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2.0

DOJ issues memo concluding that FCC Lifeline program is subject to PRWORA

  1. Original Date Announced

    May 28, 2026

    The DOJ Office of Legal Counsel (OLC) issued a memorandum opinion to the Federal Communications Commission (FCC) regarding the applicability of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) to the FCC's Lifeline program. The Lifeline program offers discounted telephone and Internet services to low-income consumers. The opinion concludes that the Lifeline program constitutes a "Federal public benefit" and a "Federal means-tested benefit" under PRWORA and thus must comply with PRWORA's eligibility and verification restrictions. It further states that collecting a subscriber's Social Security number (SSN) before enrollment does not in itself ensure compliance with PRWORA. Instead, the FCC must impose additional safeguards, such as using the SAVE tool administered by USCIS.

    Trump 2.0 [ID #2289]

    2026.05.28 DOJ - Whether FCC Lifeline Program is a Benefit Subject to PRWORA
  2. Effective Date

    May 28, 2026

Current Status

None

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