The enrollment fraud was aimed at Lifeline, a program that was created to provide discounted mobile services to users with low income levels.The Lifeline program is part of the Universal Service Fund, and is being paid for by Americans by way of surcharges on phone bills.
According to a statement that the FCC has released, Total Call Mobile has apparently received $9.7 million worth of payments since 2014. The wireless carrier did this by enrolling tens of thousands of duplicate or unqualified customers. What is worse is that the company continued this practice despite clear and repeated warnings from its own employees and even compliance specialists that there was widespread enrollment fraud being committed by Total Call Mobile’s sales agents.
Based on the FCC’s findings, Total Call Mobile employed various ploys in collecting fraudulent payments, executed through over 800 of the wireless carrier’s sales agents in no less than 13 states across America. As indicated on the FCC’s Notice of Apparent Liability, Total Call Mobile sales agents sneakily took users’ ID info, enrolled individual users for multiple devices without their consent or knowledge, and then falsely stated that unqualified users are eligible to join in the Lifeline program.
With regards to duplicate sign ups, Total Call Mobile sales agents apparently made this possible by making slight changes to a user’s ID info during the enrollment process. These sales agents also allegedly enrolled unqualified users with the use of temporary Supplemental Nutrition Assistance Program (SNAP) cards, which bear no identifying names or information. As explained by the FCC, one SNAP card can be used to sign up more than one unqualified user in order to collect subsidies from the US government.
Even though Total Call Mobile made use of a third party (via CGM’s electronic platform) in processing Lifeline enrollment for users, its sales agents employed an override function to bypass denials. The FCC found that in the final quarter of 2014, 99.8 percent of the wireless carrier’s sign ups across the US involved overriding the third party electronic platform designed to detect duplicate enrollments.
Total Call Mobile can still contest the FCC’s proposed $51.1 million fine, but for certain, it can expect a long battle ahead.