At the end of 2020, Congress passed the Consolidated Appropriations Act, a $1.4 trillion budget that included the largest public investment in broadband since the 2009 Recovery Act. Part of this $7 billion injection into broadband was the Emergency Broadband Benefit Program, a $3.2 billion program to be managed by the Federal Communications Commission (FCC) to subsidize broadband subscriptions by $50/month and $75/month on tribal lands for low-income households adversely impacted by the coronavirus. Currently, the FCC is trying to figure out how to operationalize this fund, and early in January 2021 released a Notice of Inquiry to ask for public comments. While we applaud the Benefit Program, the FCC must ensure the eligibility and enrollment requirements are streamlined and build a path to make the benefit permanent through Lifeline.
The Emergency Broadband Relief Fund was met with cheers from the broadband access community who long argued that broadband was inadequately subsidized for low-income households. Currently, low-income households are dependent on the FCC’s Lifeline program, which subsidizes voice or broadband by $9.25 a month. This is a measly amount, considering the average broadband bill in the U.S. is $68.38. Meanwhile, upwards of 18.5 million households lack broadband because of cost, including 60 percent of households with incomes below $35,000. This only got worse during the COVID-19 pandemic. The Pew Research Center found that one quarter of adults had difficulty paying their bills over the last year.
With the Emergency Broadband Relief Fund, Congress seemed to have heeded the interlaced calls of tens of millions of Americans who cannot weather the COVID storm without connectivity. Now that the puck has been passed, it is time for the FCC to act, and to act decisively. In doing so, the Commission must not only clarify but take the lead on three key points: eligibility, responsibility, sustainability.
Eligibility
Determining and streamlining the eligibility of potential participants is vital to help facilitate and maximize take up for those who need the subsidy. As currently laid out, the FCC proposal makes those households eligible who receive the Lifeline benefit (qualify for TANF or Medicaid), receive free/reduced school lunch, Pell Grant support, suffer significant loss of income, and/or currently participate in a providers’ COVID relief effort. While the potential eligibility for the Emergency Benefit is broad, the take up and awareness are the most important barriers to a successful implementation of the benefit.
As it stands, many benefit programs do not currently meet their potential take up rate and it’s widely known that Lifeline’s take up rate is abysmal. In the middle of a pandemic and recession, families must figure out where to get unemployment insurance, Medicaid, SNAP, LIHEAP, and Housing support. Navigating the maze of benefits is yet another challenge facing families in an economic hardship.
For this benefit ultimately to be successful, verification and ease of use for providers is necessary. The failure to rollout and provide pandemic emergency unemployment benefits last summer, which left millions waiting months for their stimulus check, should serve as a lesson to the importance of cooperation and coordination. USAC, in the past, has had minimal success in driving coordination on eligibility and take up without the support and bully pulpit of the FCC.
Responsibility
Funding for the Emergency Broadband Benefit Program will expire by September 2021 or when the fund is exhausted, whichever is sooner. Then, those receiving the benefit will see their monthly bills increase dramatically. As stated in the Act, “at the conclusion of the Emergency Broadband Benefit Program, any participating eligible households shall be subject to a participating provider’s generally applicable terms and conditions.” As it is written, ISPs have no requirement to inform recipients of these terms. It is folly to believe that those who qualify for the program in April, may suddenly be able to afford an average broadband subscription in September. As a result, billing and program transparency is required and participants should be notified of these conditions in plain language.
Sustainability
The FCC has been gradually chipping away at the Lifeline program for years. Lifeline saw the number of recipients decreased by 40 percent while only 19 percent of qualifying households take advantage of the program. We join those who argue that the FCC must increase the Lifeline Program to $50/month and increase eligibility. Moreover, all broadband providers should be required to provide a low-cost subscription tier. Jonathan Sallet at the Benton Institute suggests that such a tier should cost no more than $10 a month and offer 50mbps download/50 mbps upload. There is no technological reason for why Americans pay so much for broadband. A mandated low-cost tier would go a long way to increasing subscriptions and making these subscriptions sustainable.
Meaningful change
The Emergency Broadband Benefit Program offers a decisive opportunity to connect those who cannot afford a home broadband subscription. It offers a moment to model a meaningful broadband subsidy for Americans. The FCC must capitalize on this opportunity.
The temporary nature of the benefit will hinder incentives for cooperation, alignment, and support from agencies and partners. It is incumbent on the FCC to bring states, Federal agencies, non-profits, and community groups together to find ways to facilitate the implementation of the benefit. Whether it is through data-sharing agreements with USAC, working with the U.S. Digital Service to build a larger data verification and auto-enrollment platform, or an awareness campaign with existing benefit providers, the FCC must lead and not pass the implementation completely off to USAC.
If this initial push for the emergency subsidy is successful, it could pave the path for more permanent benefit at a higher level. If it fails, it will only give credence to the naysayers who believe this burden is fraught with too much administrative cost, fraud, and abuse. An FCC that cares to bridge digital divides must use the full authority of its pulpit to help people through the pandemic and beyond if we are to truly build back better.
Harin Contractor was the former Economic Policy Advisor to the U.S. Secretary of Labor. He also founded the Data Analytics team at the Universal Service Administrative Company (USAC).
Christopher Ali, is an Associate Professor in the Department of Media Studies at the University of Virginia and author of the forthcoming book with MIT Press, “Farm Fresh Broadband: The Politics of Rural Connectivity.”