Lifeline annual recertification

How do we run the Lifeline annual recertification so subscribers are reminded, recertify on their phone, and those who do not are de-enrolled on the required schedule?

Run recertification as a clock per subscriber with the verifier's result applied by rule. Before each subscriber's anniversary, Callvu opens the recertification, sends the reminders the rules require with a link to recertify on their phone (the certifications, the continued eligibility basis, the household confirmation), or submits the automated eligibility re-check to the national verifier where it performs one, chases the subscriber through the notice period with the required number and form of attempts, reads and checks a recertification on arrival, classifies the outcome (recertified, failed the re-check, no response), routes a dispute or a subscriber the rules treat specially to the program desk in the Decision Desk, de-enrolls a subscriber who did not recertify within the period in the national database and the BSS, the system of record, with the de-enrollment notice, and records every attempt for audit.

In scopeSimpleCallvu moves: chase and verify, decide, write back

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Last updated November 7, 2026.

The problem today

Four hundred subscribers were de-enrolled on the same day, most of whom would have recertified if the reminder had reached a phone they still used.

Today, without Callvu

Recertification is where Lifeline carriers lose subscribers who still qualify and keep ones who do not. A letter to an old address, a call to a disconnected number, a thirty-day window the subscriber never knew about, then a mass de-enrollment that a regulator reads as a failure of outreach. Or the opposite: subscribers never recertified and benefits claimed for years, which the audit reads as improper payments.

The FCC's Lifeline rules require the carrier (or the national verifier, where it conducts the recertification) to recertify every subscriber's continued eligibility annually, to attempt the automated re-check first where available, to notify subscribers who must recertify and give them the notice period with the required attempts, and to de-enroll within the period those who do not respond or fail, with the de-enrollment notice. The attempts, the responses and the outcomes must be recorded for audit. Each subscriber is a clock.

A recertification the subscriber can complete on the phone they actually use, reminded on the schedule, keeps the qualified and removes the rest on time.

How it runs

From the requestto the system of record.

A subscriber's annual recertification date approaches (from the enrollment anniversary in the BSS and the national database). Callvu opens the recertification for that subscriber.

Subscriber: Receives the reminders and recertifies on their phone, or responds to the verifier's request.
National verifier: Performs the automated re-check where available and holds the enrollment status.
Program desk: Decides disputes and special cases in the Decision Desk.
Callvu: Opens the clock, submits the re-check, reminds, chases, reads and checks, classifies, routes, de-enrolls and records.

Open and re-check
The subscriber's recertification is opened on the schedule the rules set before the anniversary; where the national verifier performs an automated eligibility re-check against the program databases, it is submitted first, and a subscriber it confirms is recertified by rule without contact; a subscriber it cannot confirm enters the notice period.
Chase and verify the subscriber
The subscriber is notified that they must recertify, with a link to do it on their phone (the certifications in the required form, the continued eligibility basis and any document the verifier requires, the household confirmation), through the channels on the account and in the subscriber's language; the reminders continue through the notice period with the number and form of attempts the rules require, each recorded; a recertification is read on arrival and checked (the certifications complete, the document matching the basis) and submitted to the verifier where it decides.
Classify and decide
The outcome is classified: recertified, failed the re-check or the document review with the reason, or no response at the end of the period; a subscriber who disputes a failure, a subscriber whose contact details all failed, or a case the rules treat specially (a Tribal subscriber, a subscriber mid-transfer) goes to the program desk in the Decision Desk with the attempts and only the allowed outcomes: extend within the rules, refer to the verifier's appeal, or de-enroll.
De-enroll or confirm, and write back
A subscriber who recertified is confirmed in the national database and the BSS with the next recertification date; a subscriber who failed or did not respond is de-enrolled in the national database and the benefit removed from the account in the BSS, the system of record, within the period the rules set, with the de-enrollment notice and the information on re-applying; every attempt, response and outcome is recorded for the program's audit.

Where it ends: Every subscriber was re-checked or reminded on the rules' schedule through channels they use, the qualified recertified on their phone, the rest were de-enrolled on time with the notice, and the record of every attempt exists for the audit. The Decision Trace shows the re-check result, the attempts and any decision; the Audit Trace shows each reminder, response and de-enrollment with time.

Runtime enforcement

What is enforcedwhile the work runs.

The regulations preloaded in Callvu Studio and the bank's own policies, applied as steps that run, not lines in a binder. A step that breaks a rule does not run, so a completed run was compliant.

Regulations

FCC Lifeline rules (47 CFR 54.410(f) and 54.405(e)(4)): Every subscriber's eligibility must be recertified annually; the national verifier (or the carrier where it still performs it) first attempts an automated re-check against the qualifying program and income databases, and a subscriber who cannot be confirmed must be notified and given 60 days to recertify with the required certifications; a subscriber who does not respond or who fails must be de-enrolled within five business days after the 60-day period, with a written notice; the carrier must keep records of the recertification attempts and the results for the program's retention period and the de-enrollment is reported to the national database.
Lifeline notice and outreach requirements (47 CFR 54.405(e) and the USAC recertification procedures): The recertification notice must be in the form and through the channels the rules and the program's procedures set, with the subscriber able to recertify by the methods offered (online, by phone, by mail or in the program's application), and the subscriber's language considered; the de-enrollment notice states the reason and the re-application path.
Non-usage and other de-enrollment grounds (47 CFR 54.405(e)(3) and 54.407(c)): Separate from recertification, a subscriber who does not use the service within the usage period is de-enrolled after the required notice, and a duplicate or an ineligible subscriber found by the verifier is de-enrolled on its notice; the same record keeps these grounds distinct.

Company policies

The automated re-check runs first; only unconfirmed subscribers are asked to recertify.
Reminders go through the channels on the account on the rules' schedule, each recorded, with the link to recertify on the phone.
De-enrollment happens on the rules' clock, by rule, with the notice; the program desk decides only disputes and special cases.
The national database and the BSS hold the outcome; the attempt record is the audit evidence.

Controls

Per-subscriber recertification clock.
Automated re-check submission and rule-based confirmation.
Multichannel reminders with attempt recording.
Recertification reading, checks and verifier submission.
Outcome classification and Decision Desk for disputes.
Timed de-enrollment with notice and audit record.

Clocks and deadlines

Notice period: 60 days from the recertification notice for the subscriber to respond.
De-enrollment: Within five business days after the notice period for non-responders and failures.
Next recertification: Set from the confirmation for recertified subscribers.

Documents and checks

The re-check submission and result
Each reminder with channel and time
The recertification as received and checked
Any program desk decision
The de-enrollment or confirmation and the notice

In the Decision Trace

The re-check result.
The attempts made and the outcome classification.
Any decision and the person.

In the Audit Trace

Each reminder with time and channel.
The response with time.
The de-enrollment or confirmation and the write.

The handoff

Between the front doorand the back office.

The front door

The reminders on the subscriber's channels with a link to recertify on their phone; the verifier's own application where the state requires.

The back office

The program desk decides only disputes and special cases; de-enrollment and confirmation run by rule.

The Decision Desk

A disputed failure, a subscriber whose contact details all failed, or a special case goes to the program desk in the Decision Desk with the attempts and only extend within the rules, refer to the verifier's appeal, or de-enroll.

Proof

In scope.Proof at scale, not one process at a time.

The kind of process Callvu runs in production for customers in this industry. Ask for a reference on this exact process. The results below are the industry's published proof; each claim code links to its record on agents.callvu.com.

More than 1,000 processes are live across Callvu customers.

Across Callvu customers

AT&T runs close to 100 processes on Callvu, used by 55,000 agents.

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Questions

What buyers ask next,answered plainly.

Does every subscriber have to respond?

No. The automated re-check confirms many without contact; only subscribers it cannot confirm are notified and given the 60-day period to recertify on their phone.

What happens to non-responders?

They are de-enrolled within five business days after the notice period, in the national database and on the account, with a notice stating the reason and how to re-apply.

What is kept for audit?

Every reminder with its channel and time, the response, the re-check result and the outcome, for the program's retention period.

Related processes

Low-income program enrollment (Lifeline)Service and billing address change Disconnect and cancellation Try it in the sandbox All telecom processes

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