Reconsideration Of Subscriber-Level ACP Data Collection

A key aspect of the FCC's ACP Transparency Data Collection rules may be in doubt if the FCC takes up a recent petition for reconsideration. In its Fourth Report and Order and FNPRM, the FCC adopted an aggregate-level approach for collecting ACP subscriber pricing and plan information, finding that ACP providers should submit ACP subscriber data grouped by each unique plan for a given geographic area (such as by state) rather than submitting that data through National Lifeline Accountability Database (NLAD) at the time of enrollment. Relying on provider comments discussing the administrative burdens of subscriber-level data collections, the FCC reasoned that "the subscriber-level approach as proposed by the Commission may conflict with the statutory requirement to stand up an annual collection and may be too administratively burdensome for subscribers and providers, particularly with respect to obtaining subscriber consent to the collection of