Schools and libraries report that insufficient home internet access is a significant issue in 90% of American communities. Fortunately, this week, the American Rescue Plan Act became law, providing $7.1 billion in emergency E-rate funding to connect students and teachers who lack adequate home internet. Within the next 60 days, the FCC is poised to create administrative rules and begin distributing these funds to schools and libraries. Under the leadership of Acting FCC Chair Jessica Rosenworcel, and leveraging the existing E-rate program, there is every reason to expect that more students and teachers will have off-campus Internet connections in the not-so-distant future.
USING THE E-RATE PROGRAM TO CONNECT STUDENTS
It makes sense for the FCC to use the E-rate program to tackle this challenge. In fact, 82% of schools and libraries believe that the E-rate program is the most practical solution to address this need. Applicants are familiar with the program’s existing procedures and online portal; they have established accounts for authorizing and receiving payments; the program currently distributes billions of dollars securely and efficiently, with a high-level of transparency and careful oversight; and applicants trust the E-rate program to deliver positive results:
- MISSION CRITICAL: 94% of applicants consider E-rate support mission critical to Internet.
- RELIABLE: 84% of applicants say they can depend on E-rate program for support.
- SATISFIED: 81% of applicants are satisfied with the service they receive from USAC.
- PERFORMANCE: 77% of FY2020 applicants were funded within 3 weeks of the filing deadline.
Leveraging the existing E-rate program would minimize the burden on applicants; it would eliminate the unnecessary delays and risks associated with a new system and procedures; it is a good use of public resources to leverage USAC’s existing resources; and it has been done before (i.e. there is prior precedent for the E-rate program to provide emergency support for applicants.)
PRIORITIZING THE FUNDS IN A TIMELY MANNER
Funds For Learning previously estimated that $7.5 billion was needed in order to provide connected devices and secure, off-campus Internet access for remote learners. The actual need might be even higher. With $7.1 billion available, there is a good chance that more funding is needed than can be distributed. To make certain that the funds are distributed in a timely and equitable manner, where they are needed the most, Funds For Learning suggests that the FCC use the following three-step method.
SET A BUDGET CAP FOR MOST OF THE FUNDS
$6.5 billion should be designated for an application process that uses the existing online forms. Requests would be capped using the same method as the successful Category 2 budget system. Although applicants would receive a 100% discount on their services, their funding would be limited by a clear and objective standard. Using the budget cap system has the following benefits:
- EQUITABLE. It prioritizes support for communities who have the greatest need. Higher budgets are provided for applicants who support communities with more economic need and rural areas.
- COST-EFFECTIVE. It encourages and rewards cost-effective purchases. Applicants have a predictable spending limit and must choose wisely to get the most benefit.
- FASTER. It allows faster funding commitments. The award of funding to one applicant is not tied to the requests of another, allowing applications to be processed much quicker.
SET ASIDE FUNDS FOR SPECIAL CIRCUMSTANCES
While almost every community faces the challenge of insufficient home Internet access, not every challenge is the same. Some applicants face extraordinary situations that fall far outside the norm. These communities require support that is well above the average costs experienced in most communities. For these circumstances, the FCC should set establish a designated pool of funding available specifically for exceptional challenges. The funds would be available via a separate application that is manually processed. Applications would be subject to specific criteria:
- UNIQUE. Applicants would need to demonstrate the unique nature of their circumstances.
- DEMONSTRATED NEED. Priority would be given to applicants with the highest economic need and geographic limitations.
- FLEXIBLE. Applications could be funded fully, partially, or not at all depending upon the overall pool of funds.
Funds For Learning suggests that $500 million be set aside for these special circumstance applications.
SUPPLEMENTAL APPLICATION WINDOW
Finally, if there are uncommitted funds after the other applications have been processed, the FCC should open a supplemental application window to award the remaining uncommitted funds using a priority system like the first round of “special circumstances” applications.