For the first time in nearly two decades, the FCC opened a wide-ranging review of how USAC operates. The April 15 Public Notice invited comment on six topic areas spanning the full scope of USAC’s role: the current state of operations, internal management processes, audit efficiency and fund recoveries, oversight of USAC itself, board composition, and conflicts of interest. Funds For Learning filed comments on May 15, joining a broad cross-section of organizations in the record.
What Funds For Learning Said
Funds For Learning’s comments draw on fifteen years of applicant survey data, including the 2025 E-rate Trends Report, which reflects responses from 1,329 applicants across all 50 states. That evidence base shapes our view: USAC’s administration of E-rate has measurably improved, and the program is performing at historically high levels.
Applicant satisfaction with USAC reached 86.6% in 2025, up from roughly 80% in 2019. The FCC’s 2014 goals are being achieved at record rates. Ninety-five percent of applicants say E-rate is delivering affordable broadband access, a 21-point gain since 2016. EPC usability has nearly doubled over the same period. The December 2024 Government Accountability Office (GAO) report reinforced this: E-rate was the only federal program in GAO’s review with documented procedures across all nine recommended fraud-prevention practices. A program that was poorly run would not produce numbers like these.
Across fifteen years of survey data, one area of friction stands out consistently: the PIA review process. Survey respondents across multiple years describe duplicative reviewer questions, repeated requests for documentation already on file, and long waits between responses and follow-up. The 2025 cycle drew the sharpest feedback Funds For Learning has recorded, including one applicant who reported a 54-week funding approval timeline.
Our recommendations are targeted and achievable under existing FCC authority:
- Make USAC’s internal PIA shot clocks visible to applicants
- Flag previously reviewed multi-year contracts in EPC so reviewers don’t re-request documentation already on file
- Allow a single optional call between PIA reviewers and applicants when both agree it would resolve an ambiguity faster, with a written summary uploaded to EPC for the record
- Continue expanding EPC self-service, including a dashboard showing pending deadlines and open PIA inquiries
We also support standardizing recovery letters and audit communications across all four USF programs, holding recovery actions in abeyance during pending appeals, and careful, program-specific application of any sampling and extrapolation methodology before it is codified.
Our core message to the Commission: USAC’s operational baseline in E-rate is strong. Targeted refinements will serve applicants far better than structural changes that risk disrupting a decade of hard-won progress.
What Others Are Saying
The broader record reflects a more critical view of USAC. Filers included wireless and wireline trade associations (CTIA, USTelecom), rural broadband carriers (NTCA), fixed wireless and rural providers (WISPA), a beneficiary coalition (SHLB and ALA), state E-rate coordinators (SECA), a former FCC Deputy Bureau Chief filing in her personal capacity, and individual service providers. A few highlights:
- Audit reform drew the most commentary across the record. NTCA described audits stretching across years with inconsistent standards, concurrent audits running against a single small provider, and data requests arriving with 48-hour windows after months of silence. Filers broadly called for enforceable audit timelines, materiality thresholds, and a prohibition on concurrent audits of the same participant.
- On processing delays, the asymmetry between applicant deadlines and USAC’s lack of deadlines drew near-universal criticism. Filers want shot clocks covering the full lifecycle (funding decisions, appeals, and invoice disbursement), and several called for a USAC ombudsman for stuck applications.
- On board composition, most filers support broader representation and stronger conflict-of-interest rules codified in FCC regulations rather than left to the Memorandum of Understanding (MOU). SECA was the notable dissent on both points, arguing current structure and existing MOU provisions are adequate.
- Carol Mattey, who served as FCC Deputy Bureau Chief overseeing USF (2000–2005 and 2010–2017), offered a notably different overall assessment: in her view, USAC is currently performing effectively as an administrator. She proposed reducing the board to 11 members with a majority of independent directors, and moving USF contribution billing and collection in-house to the FCC entirely.
The comment window is now closed. How any resulting reforms affect E-rate applicants, particularly around PIA timelines, audit processes, and program administration, will depend on what the Commission does next. We’ll be tracking the proceeding and will report on developments as they unfold.
Funds For Learning’s full comments are available in the FCC’s Electronic Comment Filing System under CC Docket Nos. 96-45 and 97-21. Questions? Contact us at info@fundsforlearning.com.
