Proposal for Homework Gap Funding System

To help connect students, school staff, and library patrons during the pandemic, Congress established a $7.171 billion ECF as part of the American Rescue Plan Act of 2021 and directed the Federal Communications Commission to create rules to provide for the distribution of funding. This past week Funds For Learning submitted its recommendations to ensure the most efficient and effective use of this critical support.

We offered the following the principles to guide the Commission’s implementation of the ECF. First, the ECF should build upon and leverage the success and resources of the E-rate program. Second, the ECF should support a fair and equitable distribution of funding. Third, the ECF should provide flexible solutions to accommodate the different circumstances of schools and libraries. Fourth, assistance to support broadband connectivity should be delivered swiftly with minimal burden on schools and libraries. Finally, the ECF should promote fiscal accountability and safeguard limited public funds through a combination of financial controls and incentives with public access to all data.

With these overarching principles in mind, we urge the Commission to adopt rules for the ECF program consistent with the following proposals:

1. The Commission should authorize the Universal Service Administrative Company (“USAC”) to administer the ECF using the same resources that currently support the E-rate program. To reduce administrative costs and delay, and to quickly distribute funds to applicants, the Commission should also use the existing E-rate Productivity Center system to request and administer ECF support.
2. ECF support should be available to all schools, libraries, and consortia eligible for support under the E-rate program, including tribal schools and libraries. In addition, states and territories should be permitted to file consortium application on behalf of schools and libraries, including those that may not participate in the E-rate program.
3. The Commission should recognize that schools and libraries are in the best position to determine the needs of their constituents and allow support for any solution deemed necessary to facilitate remote learning, regardless of service, equipment type or location.
4. To avoid unnecessary administrative complexity, the Commission must eliminate the presumption that only those activities occurring on-campus serve an “educational purpose.”
5. In determining what amount of support to consider reasonable, the Commission should avoid establishing an arbitrary, allowable price range for services and equipment. Instead, a modified version of the E-rate program’s Category Two budget system should be used to calculate the reasonable support amount on a per-applicant basis, and reimbursement should be authorized for eligible expenditures up to that amount.
6. To allow schools and libraries to request ECF support, the Commission should direct USAC to open a 45-day filing window, waive competitive bidding rules to the extent necessary, and make other accommodations to quickly distribute ECF support to applicants.

Our full proposal is available to read online. If you agree, please consider submitting comments to the FCC in support of our proposal.