How can the federal eRate program be upgraded and modernized?

eRate-upgradeLast month, the Federal Communications Commission (FCC) closed its comment period for its most recent Public Notice, soliciting responses for proposed changes to the eRate program. As a former school superintendent, in my current role with the American Association of School Administrators (AASA), and as a member of the USAC board, the entity that administers the eRate program, I have strongly supported the eRate program for the critical role it has played in the rapid and dramatic expansion of school and library connectivity, forever changing the face of students’ classroom experiences.

The current eRate policy environment is an unprecedented confluence of events: an FCC Chairman committed to modernizing the program, an FCC commissioner deeply passionate about eRate, the momentum of President Obama’s ConnectED proposal, the announcement of $2 billion in found funding for the eRate program, and the ever-increasing demand for connectivity in the nation’s schools and libraries. Program policy isn’t made in a silo, though, and there are external pressures that stand to shape the final eRate changes as much as the voice of program beneficiaries.

(Next page: A two-pronged approach to eRate modernization)

The eRate’s long-term success relies on its ability to be updated to reflect the ever-changing world of connectivity and educational technology, while remaining committed to its focus on equity and program sustainability. Though most schools and libraries are now connected to the internet, the quality and speed of that connection does not always meet the demand. We still have school districts that do not have the technological capacity to keep up with online formative assessments and the tracking of massive amounts of data through state longitudinal data systems.

AASA strongly supports a two-pronged approach to modernizing the eRate–one with both programmatic changes and a permanent increase in the program’s funding cap. An infusion of funding without programmatic restructuring is a poor investment, and programmatic restructuring without permanent, adequate funding sets the program on a path towards instability and failure.

The administration recently announced an infusion of $2 billion over two years for the eRate. This is not new funding—rather, it is found funding, coming in part from rollover funds not allocated to Priority Two (internal connections and their basic maintenance) services, and other tweaks to program accounting. AASA applauds the effort to find the funds, but we want this funding to be seen as what it is: a one-time infusion of eRate funding back into the eRate program. In its Public Notice, the FCC is looking to allocate these dollars to Priority Two services, which is regularly underfunded, as funding runs out before demand can be met.

In a time when it is all but certain that the demand for connectivity will keep growing, it is counterintuitive to provide a much-needed infusion of funds as a one-time investment. Districts, like individuals, will spend one-time funding differently than a permanent increase (like a bonus versus salary increase). Any serious discussion about modernizing eRate will be committed to sustainability, and any final proposal short of a permanent funding increase sets the program on an unsustainable path.

To be fair, the chairman and the FCC have signaled that there is interest in looking at a funding increase as a follow-up to this current round of proposals. We would welcome such a conversation, but do hold reservation that we—and other eRate advocates representing beneficiaries—will go through the good-faith work of identifying programmatic changes to the program only to find hesitation in fully articulating the second portion of a two-pronged approach.

Within the FCC there has been explicit opposition to raising the eRate funding level: Commissioner Pai recently expressed opposition to a budget bump for eRate, saying : “…under no circumstances should we increase the size of the eRate program without finding corresponding new savings elsewhere in the Universal Service Fund.” While his commitment to fiscal responsibility is merited, the eRate’s long-term programmatic needs will far exceed the funding that comes from “shuffling the deck chairs” or “reaching between the couch cushions.” And let’s look a little more closely at the “found funding.” That $2 billion is funding that can be “found” once; once spent, it is gone. Further, it is $2 billion over two years, announced just weeks before the Funding Year 2014 application window closed and total program demand totaled $4.868 billion. In Funding Year 2014, the demand for Priority Two services alone totaled $2.225 billion in one year, exceeding the current proposed increase spread over two years.

There are additional proposals within the Public Notice that AASA’s full response addresses. We have filed our comments and look forward to continuing to work with the FCC in its long-standing eRate modernization efforts.

Dan Domenech is executive director of the American Association of School Administrators.