How universal service fund programs and the Emergency Broadband Benefit program can close the digital divide

Millions of low-income Americans supported by the Federal Communications Commission’s Lifeline program have come to rely on mobile wireless services to meet their expanding education, health care and public safety needs. In the face of an on-going pandemic in which consumers have relied on mobile wireless services, Congress provided the FCC with an extraordinary opportunity to keep millions of Americans connected to critical services through the Emergency Broadband Connectivity Fund (EBCF). With mobile wireless services being one of the most effective ways to provide broadband to eligible consumers, providers of mobile wireless are well-equipped to efficiently use the EBCF to benefit households in need at this uniquely difficult time in our nation’s history. To help ensure the EBB program’s success, CTIA encouraged the FCC to:

• maximize participation by making the program administration as simple as possible for households and providers;
• allow eligible low-income consumers to apply EBB benefits to the services and devices that they choose, consistent with the statute; and
• keep providers and consumers apprised about when the program is going to end.

Specifically, CTIA noted that familiar processes from the Lifeline program can become the backbone of this effort, including use of the Lifeline National Eligibility Verifier (National Verifier) and National Lifeline Accountability Database (NLAD), while the Commission also provides clear guidance for providers utilizing their own or third party verification programs. The FCC should also make clear that the EBB benefit could be applied to any service offering (or combination of service offerings) that the provider made available to consumers on December 1, 2020 which includes broadband Internet access service. Further, the FCC should take a functional approach to defining connected devices eligible for EBB support that entrusts consumers with the ability to determine what devices will best enable them to access the broadband services that they need and apply the EBB to those devices.