Increasing the Impact of the Emergency Broadband Benefit Program

The challenges of a global pandemic have made broadband internet service more important than ever for nearly every aspect of daily life. And yet, broadband internet service remains out of reach for millions of Americans. The consequences for those who struggle to get connected will be significant, particularly for K-12 students.

We strongly support the bipartisan Emergency Broadband Benefits program (EBB) created by Congress to help low-income consumers access the internet. We want to help these Americans receive these benefits and get connected to reliable, high-speed internet service, as quickly as possible so that they can have access to educational and employment opportunities, healthcare, and much more.

As the FCC develops its plan for implementation, we laid out a number of policy recommendations that will encourage maximum participation by consumers and providers, allowing for significant impact – reaching more of those in need faster, including:

• Empower Consumer Choice by Enabling Broad Provider Participation: To ensure consumers have a wide range of competitive options the EBB program should encourage the broadest possible participation by providers and give them an equal opportunity to participate. The EBB program relies on the Lifeline infrastructure, including the National Lifeline Accountability Database (NLAD). That means the customers of companies that are not Eligible Telecommunications Carriers (ETCs) may be disadvantaged and denied the benefit—or full benefit—of the EBB program. To avoid inequality in eligibility for reimbursement and to provide consumers with as much choice as possible, we encourage the FCC to ensure all providers have full access to the relevant databases and programs at the outset.

• Expedite Assistance to Consumers by Allowing Providers’ Existing Verification Procedures and Access to National Verification Systems: By using providers’ existing verification procedures in place for COVID-19 support and low-income offerings, more consumers can be brought into the program more quickly. These verification procedures are an appropriate safeguard to avoid waste, fraud, and abuse in the EBB program as providers created these programs prior to a subsidy and have great incentives to avoid these concerns. Additionally, both to protect consumer privacy and minimize operational burdens, the FCC should streamline and limit the amount of personally identifiable information (PII) uploaded to the NLAD. Participating providers should not be required to collect and upload more PII than is truly necessary. Given the urgent and temporary nature of the EBB program, the FCC should streamline operational burdens and ensure that all providers have expedited access to National Verifier and the NLAD in advance of the launch of the EBB program’s benefits.

• Ensure Eligibility for Residents of Multi-Family Rental Properties, Including Those in Public Housing: Many multi-family rental properties, such as senior and student living, mobile home parks, apartment buildings, and federal housing units – often referred to as multi-dwelling units (MDUs) – have bulk billing agreements with internet service providers. Because MDU residents are not directly billed for services but instead pay a monthly fee for broadband services to their landlords, these otherwise eligible households would not be able obtain the benefit of the EBB program under their existing broadband plans. We have encouraged the FCC to draft EBB regulations in a way that offers MDU households equal opportunity to participate.

By implementing these suggestions, the FCC will encourage maximum participation in EBB, by both providers and recipients, furthering our shared goal of getting help to those in need as quickly as possible.