Note: This was originally posted on Digital Learning Now.
Yesterday, Digital Learning Now joined over 100 school districts, digital learning advocates, businesses, civil rights organizations, and education reform organizations to endorse the upgrading, reforming, and refocusing of the E-rate program.
The letter asks the Federal Communications Commission (FCC) to make the following common sense reforms designed to increase efficiencies and maximize existing funding:
- Establish minimum broadband infrastructure goals. New goals should meet the long-term needs of schools, districts and libraries, while ensuring that applicants retain the flexibility to acquire broadband solutions that meet their individual needs.
- Focus on broadband. A modernized E-rate program should prioritize connecting our schools to scalable, high-capacity broadband and deploying wireless networks that can support today’s and tomorrow’s learners in their classrooms.
- Incent cost-effective purchasing of bandwidth. E-rate reform should increase affordability by: encouraging consortium-based applications; increasing price transparency; maximizing the options available to schools and libraries that leverage private sector initiatives; and encouraging applicants to capture the efficiencies generating demand among anchor institutions to incent build-out to underserved areas.
- Simplify the application process. The FCC should develop online applicant portals and invest in improving USAC’s administrative processes.
They also echo our recent filing emphasizing the key role that consortia can play in promoting bulk purchasing and economies of scale and asking the FCC to establish clear incentives for the formation of large-scale consortia. We have noted in the past that the current program structure creates a disincentive for consortia. According to a Funds for Learning analysis, it takes 294 days on average for a consortium to receive a funding decision for Priority 1 services compared to 194 days for a single district applicant. Consortia applicants seeking Priority 2 services fare worse – waiting 483 days on average, with some as long as 565 days – compared to an individual applicant with a mere 387 day wait period. Thus, joining a consortium in the E-rate program as currently structured means accepting an extra 100 day waiting period of uncertainty. The Commission should act expeditiously to remove this impediment and instead create incentives for consortia.
Perhaps most importantly, yesterday’s consensus letter stresses a crucial point we have made often: while a successful E-rate program is essential to accelerate the transition to high-quality digital learning, any increase in funding for the program would be paid for by raising a contribution rate on American phone bills – a tax that is regressive, not progressive in nature.
The consensus letter reminds advocates and policymakers that any “funding increase must be guided by fiscal discipline and the knowledge that average consumers are responsible for funding this vital national policy.”
As the E-rate rulemaking proceeds, we look forward to working with the FCC as well as the other organizations pursuing reform to make E-rate a fiscally sustainable program. Reform should ensure schools have the level of connectivity mandated by the Communications Act while encouraging programmatic fiscal discipline; limiting waste, fraud, and abuse; and being respectful of the impact on the monthly phone bills of all Americans. Furthermore, decisions about the size of the E-rate program must be made after a fact-based analysis of the needs of the program once the reforms discussed in the consensus letter have been implemented.
With urgency, we ask that the Commission act on these common sense reforms as quickly as possible to give schools the support they need to provide their students with access to online courses, blended learning instructional methods, and the opportunity to take advantage of next generation online assessments.