The Federal Communications Commission (FCC) has issued a Notice of Apparent Liability for Forfeiture and Order (NAL) against Total Call Mobile, Inc., which proposes a forfeiture penalty of $51 million for willful and intentional violation of the FCC’s Lifeline rules. According to the NAL, over a four-year period, Total Call Mobile received millions of dollars in improper Lifeline service reimbursements from the Universal Service Fund (USF) for duplicate and ineligible Lifeline consumers. The FCC’s investigation uncovered improper enrollment practices involving over 800 Total Call Mobile sales agents, who collectively generated tens of thousands of duplicate and ineligible consumer enrollments across at least thirteen states through various deceptive practices, including surreptitiously recording consumers’ identifying information, enrolling individual consumers for multiple phones without their knowledge, and falsely claiming that ineligible consumers met the requirements to participate in the Lifeline program. In addition to the $51 million forfeiture, the NAL requires Total Call Mobile to submit a report within 30 days explaining why the FCC should not (1) order the Universal Service Administrative Company (USAC) to suspend all Lifeline reimbursements to Total Call Mobile; (2) revoke approval of Total Call Mobile’s eligible telecommunications carrier Lifeline compliance plan; and (3) initiate proceedings against Total Call Mobile to revoke its FCC authorizations.
