, collection by providers rather than solely by USAC, and application to all enrollments rather than targeted high-risk verification—is proportionate to the fraud problem it addresses. 

Responsible rulemaking would assess the marginal benefit of the specific design chosen over available alternatives before imposing a requirement that creates meaningful enrollment barriers for the program's most vulnerable populations.

5. Immigration Status Restrictions and Five-Year Waiting Period

The FCC proposes classifying Lifeline as a "federal public benefit" under Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), limiting eligibility to U.S. citizens and "qualified aliens" and potentially imposing a five-year waiting period after entry before qualified aliens could participate. This is the proposal with the greatest potential to reduce enrollment, as it would exclude currently eligible immigrants who have not yet met the waiting period—with no specified transition period for existing subscribers who would lose eligibility.

This is the proposal where a numerical estimate is most achievable—and most necessary—because the affected population is identifiable through existing federal data sources, and because the scale of potential disenrollment dwarfs any of the previous proposals.

First, a threshold issue is whether Lifeline qualifies as a "federal public benefit" under PRWORA. If it does, the consequences follow automatically from existing law—no additional rulemaking is required to impose the five-year waiting period or the qualified alien restriction. The FCC's NPRM says it "tentatively concludes" that Lifeline is a federal public benefit and seeks comment on that conclusion. The FCC is not merely proposing a policy choice but a legal interpretation that would trigger statutory consequences Congress established in 1996, and that interpretation, once adopted, would be difficult to reverse.

No federal dataset directly reports Lifeline enrollment by immigration status, because Lifeline does not currently collect that information. However, several data sources allow a reasonable estimate of the affected population:

The Census Bureau's American Community Survey tracks both immigration status and household income, allowing an estimate of how many non-citizen households fall within Lifeline's income eligibility threshold of 135 percent of the federal poverty line. According to the most recent ACS data, approximately 4.5 to 5 million non-citizen households have incomes at or below that threshold, though not all of those households would be affected, since many non-citizens are already qualified aliens who have met the five-year waiting period.

The more targeted question is how many currently enrolled Lifeline subscribers are non-citizens who are not qualified aliens, or qualified aliens who have not yet met the five-year waiting period. That number requires data Lifeline does not currently collect, which is itself a significant gap the FCC should be required to fill before adopting this rule.

Because SNAP enrollment is one of the primary pathways into Lifeline eligibility, SNAP's own immigrant enrollment data provides a useful proxy. USDA data from fiscal year 2023 shows that non-citizens represent approximately 4.4 percent of SNAP participants—but applying that figure to Lifeline enrollment would be methodologically unsound, since Lifeline subscribers qualify through multiple pathways beyond SNAP, and not all non-citizen subscribers would be affected by the proposed waiting period. The only responsible path forward is for the FCC to conduct a data-matching analysis between NLAD and U.S. Department of Homeland Security immigration records before proposing this rule—precisely the kind of analysis the FCC did not conduct before circulating the NPRM.

The five-year waiting period is a distinct and particularly acute issue because it affects qualified aliens—people who are lawfully present and would otherwise be eligible—simply based on how long they have been in the country. Refugees, asylees, and certain other humanitarian admission categories are generally exempt from the five-year bar under existing PRWORA provisions, but lawful permanent residents who arrived within the past five years would be affected. The Department of Homeland Security's immigration statistics show that approximately 1 million new lawful permanent residents are admitted annually—a population that would be ineligible for Lifeline for five years after entry regardless of income if the FCC's classification is adopted.

Immigration-related eligibility restrictions create chilling effects that extend well beyond the directly affected population. Immigrant households that are fully eligible—including households with US-citizen children—frequently disenroll from or avoid applying for programs when eligibility rules become more restrictive, out of fear or confusion about whether their participation could have immigration consequences. The Urban Institute found that over 20 percent of adults in immigrant families avoided safety net programs specifically because of concerns about green card eligibility—a chilling effect that would likely be triggered or amplified by the FCC's proposed PRWORA classification. This chilling effect is real but essentially unquantifiable in advance, which makes it important to name explicitly as an enrollment risk that goes beyond the directly affected population.

Unlike a prospective eligibility change that would affect only new applicants, this proposal—if the PRWORA classification is adopted—could immediately disqualify currently enrolled subscribers who do not meet the new requirements. The NPRM specifies no transition period. That means existing subscribers who have been receiving Lifeline benefits, potentially for years, could lose service abruptly. The enrollment impact would be immediate rather than gradual, which is a materially different kind of harm than a barrier that slows new enrollments.

This proposal is not primarily a fraud prevention measure—FCC Office of Inspector General (OIG) findings documented fraud by providers and agents, not by immigrant subscribers—but rather an immigration policy choice dressed in program integrity language. The FCC's own NPRM does not cite evidence that immigrant subscribers are disproportionately involved in the fraud the OIG documented. Imposing a five-year waiting period on lawful permanent residents does not address deceased subscriber fraud, duplicate enrollment fraud, or provider agent misconduct—the three problems the OIG actually identified. 

In addition, the FCC is proposing to require USAC to use the Systematic Alien Verification for Entitlements (SAVE) program "to conduct sufficiently thorough identity verifications to ensure that the Lifeline program has the most up-to-date and valid information on the identity of potential Lifeline subscribers." SAVE is a fee-based intergovernmental initiative administered by the Department of Homeland Security's Citizenship and Immigration Services, designed to help federal, state, tribal, and local agencies confirm citizenship and immigration status before granting benefits and licenses. The FCC is seeking comment on whether SAVE could help verify whether five years have passed since a qualified alien's entry into the U.S.—meaning SAVE wouldn't just be verifying who someone is, but about tracking when they arrived, to enforce the proposed five-year waiting period. That's a broader use of SAVE than it's typically been applied to. SAVE would be used to directly disqualify immigrants who don't meet the new criteria, so people who are currently enrolled and fail the verification would lose benefits. Routing Lifeline applications through a DHS immigration database—even framed as routine verification—signals to immigrant households that applying for phone and/or broadband service will trigger immigration scrutiny. That signal alone, regardless of whether enforcement follows, is enough to suppress enrollment among eligible households. 

FCC Commissioner Anna Gomez has noted that the SAVE database itself has serious integrity issues, citing a February 2026 ProPublica/Texas Tribune investigation finding that SAVE has out-of-date information and often misidentifies citizens as non-citizens. The FCC's proposal to use this database poses a significant risk of erroneously depriving eligible Lifeline subscribers of their benefits.

6. Voice-Only Service Phase-Out

The FCC is reconsidering whether to finally end $5.25 support for voice-only service, which affects over 160,000 subscribers—predominantly seniors and rural residents in areas with limited broadband availability. Ending this support without ensuring broadband alternatives exist in those areas could force subscribers off the program entirely.

This proposal may be the one where we can best estimate the impacts. Unlike the previous proposals where the affected population had to be estimated indirectly, the FCC already knows almost exactly how many subscribers would be directly affected—because it has been counting them and granting waivers on their behalf since 2021.

The NPRM itself identifies over 160,000 subscribers on voice-only or bundled plans that do not meet broadband standards. This is the floor of the directly affected population—subscribers who would lose their Lifeline benefit entirely if voice-only support ends and who cannot or do not transition to a broadband plan. This number comes directly from USAC's enrollment data and is not an estimate.

However, 160,000 is likely an undercount of the true impact for two reasons. First, it captures only subscribers currently on voice-only plans, not subscribers on nominally broadband-eligible plans in areas where broadband service is effectively unavailable or unaffordable even with the subsidy. Second, it does not capture subscribers who would remain enrolled on paper but lose meaningful access to service because their area has no viable broadband Lifeline provider after voice-only support ends.

Voice-only Lifeline subscribers are disproportionately concentrated in rural areas—precisely the areas where broadband infrastructure is least developed and where the fewest Lifeline-participating broadband providers operate. FCC's own broadband coverage maps, combined with USAC's provider participation data, would allow a direct analysis of how many of the 160,000 voice-only subscribers live in areas where no Lifeline-participating broadband provider currently offers service. Those subscribers face not just a plan transition but a complete loss of Lifeline coverage in their area. The FCC should conduct and share this analysis before moving forward with a phase-out. 

7. Minimum Service Standards

The FCC is seeking comment on revising the broadband data allowance formula, which has been frozen at 4.5 GB per month since 2020. The direction this goes matters for enrollment: if standards rise significantly, some providers may exit the program rather than meet them, reducing subscriber choice and potentially coverage in some areas.

The enrollment impact here is indirect—minimum service standards do not directly disqualify subscribers or create application barriers. The risk runs through provider behavior: if standards rise to a level providers cannot meet profitably, some exit the program, reducing or eliminating coverage in the areas they serve. Estimating that risk requires understanding the economics of Lifeline broadband provision, which the FCC has not published in detail.

The FCC's own behavior is the most informative data point here. The existing formula would have required 29 GB per month in 2025—a nearly 6.5x increase from the current 4.5 GB standard—and the FCC waived it. It has issued similar waivers repeatedly since 2020. Each waiver has been justified on the grounds that strict application would make Lifeline service unaffordable or cause provider exits. This is effectively the FCC's own repeated finding that the current provider economics cannot support significantly higher standards—a finding it has made four or five times without formally documenting the underlying analysis.

Lifeline broadband is heavily concentrated among a small number of providers—primarily prepaid wireless resellers rather than facilities-based carriers. This concentration matters for the enrollment impact estimate because the marginal economics of Lifeline participation are different for a large national prepaid carrier than for a small regional provider. If standards rise to a level that the large national providers can meet but smaller regional ones cannot, the enrollment impact will be geographically concentrated in the areas served primarily by smaller carriers, which tend to be rural and lower-income areas already underserved by broadband infrastructure. USAC's provider participation data would directly show this concentration.

This proposal also carries an enrollment risk in the opposite direction: If the FCC sets a new static standard at or near the current 4.5 GB—which its waiver history suggests is the likely outcome—the standard will continue to fall further behind actual broadband usage over time. Average mobile data consumption in the United States has been growing at roughly 30-40 percent per year. A static 4.5 GB standard that was already modest in 2020 becomes increasingly inadequate as a meaningful broadband subsidy over time, potentially making Lifeline service so limited relative to actual needs that subscribers choose to go without rather than maintain enrollment for a benefit that no longer covers their basic usage. This slow erosion of program relevance is a different kind of enrollment risk than provider exit—it operates over years rather than immediately—but it is real, and the FCC's own waiver history suggests the agency has been aware of it without addressing it.

A precise estimate requires provider-level economic data that the FCC has not published. What can be said directionally is:

• If standards rise significantly—toward the 29 GB level, the formula would require provider exits, which are likely, and the enrollment impact could be substantial, potentially affecting millions of subscribers in areas where exiting providers are the only Lifeline option. The FCC's own repeated waivers suggest it believes this risk is real.
• If standards remain near 4.5 GB or rise modestly—which the waiver history suggests is the most likely outcome—the immediate enrollment impact is minimal, but the program's long-term relevance as a meaningful broadband subsidy continues to erode.

In this proposal, the FCC has been implicitly generating enrollment impact data for five consecutive years through its waiver process and has simply not published it. Every waiver decision required the FCC to conclude that higher standards would harm the program—and therefore required some analysis of provider economics, subscriber impact, and coverage risk. The fact that this analysis has been conducted repeatedly in the waiver context but never formally published or subjected to public comment is the most direct example in the entire NPRM of the pattern we see: consequential decisions about a program serving millions of low-income households being made without the transparency that responsible rulemaking requires.

How States Help People Into Lifeline and How the FCC Proposes to Change That

Agreements between the FCC, USAC, and states and territories allow quick verification of Lifeline eligibility. Nearly 23 percent of Lifeline subscribers are verified through these state connections.

In addition, three states—California,¹ Oregon, and Texas—have had special permission from the FCC to use their own Lifeline eligibility verification system instead of the federal system.² In 2025, nearly one-quarter of Lifeline subscribers (24.43%, 2,147,610 total) were verified by these three states.

In November 2025, the FCC’s Wireline Competition Bureau decided to remove California's special permission to use its own Lifeline eligibility verification system instead of the federal system because a new state law eliminated a requirement that applicants provide their Social Security number (or any part of it) when applying for California's LifeLine program.³ The California law creates conflicts with federal requirements that mandate collecting the last four digits of Social Security numbers and sharing eligibility data with federal administrators. The law prohibits the California Public Utilities Commission (CPUC) and service providers from sharing applicant or subscriber information with the federal government without a court-issued subpoena or warrant.

In early 2026, the FCC also proposed to end the permissions for Texas and Oregon to run their own verification systems. Ending opt-out status for Texas and Oregon would bring those states into the federal National Verifier system. For most legitimate subscribers, the transition should be neutral, though there is a risk of service interruption during the changeover and potential loss of the ability to apply for state and federal benefits simultaneously. The added hurdles could mean fewer eligible households apply for and enroll in the federal and state programs.

Is Serving Lifeline-Eligible Households the Priority?

Lifeline exists because Congress determined that access to telecommunications services is essential to participation in modern economic and civic life. The proposals examined here—individually and collectively—would make it harder for eligible households to enroll, easier to lose benefits, and more likely that immigrant and elderly subscribers never apply in the first place. Some of these changes may be warranted. But warranted changes require evidence, and the FCC has not provided it.

For each proposal, the agency has access to data that would allow a meaningful enrollment impact estimate. It has not published that data, has not explained why, and has not committed to doing so before adopting final rules. That is not a technicality. It is a choice—and it is a choice that will be felt most acutely by the low-income households the program was designed to serve.

The Trump Administration's One Big Beautiful Bill is shrinking the universe of people eligible for Lifeline. And the FCC's proposals are making it harder for eligible people to enroll. That one-two punch is part of what FCC Commissioner Anna Gomez has called "a war on the poor."

Additional Reading

• How the Trump Administration is Narrowing the Path to Lifeline, Part I: The One Big Beautiful Bill
• 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. Late in 2025, California’s permission was revoked and the FCC is now proposing to revoke permission for Oregon and Texas.
2. The National Lifeline Accountability Database and  Lifeline National Eligibility Verifier.
3. California runs its own separate "LifeLine" program with state funding. LifeLine is also a monthly discount on basic wireline or wireless phone service, which can help lower monthly bills by removing certain fees and taxes. Participants also get free 411 and 911 access, and can receive additional benefits through partner programs. Similar to the federal Lifeline program, consumers can qualify for LifeLine based on participation in certain government assistance programs—such as Medi-Cal, SNAP (CalFresh), SSI, or the National School Lunch Program—or based on household income.

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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