Oregon Responds to FCC on Deceased and Duplicate Lifeline Subscribers

As Chair of the Public Utility Commission of Oregon (OPUC), I write to express appreciation to the FCC Office of Inspector General (OIG) for sharing the underlying death data that informed the OIG's January 26, 2026 Advisory Regarding Deceased and Duplicate Lifeline Subscribers. The opportunity to conduct an independent, Oregon-specific analysis of that data has been valuable and I submit this letter to provide additional context that offers a more complete picture of Oregon's program administration and the broader systemic issues raised in the Advisory. Staff of the OPUC (Staff) conducted a detailed, record-by-record review of all 2,220 Oregon deceased subscriber records identified by the OIG, covering the period from December 2020 through September 2025. Of the 2,220 deceased subscribers, Staff had previously and independently de-enrolled 1,014, representing 46% of OIG’s findings. Staff's analysis identified an average de-enrollment timeframe of 111 days (approximately 3.6 months), a figure directly attributable to the quarterly reporting cycle. This context is essential to understanding the enrollment patterns observed in the Advisory; the timeframe reflects an administrative reality inherent in the reporting schedule, not a deficiency in Oregon's program administration. Recognizing this limitation, the OPUC is entering into an agreement with the Center for Health Statistics to receive vital records on a daily basis, which will substantially reduce deenrollment timeframes and further guard against enrollments of deceased persons.