The following is an edited excerpt from Recommendations and Best Practices to Prevent Digital Discrimination and Promote Digital Equity submitted to the Federal Communications Commission (FCC) by the Working Groups of the Communications Equity and Diversity Council on November 7, 2022. In a Notice of Proposed Rulemaking on the prevention and elimination of digital discrimination, the FCC proposed to adopt, as guidelines for states and localities, these best practices.

1. Make low-cost broadband available to low-income households through government benefit programs, in combination with internet service providers’ low-income programs.

The FCC should continue to coordinate with State and localities to maximize the impact of programs to make low-cost broadband available. For example, the Emergency Broadband Benefit Program’s (EBB) success ushered in the creation of the Affordable Connectivity Program (ACP) reflecting Congress’s recognition that this targeted subsidy should not be limited to a short-term pandemic program. ACP is available to a wide range of low-income households (including those receiving benefits from Medicaid, Federal Public Housing Assistance, and the National School Lunch Program) and the Infrastructure Investment and Jobs Act avoided requirements, such as the eligible telecommunications carrier requirement that could have limited service provider participation.

Additional guidelines are needed to set standards for quality of service as well as marketing and communication to reach the target audiences more effectively based on lessons learned from the implementation of EBB and ACP to date.

It is also essential for the FCC to improve the ability of its Universal Service Fund (USF) programs to meet the goals of universal deployment, affordability, adoption, availability, and equitable access to broadband. While the Infrastructure Investment and Jobs Act provides critical investments, it does not eliminate the need for a robust Lifeline program, continued support for educational and rural healthcare connectivity, and, in all probability, some form of ongoing high-cost support. To ensure these vital programs truly meet the FCC's mandate, it will be critical for the commission to carry out its plan to evaluate the scope of its authority over telecommunications carrier contributions, consider further actions on that basis, and for Congress to provide the FCC with any additional tools needed to make changes to the USF contributions methodology, as the FCC recommended in its recent report to Congress on the future of the Universal Service Fund.

2. Build on the success of existing benefit programs that allow low-income households to apply a credit to an internet service of their choice.

States and localities should use available funds to supplement federal broadband benefits for low-income households. For example, Maryland’s Emergency Broadband Benefit Subsidy Program offers those approved for ACP an additional $15 a month on top of the federal discount for up to one year. Broadband providers, states and localities, and community organizations should have intentional strategies to make sure broadband benefit programs are easily accessible and available to anyone that meets the eligibility criteria for the programs.

3. Raise awareness about connectivity programs for programs among eligible households.

States and localities administering low-income benefit programs (such as SNAP and Medicaid) should inform consumers about broadband benefits such as ACP and Lifeline while the consumers are applying for the benefit-qualifying program. 

4. Strengthen marketing and communications about available federal and state connectivity programs and other programs that target low-income or other unconnected members of a community.

Program materials should explain offerings or programs in clear, nontechnical language. Program materials and support should be shared in multiple languages. State and local leaders should also explore providing translation services for consumers seeking to sign up for service. Broadband providers' customer service teams should be aware of available programs and be able to redirect a potential customer to the targeted support team. Providers can also help by having call center teams that are assigned to sponsored-service programs and staffing them to ensure fast, reliable, and effective support with minimal hold times. About 40% of respondents to the national survey ranked “having someone walk me through the process step by step” as one of their top three suggestions for how to make applying easier. Installation instructions could be made clearer with step-by-step illustrations of the installation process that are easy to follow for adults with limited technical experience. Broadband providers could offer options across their tiers of service offerings, and regularly evaluate the ACP to further increase internet adoption. Broadband providers should be transparent about any future fees or costs, explain them clearly, and ensure that enrollees consent to any future costs when signing up for a no-cost program.

5. Streamline the application process for government benefit programs

Multiple steps requiring a consumer to coordinate with a community organization, school, and/or provider can confuse consumers and discourage signups. The complexity of state, locality, and broadband provider applications for low-income broadband programs—and the time it takes to complete them— often deter potential applicants. Also, programs could allow applicants to confirm their identity using their phone number or a form of official identification other than a Social Security Number (SSN) to minimize challenges and hesitancy around personal information sharing and to be more inclusive of those with differing documentation and employment statuses.

6. Increase support and funding for organizations such as schools, nonprofits, and faith-based organizations to provide digital navigation assistance in communities they serve.

It is not enough to establish broadband programs to close the digital divide. There is also a need for “boots on the ground” to help drive awareness about these programs, help potential program participants navigate the application and enrollment process, and work with participants to build the digital skills necessary to get the most out of their broadband service. Research has shown that trusted voices in a community can play a pivotal role in these adoption efforts. Trusted voices can include high touch community-based organizations, volunteers or cross-trained staff that already work in education or other fields with close ties to the community and a familiarity with working one-on-one with residents.

Communications should also explain a program in clear, nontechnical language. Trusted sources (such as educators, faith leaders, and community organizations) should share program information with students and others and encourage them to enroll. Program materials and support should be shared in multiple languages. Broadband providers should make sure consumers can contact them about questions or issues and speak with a representative in their preferred language and adopt accessibility best practices across providers.

In addition to schools, other trusted voices—including community partners, educators, and faith leaders—should be encouraged to assist in raising program awareness in historically underserved and marginalized communities. Community anchor institutions, community organizations, faith-based institutions, and others can reinforce program marketing. Because they tend to be highly trusted, they can help recruit and support applicants, and help participants build their digital and technical skills. These organizations can also serve as the voice for applicants and households.

7. Fund, promote and leverage the use of digital navigators

Digital navigators have local knowledge and experience interacting with people of different backgrounds, including non-native English speakers. Given longstanding feelings of mistrust among those who have not adopted broadband, digital navigators can help bridge gaps that exist in communities. Digital navigators can help address barriers to getting online through one-on-one interactions or in the classroom setting, both virtually and in person:

Encourage Digital Empowerment: Navigators can demonstrate and emphasize the benefits of broadband, including access to government services, searching and applying for jobs, and conducting online education and telehealth. All stakeholders—including leaders in the business community, elected officials, school districts, and grassroots organizations—should coordinate to address this barrier to adoption.

• Affordability: Navigators can provide information regarding low-cost options and help users select an option.
• Application/Installation Process: Navigators can walk consumers through the sign-up process step-by-step and help with internet self-install kits.
• Digital Uses and Skills: Navigators can explain basic concepts, help build comfort with basic activities, and assist consumers in connecting to the Internet.

8. Stakeholders should encourage Congress to create a digital public service and engagement program (i.e., digital navigators) to could conduct trainings and outreach in non-adopting communities.

Allocate funding for digital navigators to ensure equity for those doing the high-touch work of onboarding communities in most need. It is a time-consuming effort that should not be left to volunteers as that places an undue burden on community-based organizations already involved.

9. Increase device access and participation.

Concerns about the adoption of broadband service must also account for computer or tablet access and the fact that many consumers do not have regular access to a broadband-enabled device beyond their smartphones. Evaluate the use of ACP benefits for devices to enable more federal investments to reach those in need through ACP and other federal programs.

10. Use public-private partnerships to facilitate remote learning and close the homework gap.

States and localities should consider public-private partnerships with schools, libraries, and higher education institutions to help spur broadband adoption, particularly among low-income students. The American Rescue Plan Act (ARPA) created multiple sources of funding for broadband adoption initiatives, including to benefit students. Such funding sources can be used to subsidize programs that seek to close the homework gap.

11. Ensure that members of the community have safe spaces to access the internet.

A safe space for residents to get online can enable them to engage in remote learning, create resumes, apply for jobs, register for government services, and more. Libraries and community centers are integral institutions for addressing connectivity gaps, including the provision of free skills training.

12. Strengthen digital skilling efforts in underserved communities.

While cost can be a factor in broadband adoption, affordability is only one piece of the puzzle in facilitating equal access to broadband. States and localities should work with nonprofits, community organizations, and the private sector to promote digital skilling—a lack of digital literacy and skills can be a great barrier to adoption. Digital literacy efforts should also focus on reaching and addressing the needs of older Americans.

13. Encourage the creation of workforce development/training opportunities, focusing on historically underrepresented communities.

Per Scholas, Reboot Representation, CodePath, Year UP, and NPower enable adults and students to develop marketable digital skills that can be leveraged for future careers in media and technology. Broadband deployment and adoption investments can also create non-traditional paths into tech-enabled careers.

Related Content

More Questions About Eliminating Digital Discrimination

Model Policies and Best Practices to Prevent Digital Discrimination by Broadband Internet Access Service Providers

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

© Benton Institute for Broadband & Society 2022. Redistribution of this email publication - both internally and externally - is encouraged if it includes this copyright statement.

For subscribe/unsubscribe info, please email headlinesATbentonDOTorg

Kevin Taglang
Executive Editor, Communications-related Headlines
Benton Institute
for Broadband & Society
1041 Ridge Rd, Unit 214
Wilmette, IL 60091
847-328-3040
headlines AT benton DOT org

Share this edition:

Broadband Delivers Opportunities and Strengthens Communities