Maximus

I.

FACTUAL AND PROCEDURAL

BACKGROUND

Lifeline provides discounted telecommunications services to eligible low-income Californians. The CPUC is authorized to administer the program

1 under the Moore Universal Telephone Service Act (Act). (Pub. Util. Code, § 871 et seq.1) The Act declares that furnishing LifeLine telephone service “should be supported fairly and equitably by every telephone corporation, and the [C]ommission, in administering the lifeline telephone service program, should implement the program in a way that is equitable, nondiscriminatory, and without competitive consequences for the telecommunications industry in California.” (§ 871.5, subd. (d).) To implement the Act, the CPUC in 1983 adopted General Order 153, which establishes administrative procedures for LifeLine. The order spans a little over 35 pages and provides information about tariff filings, provider notices, enrollment procedures, service requirements, rates, audits, and other procedures. The order sets forth customer eligibility criteria, and it explains the role of a “third-party administrator,” an entity hired by the CPUC to qualify applicants and verify their initial and continued eligibility…