On November 20, the Federal Communications Commission's Wireline Competition Bureau released its decision to change how the Lifeline program is run in California. Specifically, the FCC decided to remove California's special permission to use its own Lifeline eligibility verification system instead of the federal system (the National Lifeline Accountability Database and  Lifeline National Eligibility Verifier). Here's a quick look at the FCC's order and what it means for California.

Lifeline and LifeLine

Lifeline is a federal program that helps low-income Americans afford phone and internet services. The program provides monthly discounts to eligible people. The federal Lifeline program provides up to a $9.25 monthly discount on service for eligible low-income subscribers and up to $34.25 per month for eligible subscribers on Tribal lands.

Households are eligible for the federal Lifeline benefit if their income is at or below 135 percent of the Federal Poverty Guidelines or if a member of the household participates in one of these programs:

• Supplemental Nutrition Assistance Program (SNAP)
• Medicaid
• Federal Public Housing Assistance
• Supplemental Security Income (SSI)
• Veterans Pension Benefits
• Certain Tribal Assistance Programs

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. For June 1, 2025 to May 31, 2026, a one-person household making $24,000 or less and a four-person household with an income below $49,600 would be eligible for LifeLine.

Discounted home phone services available to California LifeLine participants may include the following:

• Specific Support Amount Effective January 1, 2024 - Up to $19.00
  • Monthly flat rate service discount of up to $19.00¹
  • Monthly cell phone service discount of up to $19.00 
• Service connection discount of up to $39
• Service conversion discount for home phone services of up to $39  
• Free from paying the public purpose program surcharges, CPUC’s user fee, federal excise tax, local franchise taxes, and State 911 tax associated with your phone service
• Discounts on two telephone lines if you use a teletypewriter (TTY) or are part of the Deaf and Disabled Telecommunications Program. If you use a TTY, you must have immediate and continuous access to it. If the Deaf and Disabled Telecommunications Program did not give you other proof, provide a copy of a medical certificate indicating your need for a TTY is required to receive the discount on the second home phone line.

NLAD and the National Verifier are integrated, complementary components of a single electronic system designed to protect the integrity of the federal Lifeline program. In 2012, the FCC created the NLAD to prevent, detect, and eliminate duplicative Lifeline support provided to individuals and households. Because some states had developed their own processes for eliminating duplicative support, the FCC permitted states meeting specified conditions to “opt-out” of the use of the NLAD and instead use their own systems to detect and eliminate duplicative support. To opt out, a state was required to validly certify that it had a comprehensive system in place to check for duplicative federal Lifeline support that was at least as robust as the FCC’s process.  In 2013, the FCC granted California’s request to opt out of the NLAD; the FCC found that California demonstrated that, at the time, its duplicate detection system was at least as robust as the NLAD.  The grant of opt-out status was conditioned on the CPUC’s adoption of a third-party identity verification service. 

Enter California Law AB 1303

On October 6, 2025, Governor Gavin Newsom (D-CA) signed Assembly Bill No. 1303, amending the sate's public utilities code. The law:

1. Eliminates Social Security Number Requirement for applicants to provide their Social Security number (or any part of it) when applying for California's LifeLine program. This makes it easier for eligible residents to access the program regardless of immigration status.
2. Strengthens Privacy Protections: The law prohibits the California Public Utilities Commission (CPUC), its staff, the LifeLine program administrator, and service providers from sharing applicant or subscriber information with the federal government without a court-issued subpoena or warrant. Protected information includes:²

• Name, address, and contact information
• Date of birth
• Social Security numbers
• Income information
• Information about qualifying public assistance programs
• Government-issued identification documents

Supporters described AB 1303 as protecting low-income Californians from "government overreach" and ensuring that vulnerable communities can access essential phone services without fear that their personal information will be shared with federal authorities, particularly immigration enforcement.

However, California's new law creates conflicts with federal requirements that mandate collecting the last four digits of Social Security numbers and sharing eligibility data with federal administrators.

On October 27, 2025, Senator Ted Cruz (R-TX) wrote letters to FCC Chairman Brendan Carr and U.S. Attorney General Pam Bondi pointing out that A.B. 1303 specifically extends the Lifeline subsidy to “individuals not lawfully present in the United States.” He said California law explicitly prohibits the CPUC from sharing, disclosing, or otherwise making information accessible to immigration authorities in apparent violation of federal law. Sen. Cruz wrote, "As you know, federal law generally prohibits aliens who are unlawfully present in the United States from receiving federal benefits. For this reason, federal programs must remain vigilant against potential loopholes, including fraudulent documentation and automatic eligibility schemes."

Sen. Cruz added that the FCC "has a legal obligation to ensure that federal benefits it administers, such as the Lifeline program, are not given to illegal aliens."

Sen. Cruz asked Chairman Carr for the following by November 24, 2025:

1. A comprehensive review of the FCC’s current rules, practices, and procedures governing eligibility for the federal benefits under the FCC’s jurisdiction, including the Lifeline program and the benefits provided under the Safe Connections Act.14 As part of this review, please identify any loopholes or any data limitations that may compromise program integrity and increase the risk of illegal aliens receiving federal benefits. Additionally, please review Sections 1 and 2 of A.B. 1303 and determine whether these sections may hinder the FCC and the Universal Service Administrative Company (USAC) for purposes of routine audits and integrity checks.
2. An assessment of whether state-level telecommunication programs that give benefits to illegal aliens are duplicative of federal benefits and should therefore result in those federal benefits being reduced or eliminated. 
3. A detailed explanation of the mechanisms by which the FCC and USAC verify that federal Lifeline benefits are not given to non-eligible individuals or households, particularly illegal aliens, including the schedule for and results of periodic forensic audits of the program. As part of this explanation, please review whether households headed by illegal aliens can receive federal Lifeline benefits through their U.S.-born children and whether there are any current safeguards against such abuse, such as a minimum age requirement. 
4. A detailed explanation of the mechanisms used, including by the Enforcement Bureau, to hold illegal immigrants and participating providers accountable for violations, including civil and criminal enforcement.   
5. Any recommended regulatory or legislative actions needed to fully safeguard the program.  

The FCC's Decision

The FCC's Wireline Competition Bureau finds that it would not have granted California NLAD opt-out status if the provisions of AB 1303 that make optional the collection of the last four digits of the social security number had been in place at that time. The Bureau says it's concern is "it may be possible for prospective subscribers to receive duplicative support by intentionally or inadvertently providing incorrect information in their Lifeline applications."

The Bureau also raises additional concerns about how California has checked eligibility for Lifeline over the years:

• For six years, California was in violation of a 2019 rule change that the FCC enacted, requiring Lifeline subscribers to undergo annual recertifications,
• California required 18 months to add the Veterans Pension and Survivors Benefit as a qualifying program to its application,
• California sought delays of over two years to implement basic application and eligibility changes mandated in FCC's 2016 Lifeline Report and Order, and 
• CPUC missed deadlines for adopting a third-party identification verification system.

These additional concerns factored into the Bureau's decision in this order:

Starting February 1, 2026, California will lose its special permission to check eligibility for federal Lifeline applications using its own state system. Instead:

• All California residents applying for federal Lifeline benefits must use the federal "National Verifier" system
• Phone and internet companies in California must switch to federal processes for enrolling customers in Lifeline
• The federal system will handle checking whether people qualify and preventing duplicate benefits

FCC Chairman Brendan Carr said,

Via social media, Chairman Carr said, "Senator Cruz sounded the alarm on California's decision to use taxpayer money to buy smartphones for illegal aliens. The FCC is pleased to take this action after @SenTedCruz letter highlighting the issue."

The Impact

The FCC's decision applies only to the federal Lifeline program: California's LifeLine program is not affected—it can continue operating with state funds and using its own verification system.

People living in California who qualify can still get federal Lifeline benefits, but their eligibility must be verified through the NLAD and the National Verifier.

Previously, the two programs worked together. A household could apply once and get the benefits of both Lifeline and LifeLine, combining them to make connectivity more affordable. Now, a household must apply to two programs and manage the benefits separately.

Notes

1. Does not account for Extended Area Service rates; a higher level of support is available in these areas. 
2. The law allows sharing information only for:

• Inclusion in public phone directories (if the subscriber consents)
• Directory assistance services
• Emergency 911 calls
• Debt collection (under CPUC supervision)
• Law enforcement responses to lawful court processes
• Other purposes required by the CPUC's regulatory authority

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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