CGM, LLC Low Income Enrollment & Fraud Management Platform

1. CGM, LLCLow Income Enrollment & Fraud Management Platform Presentation to the State of Alabama CGM, LLC - Confidential

2. State-Managed Low Income Enrollment & Fraud Management Platform Goals: Real-time, Online Enrollment, Eligibility Verification, Fraud Management Prevention Rather Than Correction Long-Term Lifeline Program Sustainability CGM, LLC - Confidential

3. Low Income Program: Proposed Enrollment & Fraud Management Platform Enrollment Portal Address Validation Duplicate Edit Check DB Name Address DOB Last 4 of SS Normalize Text Dip Against USPS and other sources 1. Phone Number 2. Existing Name/Address 3. Existing Address Only 4. Previous Historical Name/Address (LNK) ValidLifeline Account Denial Bin State Welfare DBs Prevents Ineligible/Phony Name & Address Fraud Prevents Duplicate Name & Address Fraud CGM, LLC - Confidential

4. Benefits to State of Alabama • Protect Federal Funds and Long-Term Viability of the Program by Eliminating Vast Majority of Eligibility and Duplicate Subsidy Fraud. • Provide Proactive Stewardship of the Program by Leveraging Assets Unique to the State. • Retain State Control Over the Eligibility Data & Process. • Simplifies Enrollment for Eligible Citizens, Driving State’s Take-Rate and Influx of Low Income Support Dollars. • Takes Pressure Off of the State’s Initial ETC Designation Process by Ensuring Compliance Downstream. • Could Position State for Eventual Broadband Pilot Program. CGM, LLC - Confidential

5. Benefits to the FCC & USAC • Provides the Model for No-Cost, Technology-Driven, Fraud-Free Foundation on Which Broadband Program Can be Deployed. • Solves the Self-Certification + Proof Dilemma, the Cumbersome Annual Certification/ Verification Process, and the E-Signature Debate. • Platform will Automate Much of the USAC (and State) Audit Process. • Audits Can Now be Targeted and Data Driven: Focus on Aberrations vs. Previous Random Approach. • Complaints will be researched/analyzed/verified via databases vs. taken as gospel and acted on. • The Statistical Data Available Through the Platform Will Drive Great Efficiencies in The Low Income Program: • Urban vs. Rural; Qualifying Programs; End User Movement; Desired Service Offerings; Effective Communication/Outreach Channels; Denial Reasons. Ultimately, It Will Measure the Current Levels of Fraud. • Assists the FCC considerably by Providing Near-term Stats Relative to Actual Fraud, Attempted Fraud and Fraud Avoided, resolving the primary complaint against the Low Income/Lifeline Program. CGM, LLC - Confidential

6. Benefits to the Consumer • Makes the Program/Subsidy More Accessible to Eligible, Unserved Consumers: • Simplifies Enrollment Process. • Multiple Program Entry Points – Consumer, Case Worker, ETC Service Provider. • Drive Take-Rate via State and ETC –Driven Awareness Campaign. • AL Estimated Eligibility Pool of 470,000 . Estimated Take –Rate of 276,000 (58%). • Benefits to the ETC Service Provider • Secures Lifeline Customer Base – Protects from Loss of Customers in a USAC or State Duplicate-Audit. • Significantly Simplifies the Enrollment Process, Driving Cost from their Model. • Evidences Responsible Stewardship and Would Likely Assist Their Efforts to Expand ETC Footprint. • Removes Poor/Unfair/Improper Practices from the Marketplace. CGM, LLC - Confidential

7. Additional/Optional Ways of Preventing Waste, Fraud and Abuse with the Platform: • Can Confirm Active Line Status for Reimbursement Requests. • Can Confirm Usage within a 60-day Window of Reimbursement Request. • Can Prevent Wireline Double Dip. • Can Ensure Correct Subsidy Amount Requested, by State. CGM, LLC - Confidential