AFFORDABLE
BROADBAND
FCC Could Improve
Performance Goals
and Measures,
Consumer Outreach,
and Fraud Risk
Management
Report to Congressional Requesters
January 2023
GAO-23-105399
United States Government Accountability Office
United States Government Accountability Office
Highlights of GAO-23-105399, a report to
congressional requesters
January 2023
AFFORDABLE BROADBAND
FCC Could Improve Performance Goals and
Measures, Consumer Outreach, and Fraud Risk
Management
What GAO Found
The Federal Communications Commission’s (FCC) Affordable Connectivity
Program offers eligible low-income households discounts on the cost of their
broadband service and certain devices. FCC reimburses participating internet
service providers for providing these discounts. Since launching, the program
has grown to include over 14-million subscribers.
FCC Affordable Connectivity Program’s Subscribers, May 2021–September 2022
FCC established some performance goals and measures for the program.
However, the goals and measures do not fully align with key attributes of
effective performance management. For example, FCC’s goals and measures
lack specificity and clearly defined targets, raising questions about how effective
these goals and measures will be at helping FCC gauge the program’s
achievements and identify improvements.
FCC has also engaged in various outreach efforts to raise ACP’s awareness and
translated its outreach materials into non-English languages to reach eligible
households with limited-English proficiency. However, GAO reviewed a selection
of these materials and the process to translate them and found that they did not
fully align with leading practices for consumer content or for developing
translated language products. For example, the translations’ quality varied due to
lack of clarity and incompleteness. Also, FCC’s translation process lacked
elements that could have improved the materials, such as testing with the target
audience. FCC has also not developed a plan to guide its overall outreach
efforts. Quality translations are key to informing eligible households with limited-
English proficiency, which may include communities FCC has indicated are
important to reach. A comprehensive plan to guide its outreach efforts would help
ensure funds dedicated to outreach are used most effectively.
FCC has taken steps to manage fraud risks in the program, but FCC’s efforts do
not fully align with selected leading practices in GAO’s Fraud Risk Framework.
For example, FCC has conducted a fraud risk assessment but has not developed
an antifraud strategy to address the identified risks. It also has not developed a
process to conduct such risk assessments regularly. Further, FCC has not
developed processes to monitor certain antifraud controls. GAO identified
weaknesses in these controls, including potential duplicate subscribers,
subscribers allegedly receiving fixed broadband at PO Boxes and commercial
mailboxes, and subscribers with broadband providers’ retail locations as their
primary or mailing addresses. Without regular fraud risk assessments, an
antifraud strategy, and sufficient monitoring of controls, FCC may not be able to
effectively prevent and detect fraud in this over $14 billion program.
View GAO-23-105399. For more information,
contact
Andrew Von Ah at (202) 512-2834 or
.
Why GAO Did This Study
Broadband, or
high-speed internet, is
critical
since everyday activities
increasingly occur online, as
highlighted by the COVID
-19
pandemic. Yet the inability to afford
broadband presents barriers to access
for some and contributes to the gap
between those with and with
out
access, known as the “digital divide.”
As required by statute, FCC launched
the Affordable Connectivity Program
in
December 2021 to help low
-income
households afford broadband, building
from
FCC’s May 2021 launch of the
predecessor
Emergency Broadband
Benefit program
.
GAO was asked to review FCC’s
implementation
of the program. This
report
assesses FCC’s program
efforts
in:
(1) establishing performance goals
and measures, (2) conduct
ing
outreach, and (3) managing
fraud
risks.
GAO reviewed program
documentation
, including outreach
materials translated into five
non-
English
languages; analyzed
enrollment data from May 2021 to
September
2022; interviewed FCC
official
s; and compared FCC’s efforts
in each area to applicable leading
practices identified
in prior GAO work
or other federal sources.
What GAO Recommends
GAO is making
nine
recommendations,
including that FCC improve its program
goals and measures, revise its
language translation process, develop
a consumer outreach plan, and
develop and imp
lement various
processes for managing fraud risks.
FCC agreed with our
recommendations and described its
plans to address each one.
Page i GAO-23-105399 Affordable Broadband
Letter 1
Background 5
FCC Has Established Some Performance Goals and Measures for
Its New Broadband Affordability Program, but They Do Not
Fully Align with Leading Practices 11
FCC Has Engaged in Outreach for Its New Broadband
Affordability Program, but Its Language Translation Process
and Outreach Planning Do Not Fully Align with Leading
Practices 18
FCC Has Taken Steps to Manage Fraud Risks in Its New
Broadband Affordability Program, but Its Efforts Do Not Fully
Align with Selected Leading Practices 33
Conclusions 47
Recommendations for Executive Action 48
Agency Comments and Our Evaluation 49
Appendix I Objectives, Scope, and Methodology 52
Appendix II Analysis of ACP and EBB Enrollment Data 63
Appendix III Printable Versions of Interactive Figure 3 68
Appendix IV Comment from the Federal Communications Commission 72
Appendix V GAO Contact and Staff Acknowledgments 81
Tables
Table 1: FCC’s Affordable Connectivity Program’s (ACP)
Performance Goals and Measures 11
Table 2: Key Attributes of Effective Performance Goals and
Measures 12
Contents
Page ii GAO-23-105399 Affordable Broadband
Table 3: Examples of FCC Partnerships with Federal Agencies to
Raise Awareness for the Affordable Connectivity Program
(ACP) 19
Table 4: Comparison of FCC’s Original Translation Process to
Recommended Practices for Developing Public-Facing
Translated Language Products 29
Table 5: Leading Practices for Planning Effective Consumer
Outreach 32
Table 6: List of Participating Providers Selected for Website
Review 55
Table 7: Federal Communications Commission’s (FCC) Non-
English Affordable Connectivity Program (ACP) Outreach
Materials Reviewed 57
Table 8: List of Stakeholders Interviewed 59
Table 9: Selected Leading Practices for Fraud Risk Management 61
Figures
Figure 1: Overview of the Fraud Risk Management Framework 10
Figure 2: FCC’s Affordable Connectivity Program’s (ACP)
Performance Goals and Measures Compared with Key
Attributes of Effective Performance Goals and Measures 14
Figure 3: Selection of FCC’s Chinese, French, Korean, Spanish,
and Vietnamese Affordable Connectivity Program (ACP)
Outreach Materials Compared with Leading Practices for
Consumer-Oriented Content 23
Figure 4: Examples of Duplicated Spanish Text on FCC’s Spanish
Version of the Affordable Connectivity Program
Consumer FAQ Webpage and English Text on Spanish
Social Media Image 25
Figure 5: FCC’s Original Translation Process for Creating Non-
English Affordable Connectivity Program Consumer
Outreach Materials 28
Figure 6: Key Elements of an Antifraud Strategy 40
Figure 7: Example of Anonymized Potential Duplicate Subscribers
and Their Related Claims in FCC’s Affordable
Connectivity Program 43
Figure 8: Examples of Issues Related to PO Box and Commercial
Mailbox Addresses in Affordable Connectivity Program
Enrollment Data 46
Page iii GAO-23-105399 Affordable Broadband
Figure 9: Enrollment in FCC’s Emergency Broadband Benefit
Program (EBB), Affordable Connectivity Program (ACP),
and Lifeline, May 2021–September 2022 64
Figure 10: Enrollment in FCC’s Emergency Broadband Benefit
Program (EBB) and Affordable Connectivity Program
(ACP) by Lifeline Enrollment Status, May 2021–
September 2022 65
Figure 11: Enrollment in FCC’s Affordable Connectivity Program
(ACP) by State as of September 2022 66
Figure 12: Enrollment in FCC’s Emergency Broadband Benefit
Program (EBB) and Affordable Connectivity Program
(ACP) by Method Used to Verify Program Eligibility, May
2021–September 2022 67
Figure 13: Printable Version of Interactive Figure 3 – Clarity and
Accuracy 68
Figure 14: Printable Version of Interactive Figure 3 –
Completeness 69
Figure 15: Printable Version of Interactive Figure 3 – Practicality 70
Figure 16: Printable Version of Interactive Figure 3 – Managing
Users’ Expectations 71
Page iv GAO-23-105399 Affordable Broadband
Abbreviations
ACP Affordable Connectivity Program
EBB Emergency Broadband Benefit program
FAQ frequently asked questions
FCC Federal Communications Commission
IIJA Infrastructure Investment and Jobs Act
PII personally identifiable information
USAC Universal Service Administrative Company
Verifier National Lifeline Eligibility Verifier
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Page 1 GAO-23-105399 Affordable Broadband
441 G St. N.W.
Washington, DC 20548
January 18, 2023
The Honorable Roger F. Wicker
United States Senate
The Honorable John Thune
United States Senate
Broadband, or high-speed internet, has become critical for daily life as
everyday activities like work, school, health care appointments, and
access to economic opportunity and civic engagement increasingly occur
online. The COVID-19 pandemic has underscored the importance of
access to broadband and highlighted the gap between those with and
without access, known as the “digital divide.” Yet, the inability to afford
broadband service presents barriers to access, particularly for low-income
households. The Federal Communications Commission (FCC) has
reported that these households have lower rates of home broadband
subscriptions.
1
Further, a nationally representative survey by Consumer
Reports reported that nearly a third of respondents who lack a broadband
subscription said it was because it costs too much, while about a quarter
who do have broadband said they find it difficult to afford.
2
Regarding
rates of home broadband subscription, the U.S. Census Bureau has also
reported that households with limited-English proficiency lag behind other
households.
3
As required by statute, FCC created the Affordable Connectivity Program
(ACP), the successor to the Emergency Broadband Benefit program
(EBB). FCC established EBB to offer eligible low-income households
discounts on the cost of broadband service and certain devices, and to
reimburse internet service providers that participate in the program
1
In the Matter of Inquiry Concerning Deployment of Advanced Telecommunications
Capability to all Americans in a Reasonable and Timely Fashion, Fourteenth Broadband
Deployment Report, FCC 21-18, para. 47 (2021).
2
Consumer Reports, Broadband Survey: A Nationally Representative Multi-Mode Survey
(July 2021).
3
U.S. Census Bureau, Computer and Internet Use in the United States: 2018
(Washington, D.C.: April 2021).
Letter
Page 2 GAO-23-105399 Affordable Broadband
(participating providers) for these discounts.
4
In November 2021, the
Infrastructure Investment and Jobs Act (IIJA) made several changes to
the program to transform it from a temporary, emergency program to a
longer-term program known as ACP, and provided an additional $14.2
billion in funding.
5
The IIJA also included new provisions on conducting
outreach to eligible households to raise awareness of ACP. As required
by the IIJA, FCC launched ACP on December 31, 2021, building from its
launch of EBB in May 2021. FCC established ACP’s final rules in January
2022, after considering public comments submitted by stakeholders.
6
Although ACP is new, like its predecessor, EBB, it builds from and relies
in part on the operation of FCC’s Lifeline program, which has provided
eligible low-income households discounts on broadband service since
2016. For example, the not-for-profit Universal Service Administrative
Company (USAC) administers both ACP and Lifeline on behalf of FCC,
and both programs use the same systems for household eligibility
verification, enrollment in the program, and participating provider
reimbursement claims. We and others have previously reported on the
susceptibility of Lifeline to fraud, and FCC has imposed millions of dollars
in penalties on providers for apparent program violations.
7
Some
stakeholders have raised concerns about program integrity for ACP,
given the program’s connections to Lifeline, while others have highlighted
the positive role that ACP can play in closing the digital divide.
4
The December 2020 Consolidated Appropriations Act directed FCC to establish this
program. Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. N, tit. IX, §
904, 134 Stat.1182, 2129-36.
5
The $14.2 billion was in addition to the $3.2 billion previously provided for EBB. The
Infrastructure Investment and Jobs Act (IIJA), Pub. L. No. 117-58, § 60502(a)(1)(A), (a)(2),
135 Stat. 429, 1238-39 (2020) (authorizing the Affordable Connectivity Program); div. J,
tit. IV, 135 Stat at 1382 (providing additional funding). This program is now codified in 47
U.S.C. § 1752.
6
In the Matter of Affordable Connectivity Program, Emergency Broadband Benefit
Program, Report and Order and Further Notice of Proposed Rulemaking, FCC 22-2
(2022).
7
See, for example, GAO, Telecommunications: Additional Action Needed to Address
Significant Risks in FCC’s Lifeline Program, GAO-17-538 (Washington, D.C.: May 30,
2017); and Department of Justice, Office of Public Affairs, TracFone Wireless to Pay
$13.4 Million to Settle False Claims Relating to FCC’s Lifeline Program, Press Release
Number 22-323 (Apr. 4, 2022). The identification of improper payments could suggest that
a program is vulnerable to fraud; however, not all improper payments are fraudulent.
Page 3 GAO-23-105399 Affordable Broadband
You asked us to review FCC’s implementation of ACP.
8
This report
examines the extent to which FCC’s ACP efforts align with relevant,
selected leading practices in: (1) establishing performance goals and
measures; (2) conducting outreach; and (3) managing fraud risks.
To assess FCC’s efforts to establish ACP performance goals and
measures, we reviewed documentation and data. For example, we
reviewed the IIJA and records in FCC’s ACP proceeding. For additional
context on ACP’s performance, we analyzed enrollment data from May
2021 to September 2022, which covers the beginning of EBB to the end
of the third quarter following the launch of ACP. We assessed the
reliability of these data and determined that they were sufficiently reliable
for the purposes of our reporting objective. We assessed FCC’s efforts
against leading practices for performance goals and measures, including
the key attributes for such goals and measures identified in our prior
work.
9
To assess FCC’s ACP outreach efforts, we also reviewed agency
documentation. For example, we reviewed FCC’s ACP outreach materials
(including webpages and items from the outreach toolkit) and FCC’s
outreach plan for EBB (the predecessor program). To assess FCC’s
outreach materials for households with limited-English proficiency, we
reviewed a selection of FCC’s non-English ACP outreach materials in
Chinese, French, Korean, Spanish, and Vietnamese, as well as FCC’s
language translation process for developing these materials. We
assessed how well the non-English materials aligned with applicable
leading practices for consumer-oriented content drawn from various
8
Senator Wicker’s request was in his role as Ranking Member of the Senate Committee
on Commerce, Science, and Transportation in the 117
th
Congress, and Senator Thune’s
request was in his role as the Ranking Member of that committee’s Subcommittee on
Communications, Media, and Broadband.
9
GAO, Agencies’ Annual Performance Plans Under the Results Act: An Assessment
Guide to Facilitate Congressional Decisionmaking, GAO/GGD/AIMD-10.1.18
(Washington, D.C.: February 1998); The Results Act: An Evaluator’s Guide to Assessing
Agency Annual Performance Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 1998);
and Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance
Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). These reports establish
guides for assessing and evaluating agency performance plans and attributes of effective
performance goals and measures, and we have reiterated these practices in our reporting
on agencies’ efforts to manage for results. See https://www.gao.gov/leading-practices-
managing-results-government.
Page 4 GAO-23-105399 Affordable Broadband
federal sources that we have used in prior work.
10
We also assessed
FCC’s translation process against applicable recommended practices
from the U.S. Census Bureau for developing public-facing translated
products.
11
We assessed FCC’s EBB outreach plan against the leading
practices for consumer education planning identified in our prior work.
12
To assess FCC’s efforts to manage ACP fraud risks, we reviewed
documentation and data. For example, we reviewed FCC’s fraud risk
assessment for ACP and relevant program policies and guidance.
Additionally, we analyzed a snapshot of ACP enrollment data as of April
1, 2022, and matched relevant elements of these data against U.S. Postal
Service and Social Security Administration data. We assessed the
reliability of these data and determined that they were sufficiently reliable
for the purposes of our reporting objective. We assessed FCC’s fraud risk
management activities against selected leading practices in our Fraud
Risk Framework.
13
Finally, for additional agency information and context on all of our
objectives, we interviewed FCC and USAC officials and a selection of 27
stakeholders. We interviewed stakeholder representatives from 8 industry
associations; 5 state, local, and tribal entities; and 14 advocacy groups
selected to obtain a variety of viewpoints from a cross-section of interests.
While their views are not generalizable to all stakeholders, they provided
us with a variety of perspectives.
14
Similarly, we reviewed comments
10
U.S. Digital Service, Digital Services Playbook, accessed Dec. 10, 2021,
https://playbook.cio.gov/; U.S. Web Design System, Design Principles, accessed Dec. 10,
2021, https://designsystem.digital.gov/design-principles/; and General Services
Administration, Top 10 Best Practices for Multilingual Websites, accessed Dec. 10, 2021,
https://digital.gov/resources/top-10-best-practices-for-multilingual-websites/.
11
U.S. Census Bureau, Developing Public-Facing Language Products: Guidance From the
2020 Census Language Program (Washington, D.C.: Nov. 3, 2021). According to this
guidance, the bureau developed this product to share detailed information on how the
agency successfully developed and executed the 2020 Census language program, which
translated over 7 million words for more than 2,500 projects.
12
GAO, Digital Television Transition: Increased Federal Planning and Risk Management
Could Further Facilitate the DTV Transition, GAO-08-43 (Washington, D.C.: Nov. 19,
2007).
13
GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 2015).
14
Throughout this report, we refer to “some” stakeholders if representatives from 2–5
entities expressed the view (and “several” if 6–10, and “many” if 11 or more).
Page 5 GAO-23-105399 Affordable Broadband
submitted by stakeholders in FCC’s ACP proceeding. Appendix I
describes our objectives, scope, and methodology in greater detail.
We conducted this performance audit from October 2021 to January 2023
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
ACP provides eligible low-income households with monthly discounts on
the cost of their broadband service and a one-time discount on the cost of
certain devices. Eligible households can receive a discount of up to $30
per month ($75 for those on tribal lands) on their broadband service, and
a one-time discount of up to $100 on a tablet, laptop, or desktop
computer if the household contributes more than $10 but less than $50
toward the device’s purchase price.
15
To be eligible, a household must
meet the eligibility criteria for a participating provider’s own low-income
broadband assistance program or one of the following conditions:
• have total income at or below 200 percent of the Federal Poverty
Guidelines;
16
• participate in Lifeline or certain other government assistance
programs;
17
15
This means the total cost of the device to the household, including discount, can be no
more than $150. Some providers offer tablets, for example, at this price point or may offer
additional discounts to meet this price point.
16
The Department of Health and Human Services issues these guidelines each year
based on a household’s size and location. For example, 200 percent of the 2022
guidelines could range from a single-person household that resides in one of the 48
contiguous states or the District of Columbia that earns $27,180, to an 8-person
household in Alaska that earns $116,580.
17
These programs include Federal Public Housing Assistance; Medicaid; the National
School Lunch or Breakfast Programs, including through the Department of Agriculture’s
Community Eligibility Provision; the Special Supplemental Nutrition Program for Women,
Infants, and Children; the Supplemental Nutrition Assistance Program; Supplemental
Security Income; and Veterans Pension or Survivor Benefits.
Background
The Affordable
Connectivity Program
Page 6 GAO-23-105399 Affordable Broadband
• participate in certain government assistance programs and live on
qualifying tribal land;
18
or
• have received a federal Pell grant during the current award year.
A household can apply to the program by mail, online, or through a
participating provider. To process applications, FCC uses a modified
version of the same online tool it uses for Lifeline. Known as the National
Lifeline Eligibility Verifier (Verifier), FCC completed its launch of this tool
in 2020 in response to concerns about Lifeline fraud.
19
Historically,
providers verified that applicants met Lifeline eligibility requirements
before providing them with discounted service. In response to concerns
that FCC’s reliance on providers to make such eligibility determinations
left the program vulnerable to fraud, FCC established the Verifier to shift
responsibility for eligibility verification from providers to USAC.
The Verifier relies on automated connections to federal and state benefits
databases and other automated sources to validate an applicant’s
identity, address, and participation in qualifying programs.
20
When
applicants cannot be automatically verified, they must submit
documentation to USAC for manual review. An applicant may also apply
in person with the assistance of a participating provider, or through a
provider’s website if the provider has established an interface between its
website and the Verifier. Alternatively, a provider may use its own FCC-
approved alternative verification process to determine eligibility (in
18
These programs include Bureau of Indian Affairs General Assistance; the Food
Distribution Program on Indian Reservations; Tribal Head Start (only if the household
qualified through the program’s income standard); and Tribal Temporary Assistance for
Needy Families. FCC’s definition of tribal lands for ACP purposes includes “any federally
recognized Indian tribe’s reservation, pueblo, or colony, including former reservations in
Oklahoma; Alaska Native regions established pursuant to the Alaska Native Claims
Settlement Act (85 Stat. 688); Indian allotments; Hawaiian Home Lands - areas held in
trust for Native Hawaiians by the state of Hawaii, pursuant to the Hawaiian Homes
Commission Act, 1920 July 9, 1921, 42 Stat. 108, et. seq., as amended; and any land
designated as such by the Commission for purposes of this subpart pursuant to the
designation process in § 54.412.” 47 C.F.R. § 54.400(e).
19
We previously reported on the Verifier’s implementation. See, GAO,
Telecommunications: FCC Has Implemented the Lifeline National Verifier but Should
Improve Consumer Awareness and Experience, GAO-21-235 (Washington, D.C.: Jan. 28,
2021).
20
According to USAC reporting as of January 2022, the Verifier has database connections
with 2 federal agencies (the Department of Housing and Urban Development and Centers
for Medicare and Medicaid Services) and 23 states and territories (Colorado, Florida,
Georgia, Indiana, Iowa, Kentucky, Michigan, Minnesota, Mississippi, Missouri, Nevada,
New Mexico, North Carolina, Oregon, Pennsylvania, Puerto Rico, South Carolina,
Tennessee, Texas, Utah, Virginia, Washington, and Wisconsin).
Page 7 GAO-23-105399 Affordable Broadband
addition to, or instead of, the Verifier), or—if the applicant is qualifying
through a child or dependent who participates in the free and reduced
price school lunch or breakfast programs—may rely on schools for
verification. If a household already participates in Lifeline, it need not re-
verify its eligibility for ACP.
To subscribe to ACP once deemed eligible, applicants must contact a
participating provider to select a broadband service plan and have the
provider enroll them in the program and apply the discount. A program
subscriber may choose any broadband plan that the provider offers,
including mobile plans and bundled plans, though the discount cannot be
applied to video services. The provider enrolls the subscriber into the
program using the National Lifeline Accountability Database (the same
system used for Lifeline). When entering a subscriber into this database,
the provider must submit the subscriber’s
1. full name,
2. full residential address,
3. date of birth,
4. phone number associated with the ACP-supported service or email,
5. date the ACP discount was initiated, and
6. method by which the subscriber qualified for the program.
A subscriber can only receive the device discount from the same provider
from which it receives the service discount. Not all providers offer the
device discount. Providers receive reimbursements for these discounts
from FCC and manage their reimbursement claims using the Affordable
Connectivity Claims System (which is built on the Lifeline Claims
System).
While ACP shares similarities with Lifeline, ACP differs from Lifeline in
key ways. For example:
• Funding. ACP is funded by appropriations from the U.S. Treasury
General Fund, while Lifeline is funded by FCC’s Universal Service
Fund, which is in turn funded by required contributions from
telecommunications providers. FCC determines the amount of
contributions required from providers each quarter to support the
fund’s costs, and providers generally pass their contribution fees on to
their customers in the form of a line item on their phone bills.
Page 8 GAO-23-105399 Affordable Broadband
• Household eligibility. Household eligibility is more expansive under
ACP. Unlike ACP, Lifeline does not include the Special Supplemental
Nutrition Program for Women, Infants, and Children; the National
School Lunch or Breakfast Programs; Federal Pell Grants; or a
participating provider’s own low-income program as qualifying
programs. The income threshold for Lifeline eligibility is 135 percent of
the Federal Poverty Guidelines, as opposed to 200 percent for ACP.
21
• Participating providers. More providers can participate in ACP. To
participate in Lifeline, a provider must be designated as an eligible
telecommunications carrier by state public utility commissions or FCC;
this designation is not required to participate in ACP. Statutory and
regulatory requirements are associated with being designated an
eligible telecommunications carrier, such as requiring that the provider
offer an evolving level of services, such as broadband speeds,
throughout its service area.
• Discount and level of service. ACP provides subscribers with a
larger discount. Lifeline does not offer a device discount, and
subscribers may only receive a broadband service discount of up to
$9.25 per month ($34.25 for those on tribal lands) with Lifeline, as
opposed to up to $30 per month ($75 for those on tribal lands) with
ACP.
22
However, households may participate in both ACP and
Lifeline, if they choose, and may apply the discounts to the same or
separate qualifying services, and with the same or different providers.
Furthermore, providers must meet minimum standards for the Lifeline-
supported services they offer, such as minimum broadband speeds,
but there are no such minimum standards for ACP.
21
Income eligibility under ACP’s predecessor, EBB, was also 135 percent and EBB also
did not include the Special Supplemental Nutrition Program for Women, Infants, and
Children. Under EBB, households were also eligible if the household experienced a
substantial loss of income due to job loss or furlough if the household’s total 2020 income
was at or below $99,000 for single tax filers and $198,000 for joint filers. A household
could also qualify through participation in a provider’s own COVID-19 program.
22
ACP’s predecessor, EBB, also offered a larger potential service discount of up to $50
per month.
Page 9 GAO-23-105399 Affordable Broadband
Managers of federal programs are responsible for managing fraud risks
and implementing practices for combating those risks.
23
The objective of
fraud risk management is to ensure program integrity by continuously and
strategically mitigating both the likelihood and effects of fraud. Effectively
managing fraud risk helps to ensure that federal programs’ services fulfill
their intended purpose, that funds are spent effectively, and that assets
are safeguarded. In July 2015, we issued the Fraud Risk Framework,
which provides a comprehensive set of key components and leading
practices that serve as a guide for agency managers to use when
developing efforts to combat fraud in a strategic, risk-based way.
24
The Fraud Reduction and Data Analytics Act of 2015 required the Office
of Management and Budget to establish guidelines for federal agencies to
create controls to identify and assess fraud risks and to design and
implement anti-fraud control activities, and to incorporate the leading
practices from the Fraud Risk Framework in the guidelines.
25
Although
that act was repealed in March 2020, the Payment Integrity Information
Act of 2019 requires these guidelines to remain in effect, subject to
modification by the Office of Management and Budget as necessary, and
in consultation with GAO.
26
As depicted in figure 1, the framework
describes leading practices within four components: (1) commit, (2)
assess, (3) design and implement, and (4) evaluate and adapt.
23
As we have previously reported, fraud and fraud risk are distinct concepts. Fraud—
obtaining something of value through willful misrepresentation—is challenging to detect
because of its deceptive nature. Fraud risk (which is a function of likelihood and impact)
exists when people have an opportunity to engage in fraudulent activity, have an incentive
or are under pressure to commit fraud, or are able to rationalize committing fraud. Fraud
risk management is a process for ensuring program integrity by mitigating the likelihood
and impact of fraud. When fraud risks can be identified and mitigated, fraud may be less
likely to occur. Although the occurrence of fraud indicates there is a fraud risk, a fraud risk
can exist even if actual fraud has not yet occurred or been identified.
24
GAO-15-593SP.
25
Pub. L. No. 114-186, 130 Stat. 546 (2016); Payment Integrity Act of 2019 § 3(a)(4), Pub.
L. No. 16-117, 134 Stat. 113, 133 (2020) (repealing The Fraud Reduction and Data
Analytics Act of 2015).
26
Pub. L. No. 116-117, § 2(a), 134 Stat. 113, 131-32 (2020), codified at 31 U.S.C. § 3357.
Fraud Risk Management
Page 10 GAO-23-105399 Affordable Broadband
Figure 1: Overview of the Fraud Risk Management Framework
Page 11 GAO-23-105399 Affordable Broadband
FCC has established some performance goals and measures for ACP, as
called for by leading practices.
27
According to leading practices, effective
organizations establish performance goals and measures to help assess
and manage program performance. First, organizations set goals that
clearly define intended program outcomes. Second, organizations
establish measures, which are concrete, observable conditions that
clearly link with the goals and allow organizations to assess, track, and
show the progress made toward achieving the goals. FCC established
three goals for ACP and two measures for each goal (see table 1).
Table 1: FCC’s Affordable Connectivity Program’s (ACP) Performance Goals and Measures
Performance goal
Performance measures
Goal 1: Reduce the digital
divide for low-income
consumers
Measure 1: Estimate the prior internet access of ACP subscribers and monitor responses over time
and by area
Measure 2: Analyze ACP enrollments in areas with low adoption rates
According to FCC officials, to estimate prior access, FCC will survey subscribers. FCC’s target is to
analyze data quarterly to identify if there is an overall increase in first-time broadband connections, an
increase in first-time connections tied to targeted outreach, and higher than usual first-time
connections for a specific sub-group of subscribers. For the second measure, FCC will pair enrollment
data by geographic area with U.S. Census Bureau data and other data that FCC collects to calculate
an adoption rate and compare trends in areas with the lowest rates to those with the highest. FCC
aims to analyze, quarterly, areas with low rates to monitor progress relative to overall growth. FCC’s
target is to identify 5 to 10 Census tracts, ZIP codes, or counties in the bottom 20 percent of
broadband penetration rates that have low ACP participation to refer for targeted outreach, and 5 to 10
with high participation to examine reasons for success.
27
GAO/GGD/AIMD-10.1.18; GAO/GGD-10.1.20; and GAO-03-143.
FCC Has Established
Some Performance
Goals and Measures
for Its New
Broadband
Affordability Program,
but They Do Not Fully
Align with Leading
Practices
FCC Has Established
Some Program
Performance Goals and
Measures
Page 12 GAO-23-105399 Affordable Broadband
Performance goal
Performance measures
Goal 2: Increase awareness
of and participation in ACP
Measure 1: Monitor participation over time and by area
Measure 2: Estimate ACP awareness
According to FCC officials, as part of the first measure, they will pair enrollment data with Census data
to calculate an ACP participation rate by state and extrapolate these findings to the ZIP code level. To
estimate awareness, they will survey the general public to calculate the percentage of respondents
who know about ACP and to capture information about those who do not. FCC’s target is to identify at
least three geographic areas or demographic groups that are the least aware of ACP to refer for
targeted outreach.
Goal 3: Ensure efficient and
effective administration of
ACP
Measure 1: Evaluate the speed and ease of the application and reimbursement processes
Measure 2: Evaluate the overall burden of the program on consumers
FCC stated that it will measure the burden on consumers using the same methodology it uses for its
Lifeline program to compute a monthly dollar figure.
Source: GAO analysis of In the Matter of Affordable Connectivity Program, Emergency Broadband Benefit Program, Report and Order and Further Notice of Proposed Rulemaking, FCC 22-2 (2022) and
other Federal Communications Commission (FCC) information. | GAO-23-105399
According to FCC officials, while FCC has not yet begun formally
reporting on any of these measures, ACP’s millions of subscribers to date
demonstrate its progress toward achieving these goals. We analyzed
program enrollment data and found that as of September 2022, about 14
million households had enrolled in ACP; this number is approximately a
third of the minimum estimate of eligible households.
28
See appendix II for
additional analysis on ACP participation.
In comparing FCC’s ACP performance goals and measures to leading
practices for effective goals and measures, we found that they did not
fully align with these practices. As noted above, according to leading
practices, effective organizations set program goals and measures; steps
FCC has taken. However, for goals and measures to be useful for
performance management, the practices indicate that they should reflect
key attributes, as summarized in table 2.
Table 2: Key Attributes of Effective Performance Goals and Measures
Key attributes
Definitions
Attributes of goals and
measures
Objective
Goals and measures are reasonably free of significant bias or manipulation
that would distort the assessment of performance and do not allow subjective
considerations to dominate.
Measurable and
quantifiable
Goals and measures include a quantifiable, numerical target or other value
and indicate specifically what should be observed, in which population or
conditions, and in what time frames.
28
We estimated eligibility using the U.S. Census Bureau’s 2019 American Community
Survey and Puerto Rico Community Survey. For more detail, see appendix I.
FCC’s Program Goals and
Measures Do Not Fully
Align with Leading
Practices
Pag
e 13 GAO-23-105399 Affordable Broadband
Key attributes
Definitions
Primary function
Goals and measures reflect the program’s primary function and core
activities.
Linkage
Goals and measures reflect the agency’s strategic goals.
Additional attributes of goals
Results-oriented
Goals focus on the results the program expects to achieve. Outcome goals
are included whenever possible; output goals can supplement outcome
goals. Outputs are the services delivered by a program; outcomes are the
results of those services.
Crosscutting
Goals reflect the crosscutting nature of programs, when applicable. Goals of
programs contributing to the same or similar outcomes are complementary to
permit comparisons of results and identification of wasteful duplication,
overlap, or fragmentation.
Additional attributes of
measures
Clarity
Measure is clearly stated.
Reliability
Measure provides a reliable way to assess progress and produces the same
result under similar conditions.
Limited overlap
Measure gives new information beyond that provided by other measures.
Balance
The suite of measures covers an organization’s various priorities.
Government-wide
priorities
Each measure covers a priority such as quality, timeliness, efficiency,
outcomes, or cost of service.
Source: GAO/GGD/AIMD-10.1.18, GAO/GGD-10.1.20, and GAO-03-143. | GAO-23-105399
As shown in figure 2 and discussed below, FCC’s ACP performance
goals and measures lack some of these key attributes, in large part
because they lack specificity and clearly defined targets.
Page 14 GAO-23-105399 Affordable Broadband
Figure 2: FCC’s Affordable Connectivity Program’s (ACP) Performance Goals and Measures Compared with Key Attributes of
Effective Performance Goals and Measures
FCC’s goals and measures largely align with some of the attributes of
effective goals and measures; specifically, those related to reflecting the
program’s primary functions and government-wide priorities, linking with
strategic goals, and being results-oriented and balanced. For example,
the goal to reduce the digital divide reflects the program’s primary
function, in that a primary function of the program is to address
broadband affordability for low-income households and in that affordability
is an aspect of closing the digital divide. Similarly, regarding the goal to
increase awareness and participation, the ACP final rules state that for
the program to achieve its full potential, households must be clearly
informed of the program’s existence, benefits, and eligibility qualifications,
Page 15 GAO-23-105399 Affordable Broadband
and how to apply.
29
Accordingly, awareness is primary to the program’s
success, as is participation in the program.
These two goals also link to FCC’s strategic goal to bring affordable
broadband to 100 percent of the population, including low-income
Americans, as part of addressing the digital divide, and the third goal
(ensure efficient and effective administration) links with FCC’s fostering
operational excellence strategic goal.
30
The digital-divide goal is also
results-oriented—since it expresses an outcome (a reduction in the digital
divide) of the program’s outputs (discounts on the cost of broadband
service)—as is the awareness-and-participation goal, since it covers an
outcome (participation) of increasing awareness. The measures for all
three goals also cover various government-wide priorities such as
outcomes, efficiency, and cost, and are balanced because they cover
various FCC priorities.
However, FCC’s current ACP goals and measures do not fully align with
many of the other attributes of effective goals and measures. For
example:
• Measurability and clarity. All three goals and their corresponding
measures are not expressed in a quantifiable manner, and all of the
measures also lack clarity. For example, none of the goals or
measures define a specific, numerical target. For instance, regarding
the measures on prior internet access and enrollment in areas with
low adoption, FCC has identified time frames and attempted to set
targets for each measure, but the targets are vague and not
numerical. Similarly, the measure on speed and ease of the
application and reimbursement processes does not define any
specific targets, populations, conditions, or time frames. The
measures’ lack of specificity also means they lack clarity. For
example, the specific program achievements that FCC is trying to
measure (e.g., a certain number of new broadband connections;
percentage increase in low-adoption areas; a certain level of
awareness, ease, or burden; or other value) are unclear. Additionally,
in the measure on participation over time and by area, it is not clear
what “over time” represents, and similarly, in the applications-and-
reimbursements measure, it is not clear what “ease” represents.
29
FCC 22-2, para. 190.
30
FCC, Strategic Plan: Fiscal Years 2022-2026 (Washington, D.C.: Mar. 29, 2022).
Page 16 GAO-23-105399 Affordable Broadband
• Objectivity and reliability. The lack of specific targets and clarity
means it is also unclear whether the current goals and measures will
be objective or reliable measures of progress. For example, without
knowing what “specific subgroups” FCC is referring to in the measure
on prior internet access or what specific time periods or rate of
progress FCC is aiming for in the measures on participation and
awareness, FCC could present results in ways that make the results
look more or less favorable. Similarly, it is unknown how FCC will
weigh the subjective judgments of the different parties captured by the
applications-and-reimbursements measure, to ensure objectivity when
measuring performance. Regarding the measure on overall consumer
burden and its monthly-dollar-figure metric, it is unclear if FCC’s
methodology is reliable or aligns with the program’s primary functions
or intended results. FCC intends to divide the annual expenditures of
the program by the number of U.S. households to derive a monthly
dollar figure. If one of the goals of the program is to increase
participation and if the program’s expenditures increase as
participation increases, then the program’s expenditures-per-U.S.-
household will also increase. Therefore, it is unclear how this
approach meaningfully conveys program performance.
• Crosscutting and limited overlap. It is unclear how FCC intends to
consider the crosscutting nature of Lifeline across its current ACP
goals, and how some of the measures might overlap. Specifically,
FCC officials have indicated FCC’s interest in incorporating data from
Lifeline into its analyses. For example, in exploring first-time
broadband subscribership as part of the goal to reduce the digital
divide, this could mean those who were not already enrolled in Lifeline
and using it to obtain broadband prior to ACP enrollment. However,
the lack of specificity regarding what targets FCC is measuring means
it is unclear how FCC will gauge the performance of ACP and Lifeline
relative to each other. The lack of specificity on what achievements
are being measured means it is also unclear how much the measures
for the digital divide and participation goals will overlap, as they both
entail monitoring participation rates.
ACP provides eligible households with two possible discounts: the
monthly broadband service discount and the one-time device discount.
However, none of FCC’s established goals and measures address
performance of the device discount. FCC officials told us that FCC does
not plan to separately analyze performance of this aspect of ACP.
According to these officials, this is because program subscribers can only
receive the device discount from the same participating provider that they
receive the service discount from. As such, FCC officials said they believe
Page 17 GAO-23-105399 Affordable Broadband
the current goals and measures already capture the device discount as
well.
According to FCC officials, FCC has not yet fully refined its ACP
performance goals and measures because efforts to collect certain
information and data are still under way. For example, FCC officials told
us they intend to survey program subscribers to learn how ACP affected
their internet access. These officials added that the results of that survey
will then inform a broader survey of the entire country that will measure
outcomes for the general public. To conduct this broader survey, FCC
officials stated that FCC plans to request proposals from vendors with
public survey experience. According to these officials, FCC plans to use
these surveys as sources of information to refine performance measures.
The officials said there is no set timeline for implementation of these
surveys.
In the meantime, according to FCC officials, USAC conducted outreach to
a sample of ACP subscribers in September 2022 for some of FCC’s
measures, and FCC’s Office of Economics and Analytics has also begun
analyzing some data that relates to others. These officials noted that FCC
plans to establish additional targets after establishing some baselines.
FCC officials also noted that the IIJA requires FCC to issue rules on the
annual collection of information about the price and subscription rates of
internet service offerings received by ACP subscribers.
31
In June 2022,
FCC issued a Notice of Proposed Rulemaking requesting comments on
the data to be collected and mechanism for collecting these data. In this
notice, FCC also proposed using these data to evaluate whether the
program was achieving the established goals and asked questions about
this proposal, particularly about what information it should collect to
measure performance.
32
ACP represents a significant investment in helping consumers afford
broadband, and effective performance goals and measures could help
FCC and others gauge the program’s achievements and identify
opportunities for improvement. We acknowledge that collecting relevant
information and data can help agencies establish baselines from which to
measure progress. However, knowing what the specific goals are and
what needs to be measured should drive what data and information to
31
See IIJA § 60502(c)(1).
32
In the Matter of Affordable Connectivity Program, Notice of Proposed Rulemaking, FCC
22-44, para. 12 (2022).
Stakeholders’ Views on FCC’s ACP
Performance Goals and Measures
Many stakeholders we spoke with stressed
the importance of the Federal
Communications Commission (FCC) using
quality information to evaluate the Affordable
Connectivity Program’s (ACP) performance
and said it was unclear if the performance
measures FCC had established would be
effective. Most stakeholders generally agreed
that developing more specific measures that
show what the program is achieving would be
necessary. For example, they cited metrics
detailing how many ACP subscribers are new
to ACP versus how many were already
Lifeline participants, which enrollment
methods subscribers are using, or the
program participation rate by various
demographic characteristics (such as
geography, race, age, and socioeconomic
status). Several stakeholders added that, for
various reasons, the device discount aspect of
the program has not been effective and
wanted FCC to assess this aspect in order to
help identify improvements.
Source: GAO analysis of information from stakeholders. |
GAO-23-105399
Page 18 GAO-23-105399 Affordable Broadband
collect, how to collect it, and how to balance tradeoffs. For example, it is
unclear how FCC’s planned survey measuring outcomes for the general
public will relate to ACP performance.
We also acknowledge that program subscribers must receive the device
discount from the same participating provider from which they receive the
broadband service discount. However, not all providers offer the device
discount and not all subscribers receive it. Therefore, it is unclear how
FCC’s current goals and measures will capture this aspect of the
program. Without more specific and clearer goals and measures, it is
unclear whether FCC will be able to effectively demonstrate the
program’s achievements to Congress and other stakeholders.
To raise awareness of ACP, FCC has completed a variety of outreach
activities, including (1) creating consumer outreach materials, (2)
partnering with federal agencies, and (3) engaging and leveraging other
outreach partners.
• Creating consumer outreach materials. FCC has created a variety
of outreach materials (available in English and non-English
languages) to inform eligible households about the program. FCC’s
website has several ACP consumer-focused webpages with
information about program eligibility, how to apply, and responses to
frequently asked questions (FAQ). FCC has also created a toolkit with
various items such as flyers and fact sheets available to download,
print, and distribute. These items include those intended for outreach
partners to distribute to the public and those intended for government
FCC Has Engaged in
Outreach for Its New
Broadband
Affordability Program,
but Its Language
Translation Process
and Outreach
Planning Do Not Fully
Align with Leading
Practices
FCC Has Engaged in
Various Outreach Efforts
to Raise Program
Awareness
Page 19 GAO-23-105399 Affordable Broadband
entities to use, including posters and a letter inviting eligible
households to participate. FCC can also print these items and mail
them to outreach partners across the country upon request. According
to FCC documentation, from January 2022 to September 2022, FCC
mailed almost 200,000 printed items to outreach partners to distribute
to their communities.
• Partnering with federal agencies. To raise awareness of ACP, the
IIJA requires FCC to work with the seven federal agencies
33
that
administer programs that qualify households for ACP.
34
To promote
ACP, FCC officials told us they have leveraged existing relationships
with these agencies that they developed during outreach efforts for
ACP’s predecessor, EBB. See table 3 for examples.
Table 3: Examples of FCC Partnerships with Federal Agencies to Raise Awareness for the Affordable Connectivity Program
(ACP)
Federal agency
Outreach effort(s) completed or planned
Department of Agriculture
According to FCC officials, they are working with the department to include information about ACP
in the department’s meetings with its stakeholders, who include state-level administrators of
departmental programs.
Department of Education
According to FCC officials, they worked with the department to share information about ACP with
Pell grant recipients for the 2020–2021 and 2021–2022 academic years via email. FCC officials
said they planned to replicate this effort in future years, including the 2022–2023 academic year.
Department of Housing and
Urban Development
In March 2022, FCC officials presented at a departmental webinar and gave an overview of ACP
along with best practices for engaging residents of public housing, outreach, and program
enrollment.
Department of Veterans Affairs
FCC officials stated that FCC will work with the department to provide digital consultations to
veterans to help them learn about ACP.
33
These agencies are the Departments of Agriculture (Food Distribution Program on
Indian Reservations; National School Lunch or Breakfast Programs; Special Supplemental
Nutrition Program for Women, Infants, and Children; Supplemental Nutrition Assistance
Program), Education (Federal Pell Grants), Health and Human Services (Medicaid, Tribal
Head Start, Tribal Temporary Assistance for Needy Families), Housing and Urban
Development (Federal Public Housing Assistance), Interior (Bureau of Indians Affairs
General Assistance), and Veterans Affairs (Veterans Pension or Survivor Benefits), as
well as the Social Security Administration (Supplemental Security Income).
34
The IIJA requires FCC to “collaborate with relevant Federal agencies, including to
ensure relevant Federal agencies update their System of Records Notices, to ensure that
a household that participates in any program that qualifies the household for the
Affordable Connectivity Program is provided information about the program, including how
to enroll in the Program.” IIJA § 60502(a)(3)(B)(ii). FCC concluded that it does not have
the authority to compel these other agencies to do this, but directed various staff offices
within FCC to fulfill this collaboration requirement through other activities. See FCC 22-2,
para. 199.
Page 20 GAO-23-105399 Affordable Broadband
Federal agency
Outreach effort(s) completed or planned
Social Security Administration
In March 2022, FCC published a guest blog post on the Social Security Administration’s website
that explained the benefits of ACP and program eligibility. According to FCC officials, the Social
Security Administration agreed to add information about ACP to media playing in its waiting rooms.
FCC officials said the Social Security Administration also included information on ACP in a “Dear
Colleague Letter,” an outreach notice the agency distributed to its stakeholders.
Source: GAO analysis of Federal Communications Commission (FCC) information. | GAO-23-105399
Note: Each of the listed agencies administer programs that qualify eligible low-income households for
ACP.
FCC officials told us they are working to formalize their relationships with
other agencies. For example, they are in the process of developing
memorandums of understanding with some of these agencies. According
to FCC officials, they have also leveraged a White House initiative to
formalize commitments from other agencies and convene cross-agency
meetings.
35
• Engaging and leveraging other outreach partners. FCC shares
information with its outreach partners—including participating
providers; state, local, and tribal entities; and advocacy groups—
through emails, monthly meetings, and other events. FCC sends
ACP-related information to an email listserv that contains over 50,000
unique email addresses as of March 2022. FCC has also hosted
monthly partner meetings to discuss program updates, and completed
a number of other events to engage its outreach partners. According
to FCC documentation, between November 2021 and September
2022, FCC completed about 400 presentations, discussions, “train-
the-trainer” events, virtual town halls, and briefings.
FCC also leverages these outreach partners’ activities to help raise
awareness of ACP. In the program’s final rules, FCC states that
outreach partners’ activities, as described below, play an important
role in raising awareness about the program.
36
Participating providers: The ACP final rules require participating
providers to publicize the availability of the program and carry out
public awareness campaigns. FCC gives providers flexibility in how to
35
In May 2022, the White House launched the website getinternet.gov to help raise
awareness of ACP and connect eligible households with participating providers that would
provide broadband service at no cost to ACP subscribers. This initiative is separate from
FCC-led outreach efforts.
36
FCC 22-2, para. 271.
Page 21 GAO-23-105399 Affordable Broadband
meet these requirements.
37
According to some industry stakeholders
we spoke with, providers have various efforts to raise awareness of
ACP, such as including flyers in utility bills, using radio and television
advertisements, or advertising online. We reviewed a selection of 20
participating provider websites for additional context on how providers
advertise ACP online and found that some of the websites did not
provide detailed information about the program and some did not
advertise ACP at all.
38
According to FCC officials, providers that do
not advertise on their websites could still be considered in compliance
with program rules if they advertise by other means, such as by mail
and customer service calls. FCC officials also said they would likely
incorporate providers’ advertising efforts into future reviews of the
program, which would help FCC identify non-compliance with the
requirement to publicize the program.
State, local, and tribal entities: State, local, and tribal entities have
also made various efforts to raise awareness of ACP. For example, in
a letter submitted to FCC, Montgomery County, Maryland, described
the 14 enrollment campaign events it held in June 2022 and noted
that the county used these events to help eligible households enroll in
ACP. Some states and cities, in collaboration with the White House,
planned to text eligible residents about the program.
39
In comments
submitted to FCC, the city of Boston described how it planned to train
volunteer tax preparers to share information about ACP with those
who qualify for the Earned Income Tax Credit, since these individuals
often qualify for ACP. One tribal stakeholder we spoke with said that
some entities have partnered with tribes to communicate with tribal
elders and used other “on the ground” efforts to raise awareness.
37
FCC 22-2, para. 205, 207. The IIJA requires the public awareness campaign. (IIJA
§ 60502(3)(B)(ii)). The ACP final rules state that participating providers must publicize the
availability of ACP in a manner reasonably designed to reach consumers likely to qualify
and in a manner that is accessible to individuals with disabilities. FCC does not prescribe
specific forms of outreach that providers must use but does establish that providers must
collaborate with state agencies, public interest groups, and non-profit organizations on
public awareness campaigns and provides other guidance.
38
At the time of our review, according to FCC data, 10 of the providers we selected
accounted for nearly 80 percent of the program’s subscribers.
39
In May 2022, the White House announced it was partnering with two states
(Massachusetts and Michigan) and three cities (Mesa, Arizona; New York City; and
Philadelphia) to text millions of eligible households about ACP.
Page 22 GAO-23-105399 Affordable Broadband
Advocacy groups: Advocacy groups have also conducted a variety of
outreach efforts. For example, ACP Para Mi (ACP For Me) is a
nationwide partnership of local and national Latino organizations and
community leaders working to raise awareness for the program by
serving as a bilingual resource hub. This partnership provides
outreach content in English and Spanish, along with a step-by-step
guide for community advocates to help families navigate the ACP
enrollment process. The National Digital Inclusion Alliance, a nonprofit
focused on digital equity, published an extensive FAQ resource on its
website, and hosted a webinar titled “What You Need to Know about
the FCC Affordable Connectivity Program.”
FCC has translated ACP outreach materials into non-English languages,
but we found that the m
aterials did not always align with leading practices
for consumer-oriented content.
40
Specifically, FCC translated some of its
outreach materials (including webpages and items from its outreach
toolkit) into multiple non-English languages for use by individuals with
limited-English proficiency.
41
FCC employed an original translation
process used for materials it distributed when ACP launched and later
began updating this process in September 2022. In reviewing a selection
of the materials in five of the non-English languages (Chinese,
42
French,
Korean, Spanish, and Vietnamese), we found that the translations were
not always clear and accurate or complete (compared to the English
materials). We also found the translated materials did not always include
elements that make them practical or help manage users’ expectations
(such as directing a user to additional assistance or indicating when a
user will navigate to an English-only area). See figure 3 and the
discussion below.
40
U.S. Digital Service, Digital Services Playbook; U.S. Web Design System, Design
Principles; and General Services Administration, Top 10 Best Practices for Multilingual
Websites.
41
The ACP consumer-oriented webpages are available in Chinese, Korean, Spanish,
Tagalog, and Vietnamese. Items from the outreach toolkit are available in Arabic,
Chinese, French, Haitian-Creole, Korean, Portuguese, Russian, Spanish, Tagalog, and
Vietnamese.
42
The ACP webpages were translated into Traditional Chinese, while the outreach toolkit
items were available in both Traditional and Simplified Chinese, a form of written Chinese
where traditional Chinese characters have been simplified. We reviewed the webpage in
Traditional Chinese and toolkit items in Simplified Chinese to ensure coverage of both
forms of Chinese. For more detail, see appendix I.
FCC’s Language
Translation Process and
the Resulting Non-English
Program Outreach
Materials Do Not Fully
Align with Leading
Practices
Clarity
and
accuracy
Completeness Practicality
Managing
users’
expectations
Leading
practice
D
i
r
e
c
t
i
o
n
s
:
H
o
v
e
r
o
v
e
r
i
n
d
i
v
i
d
u
a
l
p
r
a
c
t
i
c
e
t
o
v
i
e
w
d
e
t
a
i
l
s
.
Figure 3: Selection of FCC’s Chinese, French, Korean, Spanish, and Vietnamese Affordable Connectivity
Program (ACP) Outreach Materials Compared with Leading Practices for Consumer-Oriented Content
To access a printable version of this interactive graphic, see appendix III.Print instructions
Page 23 GAO-23-105399 Affordable Broadband
Interactive graphic
Page 24 GAO-23-105399 Affordable Broadband
• Clarity and accuracy. According to leading practices for consumer-
oriented content, outreach materials should be written in clear, easy-
to-follow language that is factually accurate, and federal documents
should be identifiable as a federal product. We found that the Spanish
and Chinese materials were clear and easy to understand, but some
other non-English materials reviewed were difficult to understand. In
particular, we found clarity issues in the Korean and Vietnamese
materials. In the Korean content, we consistently found grammatical
errors, spacing issues (which, in the Korean language, may confer
incorrect or different meanings), and mistranslations that inadvertently
changed the meaning of the text.
43
We also found that the
Vietnamese webpages read as though they had been generated by a
machine translation, as they read unnaturally and were difficult to
parse.
Additionally, in most of the non-English materials we reviewed,
accurate information was conveyed; headings, images, and links were
accurately labeled; and hyperlinks functioned properly. However, we
also found some instances where inaccurate information could
confuse a user. For example, one response to a question on the
Korean Consumer FAQ webpage stated that households on tribal
lands may receive up to $70 (rather than $75) per month off their
broadband service, which is correctly listed elsewhere on other
Korean materials. In another instance, the Korean ACP main
webpage conveyed that the participating provider (rather than the
household) must contribute between $10 and $50 toward the
purchase of the device. The Spanish Consumer FAQ webpage
repeated the same question twice and listed a different response to
the question each time. We also found that a Spanish social media
image included English text. See figure 4 for these examples.
43
Korean relies on correct spacing to convey specific grammatical constructs, thus
missing or incorrect spacing in written Korean can create confusion in meaning.
Page 25 GAO-23-105399 Affordable Broadband
Figure 4: Examples of Duplicated Spanish Text on FCC’s Spanish Version of the
Affordable Connectivity Program Consumer FAQ Webpage and English Text on
Spanish Social Media Image
Page 26 GAO-23-105399 Affordable Broadband
• Completeness. Leading practices for consumer-oriented content call
for the content on non-English materials to match the content on the
English materials. We found that the content on the non-English
outreach toolkit items generally matched their English counterparts.
However, we also found that all of the non-English ACP main
webpages were missing information. Most lacked hyperlinks to the
FCC’s Complaint Center (where consumers can file an informal
complaint about ACP) and to the Consumer FAQ webpage.
44
The
non-English ACP main webpages were also missing information on
upcoming events and, in some cases, were missing the phone
number for the ACP Support Center. Consumers can call this center
to learn about the status of their application, documents needed to
prove eligibility, and participating providers that service the caller’s
area.
In addition, the leading practices describe the importance of
consistent maintenance of non-English content compared to its
English version. This allows users of both versions to have a
comparable experience. We found that FCC delayed updating the
non-English ACP main webpages. While the English version of this
webpage was updated in March 2022, the non-English versions had
not been updated since January 2022.
• Practicality. According to leading practices, consumer-oriented
content should be practical, allowing users to easily understand and
complete key tasks and directing users to additional assistance. We
found that all of the non-English materials we reviewed contained
information to direct users to begin the application process, such as
by listing instructions or directing users to the ACP website. However,
although many of the non-English materials also included the ACP
Support Center phone number, they did not disclose that callers could
receive assistance in other non-English languages. In fact, FCC
44
According to FCC officials, not linking to the center was a deliberate choice, as it is only
available in English. However, consistent with leading practices, in some other parts of its
non-English webpages, FCC included an indicator signaling when a user would navigate
to an English-only area.
Page 27 GAO-23-105399 Affordable Broadband
officials told us that callers can receive assistance in up to 200 non-
English languages via a third-party translator service.
45
• Managing users’ expectations. With respect to online content,
leading practices for consumer-oriented content state that the website
maintain users’ expectations on non-English websites by indicating
when a user will navigate to an English-only area. We found that the
Spanish webpages sometimes included a parenthetical en inglés (in
English), but the other non-English webpages did not disclose when
hyperlinks led to content in English.
FCC’s original translation process for producing these non-English
outreach materials varied slightly based on the target language. FCC
primarily used an internal (or, “in-house”) staff translator for Spanish
translations and a language translation contractor for other non-English
languages, as well as for Spanish when the staff translator was not
available. See figure 5.
45
FCC officials told us that callers may request to speak with a Spanish-speaking agent.
The other non-English languages are supported via a language service, which a caller
may request once connected to an agent. They added that, if an interpreter is available,
the interpreter joins the call and translates the conversation in real time. If an interpreter is
unavailable, the caller can leave a message, which could be translated and addressed
once an interpreter is available. FCC officials said that it is common for this type of service
to function this way.
Stakeholders’ Views on the Quality of
FCC’s Non-English ACP Outreach
Materials
Many stakeholders we spoke with stressed
the importance of non-English, culturally
competent outreach materials. Some said that
the Federal Communications Commission’s
(FCC) Affordable Connectivity Program (ACP)
translations were ineffective. For example,
one stakeholder that advocates for
populations with limited-English proficiency
said that FCC’s translated materials were so
poor that the group produced its own.
Furthermore, when the program launched as
ACP after the initial launch of the Emergency
Broadband Benefit program (EBB), some
stakeholders said the quality of the translated
materials had not improved, even though one
group had worked with FCC to improve
translated EBB materials. One stakeholder
said that FCC published ACP materials in
Portuguese, but labeled them as Spanish.
The stakeholder said FCC quickly remedied
the issue.
Source: GAO analysis of information from stakeholders. |
GAO-23-105399
Page 28 GAO-23-105399 Affordable Broadband
Figure 5: FCC’s Original Translation Process for Creating Non-English Affordable Connectivity Program Consumer Outreach
Materials
According to FCC documentation, under this original process, FCC’s
contractor had two quality assurance controls for translation tasks. First,
translators were required to meet certain language proficiency
requirements. FCC officials told us that they received documentation to
verify that translators met these requirements. As a second control,
FCC’s translation contract stated that the contractor would have at least
two native language or proficient individuals collaborate and review the
accuracy of each translation task assigned. According to FCC officials,
Page 29 GAO-23-105399 Affordable Broadband
FCC did not receive documentation that the contractor had completed this
second quality assurance control, but FCC staff had active discussions
with the contractor.
We found that this original process, which FCC used to produce ACP’s
non-English outreach materials, did not fully align with recommended
practices. In comparing FCC’s original language translation process to
recommended practices from U.S. Census Bureau guidance for
developing public-facing translated language products, we found that
FCC’s process lacked certain elements that could improve the quality and
effectiveness of its non-English materials. See table 4.
Table 4: Comparison of FCC’s Original Translation Process to Recommended Practices for Developing Public-Facing
Translated Language Products
Recommended practice
Description
How FCC’s translation process aligns
with the practice
1. Develop a plan for
designing and
producing translated
products
The plan reflects the translation’s goals and audience,
identifies which languages and what materials will be
translated, and serves to document the translation
workflow process and define the roles and
responsibilities of the translation team. When possible,
plans are informed by data, research, and results from
previous projects.
Partially aligns. FCC’s process did not
include a plan to identify the translation’s
goals, audience, and which languages would
be supported. However, it did describe how
FCC shares information on the target
audience with FCC’s contractor and staff
translator.
2. Incorporate review and
quality assurance steps
into the translation
process and document
these steps
A first translator completes an initial draft of the
translation, then a second translator (the reviewer)
reviews the draft, comparing it to the English version for
accuracy. As a final check, a quality assurance monitor
reviews the product to identify quality assurance issues.
This process is documented to ensure that all
requirements have been met.
Partially aligns. Translated drafts were to be
reviewed by at least one additional person to
review the draft for accuracy. However, FCC
did not require documentation to verify that
the contractor completed its quality
assurance processes.
3. Develop and test the
product with others who
represent its intended
audience
After the content is translated, translators and other staff
work together to ensure the translation is correctly placed
into its final format, such as a webpage or flyer. Once
placed, a diverse group of individuals who represent the
intended audience provides feedback on the product’s
effectiveness.
Partially aligns. FCC worked with the
contractor and staff translator to ensure the
translated content was correctly placed in its
final format. FCC considered external
feedback on translations after publication, but
did not test the product with a group that
represented its intended audience to
incorporate feedback before it was finalized.
4. Update and finalize the
product based on
testing results
The translation team incorporates appropriate feedback
into the final product. Then, the reviewer examines the
updated translation to ensure accuracy and that no other
changes are needed. Team members review the final
product to ensure translations were inserted correctly
and all requirements have been met.
Does not align. FCC did not solicit feedback
from its intended audience to incorporate into
a final product prior to publication, so it could
not update and finalize the product based on
that feedback.
Source: GAO analysis of Federal Communications Commission (FCC) information and U.S. Census Bureau, Developing Public-Facing Language Products: Guidance from the 2020 Census Language
Program (Nov. 3, 2021). | GAO-23-105399
Page 30 GAO-23-105399 Affordable Broadband
Regarding the gaps in its translated content and translation process, FCC
officials told us that the compressed timelines associated with launching
ACP affected their ability to produce non-English outreach materials in full
alignment with recommended practices. For example, they told us that
conducting testing through focus groups or surveys would have
significantly delayed the production of materials. In September 2022, FCC
updated its original language translation process as part of a change in its
language translations contractor. The updated process addresses some,
but not all, of the gaps we identified. For example, the updated process
includes additional quality assurance steps for FCC’s contractor. In
particular, according to documentation from FCC’s contractor, an editor
will review and proofread translators’ work to help ensure quality, and
FCC requires the contractor to provide certification of these individuals’
credentials. The October 2022 performance work statement for the new
contractor also includes requirements for the contractor to maintain a
quality control plan and, according to documentation from the contractor,
results from the contractor’s quality reviews are documented. However, it
is unclear how FCC is documenting that all quality assurance steps are
taken for translated materials produced when FCC’s internal translators
and reviewers are involved for Spanish translations (which, based on the
updated process, are still produced predominately by FCC staff, not the
contractor).
The updated process also does not reflect an overall plan for designing
and producing translated products. While some FCC and contractor
documentation reference elements of a plan, such as the types of
audiences and languages, it does not constitute a comprehensive plan.
Additionally, the updated process—like the original one—does not include
testing of the translated material with those who represent the intended
audience prior to publication. Such testing could take place through a
variety of methods, such as by providing the materials to stakeholder
groups for feedback.
Producing quality non-English content is key to informing eligible
households with limited-English proficiency, which may include
households from communities FCC has indicated are important to reach.
Specifically, FCC has acknowledged the importance of its outreach efforts
reaching people of color, persons with disabilities, persons who live in
rural or tribal areas, and others who are or have been historically
unserved, marginalized, or adversely affected by persistent poverty or
Page 31 GAO-23-105399 Affordable Broadband
inequality.
46
Without a sufficient language translation process, FCC may
continue to produce and distribute non-English ACP outreach materials
that lack the quality necessary to help those with limited-English
proficiency understand and use the information, which could hamper their
ability to enroll in the program.
Although FCC has completed a variety of ACP outreach efforts, it has not
developed an outreach plan to guide these activities. According to FCC
officials, FCC has largely leveraged the outreach infrastructure from the
program’s predecessor, EBB, (such as tools, strategies, and
partnerships) to inform its new, ACP outreach efforts. These officials said
that FCC had not created an ACP outreach plan due to the compressed
timelines for launching ACP required by the IIJA.
The FCC officials added that FCC was in the process of developing a
plan that makes use of expanded outreach tools specified in the IIJA but
could not provide a specific timeline of when one would be completed.
47
FCC officials told us that they are currently pursuing contracting and
personnel to implement these tools, which include an outreach grant
program, paid media campaigns, and focus groups. FCC has issued rules
for the grant program, which will fund partners’ outreach efforts, and for a
separate pilot program focused on increasing ACP awareness among
households that receive federal housing assistance.
48
Many stakeholders
we spoke with generally agreed that these tools would increase
awareness of ACP, especially the grant program.
We have previously determined that agencies should have a plan for
outreach activities to help them overcome challenges that may emerge,
and identified nine leading practices for such planning, as show in table
5.
49
46
FCC 22-2, para. 194.
47
IIJA § 60502(a)(3)(B)(ii), adding 47 U.S.C. § 1752(b)(10)(C).
48
In the Matter of Affordable Connectivity Program, Second Report and Order, FCC 22-64
(2022); and In the Matter of Affordable Connectivity Program, Third Report and Order,
FCC 22-65 (2022).
49
GAO-08-43. In 2021, we recommended that FCC develop and implement a plan to
educate eligible consumers about requirements for Lifeline and the Verifier that align with
these leading practices, since we found that FCC’s consumer education plan for these
also did not fully align with these practices. See GAO-21-235. While USAC developed a
plan in response to this recommendation, the recommendation remains open as of
October 2022 because it does not yet fully align with the practices.
FCC Has Not Developed a
Consumer Outreach Plan
for ACP
Page 32 GAO-23-105399 Affordable Broadband
Table 5: Leading Practices for Planning Effective Consumer Outreach
Leading practice
Description
Analyze the situation
Analyze the situation, including key target dates and competing voices or messages.
Review relevant past experiences to identify applicable “lessons learned” that may help
guide efforts.
Identify stakeholders
Identify and engage all key stakeholders involved in outreach efforts and clarify their roles
and responsibilities.
Identify credible messengers
Identify who will be delivering the messages and ensure that the source is credible with
audiences.
Design media mix
Plan the media mix (e.g., online, print, broadcast) to optimize earned media (e.g., news
stories, opinion editorials) and paid media.
Define goals and objectives
Define the goals of the outreach campaign and the objectives that will help the campaign
meet those goals.
Identify resources
Identify available short-term and long-term budgetary and other resources.
Research target audiences
Conduct audience research and measure audience awareness. Identify any potential
audience-specific obstacles, such as access to information.
Develop consistent, clear messages
Develop clear and consistent audience messages based on budget, goals, and audience
research findings.
Establish metrics to measure success
Establish both process and outcome metrics to measures success in achieving objectives
of the outreach campaign.
Source: GAO-08-43. | GAO-23-105399
Although FCC has not created an ACP outreach plan, FCC developed an
outreach plan for the program’s predecessor, EBB. However, we found
this plan did not fully align with these leading practices. Specifically, we
found the EBB outreach plan partially aligned with some practices and did
not align with others. For example, as part of planning a mix of different
media (e.g., online, print, broadcast), the plan referenced earned media
methods, but did not strategize how to optimize them with other media or
specify the frequency or duration. FCC officials told us that the
compressed timelines associated with launching EBB did not allow them
to develop a plan that fully aligned with these practices, though they
adapted their approaches as the program progressed. In response to the
evolving pandemic environment, FCC used a phased outreach plan to
guide its efforts when EBB launched, and FCC officials told us that they
intend to build on elements of this previous plan for ACP.
ACP outreach involves numerous stakeholders and efforts, and—as
established in the ACP final rules—a $100 million budget, making it a
complex undertaking that could benefit from a comprehensive plan to
ensure these funds are effectively used to reach the target audience.
50
50
FCC 22-2, para. 193.
Page 33 GAO-23-105399 Affordable Broadband
For example, as ACP continues to grow and additional stakeholders
emerge, it will be even more important for FCC to align stakeholders to
relay consistent messages, as inconsistent messaging could confuse
households. Indeed, one stakeholder we spoke with noted that variation
in messaging is likely to confuse those who may be interested in the
program. While we acknowledge the compressed timelines that FCC
faced and that some of FCC’s planned outreach tools are still in
development, a consumer outreach plan could drive the development of
these tools, including the development of newer tools. For example, a
plan could help guide FCC in making decisions about what mix of tools
will be most effective in helping FCC meet its goal of raising awareness of
and participation in the program.
FCC has taken some steps to manage fraud risks in ACP. For example, it
has identified the Office of Managing Director to lead fraud risk
management activities at the agency, including for ACP. Additionally,
FCC assessed fraud risks in ACP in May 2022. However, some of FCC’s
efforts do not fully align with leading practices in the Fraud Risk
Framework.
51
Specifically, FCC has not established a process to ensure
that fraud risk assessments for ACP occur on a regular basis or that
these assessments are updated to reflect changes to the program.
Further, FCC has not developed an antifraud strategy to address the risks
identified in its assessment. Finally, FCC has not developed processes to
monitor its fraud management activities, including certain antifraud
controls, which could provide valuable information for assessing and
responding to fraud risks.
51
GAO-15-593SP.
FCC Has Taken
Steps to Manage
Fraud Risks in Its
New Broadband
Affordability Program,
but Its Efforts Do Not
Fully Align with
Selected Leading
Practices
Page 34 GAO-23-105399 Affordable Broadband
Consistent with a leading practice outlined in our Fraud Risk Framework,
FCC identified a dedicated entity to lead fraud risk management activities
across the agency. Specifically, in July 2020, FCC issued its Antifraud
Directive to lay out high-level policies for managing fraud risks in its
programs.
52
The directive named FCC’s Office of Managing Director as
the entity to lead fraud risk management activities in FCC programs,
which includes ACP. According to FCC officials, the Enterprise Risk
Management Group within this office will function as the dedicated entity.
As discussed further below, the dedicated entity’s responsibilities for
overseeing fraud risk management activities for ACP will be critical as
these activities mature.
52
FCC, Policy for Detecting and Deterring Fraud and Promoting Ethical Conduct within the
FCC, FCCINST 1102.6 (Washington, D.C.: July 2020).
FCC Identified a
Dedicated Entity to Lead
Fraud Risk Management
Activities
Fraud Risk Framework Component:
Commit to combating fraud by creating an
organizational culture and structure conducive
to fraud risk management
Source: GAO-15-593SP. | GAO-23-105399
Page 35 GAO-23-105399 Affordable Broadband
In May 2022, FCC conducted a fraud risk assessment for ACP. We found
that this assessment generally aligned with five leading practices for
identifying and assessing fraud risks. However, FCC has not met two
related leading practices for planning regular fraud risk assessments.
Specifically, FCC has not (1) developed a process to conduct such
assessments at regular intervals or when there are changes to the
program or (2) identified specific tools, methods, and sources for
gathering information about fraud risks.
FCC assessed fraud risks in ACP in May 2022. Prior to this effort, FCC
had not assessed fraud risks in ACP or the program’s predecessor,
EBB.
53
We found that FCC’s fraud risk assessment for ACP generally
aligned with the Fraud Risk Framework’s five leading practices for
identifying and assessing risks. These practices include (1) identifying
inherent fraud risks, (2) assessing the likelihood and impact of those
risks, (3) determining fraud risk tolerance, (4) examining the suitability of
existing fraud controls and prioritizing residual risks, and (5) documenting
the program’s fraud risk profile. For example, FCC identified and
assessed 24 inherent fraud risks related to ACP and documented its
assessment in a fraud risk profile. The profile summarizes risks compared
to FCC’s risk tolerance, related antifraud controls, and suggested
mitigation efforts for each identified risk. While FCC generally followed
53
FCC conducted a programmatic risk assessment for EBB in May 2021. Although this
risk assessment considered fraud, it was not a fraud risk assessment as outlined by
leading practices in the Fraud Risk Framework.
FCC Assessed Fraud
Risks for ACP but Lacks a
Process to Ensure Such
Assessments Occur
Regularly or Are Updated
Fraud Risk Framework Component:
Plan regular fraud risk assessments and
assess risks to determine a fraud risk profile
Source: GAO-15-593SP. | GAO-23-105399
May 2022 Fraud Risk
Assessment
Page 36 GAO-23-105399 Affordable Broadband
leading practices for assessing fraud risks, we identified concerns related
to two aspects of the assessment, concerns that are discussed later in
this report.
54
FCC has not established a process to ensure that it regularly assesses
fraud risks in ACP in the future or revisits the assessment if there are
changes to the program. According to the Fraud Risk Framework, a
separate leading practice for fraud risk management is to plan to conduct
fraud risk assessments at regular intervals and when there are changes
to the program or operating environment, as assessing fraud risks is an
iterative process.
FCC has not established such a process because responsibilities for
these assessments—and, in turn, any processes to regularly conduct
them—are not clearly defined. FCC’s Antifraud Directive outlines, at a
high-level, the agency’s intention to manage fraud risks in its programs,
including assessing fraud risks regularly. The Directive explains that fraud
risks will be considered as part of the agency’s broader enterprise risk-
management process. The Fraud Risk Framework acknowledges that
agencies may use initiatives like enterprise risk management to assess
fraud risks, but that does not eliminate the need for separate and
independent fraud risk-management efforts.
55
For example, assessing
entity-level risks as part of enterprise risk management may not devote
sufficient attention to program-level fraud risks. FCC officials stated that
they understood the distinction between these concepts and explained
that the agency will be assessing its programs’ fraud risks separately from
its enterprise risk management process. In an August 2022 presentation
to its Senior Management Council, FCC noted that its next steps for fraud
risk management include formalizing its governance framework for fraud
risk management, including a methodology for fraud risk assessments
conducted on a 3-year cycle. Currently, responsibilities and schedules for
54
The concerns related to (1) the consideration of prior programs when assessing the
likelihood of inherent fraud risks and (2) the examination of existing controls and how they
mitigate identified fraud risks.
55
In October 2022, the Office of Management and Budget issued an alert reminding
agencies that, consistent with the guidelines contained in OMB Circular A-123, they must
establish financial and administrative controls to identify and assess fraud risks. In
addition, the office reminded agencies that they should adhere to the leading practices in
GAO’s Fraud Risk Framework as part of their efforts to effectively design, implement, and
operate an internal control system that addresses fraud risks, which includes fraud risks
that do not rise to the level of enterprise-wide risks. See Office of Management and
Budget, Establishing Financial and Administrative Controls to Identify and Assess Fraud
Risk, CA-23-03 (Oct. 17, 2022).
No Process for Planning
Regular Fraud Risk
Assessments or Identifying
Information Sources
Page 37 GAO-23-105399 Affordable Broadband
fraud risk assessments in ACP (or any FCC program) are not
documented in the Antifraud Directive or other policies.
Additionally, FCC has not identified specific tools, methods, and sources
for gathering information about fraud risks, which is a related leading
practice for planning regular fraud risk assessments outlined in our Fraud
Risk Framework. We identified an area in which FCC may have
understated the likelihood of certain risks in its May 2022 fraud risk
assessment by overlooking available information from the Lifeline
program. As part of its assessment, FCC considered whether the
identified risks had been observed in similar programs, including in EBB
and Lifeline. According to the assessment, 20 of the 24 identified risks
had not been observed. However, as described below, we identified
multiple instances where these risks appear to have occurred in Lifeline,
even though FCC’s assessment indicated they have not been observed in
similar programs.
• Lack of data on non-usage of broadband service. According to
FCC’s assessment, the lack of non-usage data resulting from a
system not properly tracking usage could lead to participating
providers receiving reimbursements for program subscribers who are
not using their broadband service.
56
We identified similar issues
related to two Lifeline program violations. For example, in one
instance, FCC reported that a provider identified a flaw in the
provider’s system used to monitor its Lifeline service usage, which
affected the number of subscribers that should have been de-enrolled
for non-usage. FCC determined that the provider continued to seek
reimbursement for ineligible subscribers.
• Reimbursement claim falsification. According to FCC’s
assessment, intentional submission of incorrect reimbursement
amounts or failure to revise claims when errors are identified presents
a risk of program fraud. We identified similar issues in a Lifeline
program violation. Specifically, FCC reported that a provider
submitted a significant amount of claims for subscribers who were
ineligible or should have been de-enrolled, even after it had known of
the issues. The issues included deceased subscribers and
subscribers who did not use the provider’s Lifeline service.
56
Non-usage refers to certain instances in which subscribers who receive their broadband
service free (after discounts are applied) do not use the service.
Page 38 GAO-23-105399 Affordable Broadband
• Failure of timely de-enrollment. According to FCC’s assessment,
delaying necessary de-enrollment of a subscriber could result in
collection of additional months of reimbursements.
57
We identified a
similar issue in a Lifeline program violation. Specifically, a provider
indicated that it had received Lifeline overpayments because of its
failure to de-enroll ineligible non-usage and other subscribers, even
after it represented to FCC that it had corrected the issues.
Formally documenting a process to assess fraud risks regularly—with
clear responsibilities for such assessments and specific tools, methods,
and sources of information about fraud risks to be used in the
assessment—can help ensure that fraud risk management activities are
carried out. This is especially notable given that effective fraud risk
management is an iterative process and that assessments are to
leverage useful, available information about fraud risks facing the
program.
57
Although timeframes may differ given the circumstances, ACP rules generally require
providers to de-enroll subscribers who (1) are no longer eligible for the program, (2)
receive duplicative support, (3) do not meet non-usage requirements, (4) fail to recertify
their eligibility when required, or (5) request to be de-enrolled.
Page 39 GAO-23-105399 Affordable Broadband
Although FCC has assessed fraud risks in ACP, it has not yet developed
an antifraud strategy for the program based on the fraud risk profile.
According to the Fraud Risk Framework, a leading practice for managers
who effectively manage fraud risk is to develop and document an
antifraud strategy that describes the program’s activities for preventing,
detecting, and responding to the risks identified in the fraud risk profile.
According to FCC officials, FCC is reviewing the actions suggested by the
contractor that prepared FCC’s ACP fraud risk assessment and will
develop a plan for implementing those actions, as appropriate.
58
The
officials said FCC is also planning to determine whether residual fraud
risks—such as issues related to participating providers claiming
reimbursements for subscribers who did not use the service—require
additional internal controls. While these steps are important for
addressing residual risks identified in the assessment, they do not
constitute an antifraud strategy as outlined in our framework. Specifically,
key elements of an antifraud strategy include identifying what the agency
is doing to manage fraud risks in the program and roles and
responsibilities for fraud risk management activities (see fig. 6).
59
58
As noted in the Fraud Risk Framework, managers consider the benefits and costs of
control activities to address identified residual risks when developing an antifraud strategy.
59
As discussed above, FCC’s Antifraud Directive outlines high-level policy for fraud risk
management for the agency, but it does not document responsibilities for fraud risk
management activities for ACP.
FCC Has Not Developed
an Antifraud Strategy for
ACP
Fraud Risk Framework Component:
Design and implement a strategy with specific
control activities to mitigate assessed fraud
risks and collaborate to help ensure effective
implementation
Source: GAO-15-593SP. | GAO-23-105399
Page 40 GAO-23-105399 Affordable Broadband
Figure 6: Key Elements of an Antifraud Strategy
Developing an antifraud strategy that aligns with the leading practices in
the Fraud Risk Framework would help ensure that FCC effectively
manages the risks identified in its fraud risk profile. Such a strategy would
also fully and clearly establish roles and responsibilities for those involved
in fraud risk management activities for ACP.
Page 41 GAO-23-105399 Affordable Broadband
FCC has not developed processes to comprehensively or regularly
monitor its ACP fraud risk management activities, including its fraud risk
assessment and certain antifraud controls. The Fraud Risk Framework
notes that monitoring and evaluating the effectiveness of antifraud
activities, including fraud risk assessments and antifraud controls, is a
leading practice for fraud risk management. Such monitoring processes
can produce useful information to support efforts to consider how existing
controls mitigate fraud risks as part of a fraud risk assessment.
While FCC’s ACP fraud risk assessment generally aligned with leading
practices in the Fraud Risk Framework for conducting those
assessments, as discussed above, we identified concerns related to
FCC’s consideration of how existing controls mitigate identified risks. The
ACP fraud risk assessment acknowledges that the consideration of how
existing controls mitigate fraud risks is subjective. However, we identified
issues related to three major controls for ACP: (1) duplicate subscriber
check, (2) identity verification, and (3) address validation.
60
FCC did not
consider these issues in its fraud risk assessment because it did not
comprehensively monitor these controls. The issues we identified call into
question whether the controls are having their intended effect—to prevent
and detect fraud—and their mitigation of identified fraud risks.
61
FCC uses its enrollment database to prevent duplicate subscribers in
ACP (and Lifeline) as the ACP discounts are limited to one per
household. However, we identified over 2,500 potential duplicate
subscribers in the ACP enrollment data as of April 1, 2022. The specifics
of these potential duplicates vary, although the majority of them have at
least slight variations in personally identifiable information (PII), like name
60
We analyzed a snapshot of ACP enrollment data as of April 1, 2022. The enrollment
data contain information on approximately 11.2 million households enrolled in ACP as of
that date.
61
We plan to share the results of our data analytics with FCC for additional review and
action, as appropriate.
FCC Has Not Developed
Processes to Monitor Its
ACP Fraud Risk
Management Activities,
including Certain Antifraud
Controls
Fraud Risk Framework Component:
Evaluate outcomes using a risk-based
approach and adapt activities to improve fraud
risk management
Source: GAO-15-593SP. | GAO-23-105399
Duplicate Subscriber Check
Page 42 GAO-23-105399 Affordable Broadband
or date of birth (similar to prior Lifeline program violations).
62
The
remaining potential duplicates appear to have identical PII. We analyzed
ACP reimbursements for a non-generalizable sample of 60 pairs of these
potentially duplicative subscribers. We identified that providers received
simultaneous reimbursements for 26 of 45 pairs of potential duplicates
with variation among PII, and 0 of 15 pairs of potential duplicates with
identical PII.
63
Figure 7 illustrates an anonymized example of potentially
duplicative subscribers for which participating providers received
simultaneous reimbursements.
62
For this analysis, we reviewed first name, middle name, last name, date of birth, phone
number, the last four digits of the Social Security number, and primary address fields
(street address, city, state, and ZIP code). Some subscribers are eligible for ACP through
a benefit-qualifying person, who is another household member, such as a child or
dependent. We did not review personal information in the fields related to the benefit-
qualifying person. In September 2022, the FCC Office of the Inspector General reported
on several instances in which multiple subscribers used the same child’s personal
information to enroll in ACP. According to FCC, the agency is taking steps to address
issues related to the benefit-qualifying person.
63
Potentially ineligible households for which providers did not submit reimbursement
claims still represent a risk of potential fraud. All households in a snapshot of ACP
enrollment data may be claimed for reimbursement, though providers should only claim
households if they received and used service during the relevant month. Providers have
up to 6 months from the snapshot date to submit claims or upward revisions on prior
claims. Additionally, we identified 10 pairs of potential duplicates with varied PII and seven
pairs of potential duplicates with identical PII that had claims activity on both potential
duplicate subscribers but in different months. Claims history in both potential duplicate
subscribers presents a fraud risk, even if the claims for those potential duplicates do not
overlap.
Page 43 GAO-23-105399 Affordable Broadband
Figure 7: Example of Anonymized Potential Duplicate Subscribers and Their
Related Claims in FCC’s Affordable Connectivity Program
a
Internet service providers are allowed 6 months to submit and revise reimbursement claims in the
program, so claims for May and June 2022 may be submitted after we pulled claims data for this
example.
Verification of identity depends on how an applicant applies for ACP. For
applicants applying through the Verifier, FCC uses a third-party vendor to
verify the applicant’s identity by using personal information, like name and
date of birth, entered on the application.
64
According to agency officials,
applicants who do not apply through the Verifier are not subject to this
identity verification, although participating providers who use their
alternative verification processes to determine eligibility and enroll
64
According to USAC officials, the third-party vendor uses last name, date of birth, and the
last four digits of an applicant’s Social Security number to verify identity. If applicants do
not provide the last four digits of their Social Security number, they are required to submit
additional documentation, such as a driver’s license or passport. However, according to
USAC officials, the third-party vendor can verify identity in most cases, regardless of
whether the applicant provides the last four digits of the Social Security number.
Identity Verification
Page 44 GAO-23-105399 Affordable Broadband
subscribers directly are expected to use verification processes at least as
stringent as the Verifier.
Our analysis of ACP enrollment data identified subscribers with
questionably old and young dates of birth. Specifically, we identified over
200 subscribers whose dates of birth were over 110 years old and 109
subscribers whose dates of birth were over 120 years old. The majority of
these subscribers were enrolled through providers’ alternative verification
processes, which bypass FCC’s third-party identification process
described above. Conversely, we identified 20 subscribers whose dates
of birth were under 10 years old and 12 subscribers whose dates of birth
were under 5 years old.
65
All of these subscribers were enrolled through
the Verifier and should have been verified by FCC’s third-party identity
verification process.
We also identified ACP subscribers who provided partial Social Security
numbers that do not match records from the Social Security
Administration. As mentioned earlier, a vendor validates the identities of
applicants who submit information through the Verifier using name, date
of birth, and if provided, the last four digits of the applicant’s Social
Security number. Based on our analysis, we found that over 874,000
(over 10 percent) of the approximately 8.5 million ACP subscribers who
included the last four digits of their Social Security number did not match
records in the Social Security Administration’s Enumeration Verification
System. These mismatches may be due to inaccurate identifying
information and could be caused by non-fraudulent issues, like data entry
errors. Nonetheless, these mismatches represent a fraud risk that
monitoring processes may flag for further review.
Validation of an applicant’s address depends on how the individual
applies for ACP. For applicants applying through the Verifier, FCC uses
U.S. Postal Service data to validate addresses prior to enrollment.
66
According to agency officials, applicants who do not apply through the
Verifier are not subject to this address validation, although participating
providers who use an alternative verification process are expected to use
verification processes at least as stringent as the Verifier. Our analysis of
65
This includes two subscribers whose dates of birth were less than a month before their
broadband service began.
66
If the address cannot be validated through this system, applicants may be able to
electronically drop a pin on a map and submit documentation (such as a utility bill or
mortgage or lease statement) to verify their address.
Address Validation
Page 45 GAO-23-105399 Affordable Broadband
ACP enrollment data against U.S. Postal Service data identified
addresses flagged as: (1) PO Boxes or commercial mailboxes, (2) having
missing or invalid secondary information, and (3) unique ZIP codes that
may warrant additional attention.
67
Although not all cases may be
indicative of potential fraud, they represent issues that monitoring
processes should flag for further review.
• PO Boxes and commercial mailboxes.
68
The ACP application
explains that the primary address should be where the subscriber
receives broadband service and instructs applicants to not provide a
PO Box as a primary address. PO Box and commercial mailbox
addresses raise questions about where the service is being
provided—particularly for wired service—and can hinder efforts to
enforce ACP’s one-per-household rule. Our analysis of ACP
enrollment data flagged over 4,200 primary addresses as PO Boxes
and over 6,600 primary addresses as commercial mailboxes.
69
Further, our analysis flagged 85 of these PO Box addresses and 126
of these commercial mailbox addresses that reportedly received wired
service at those locations. Furthermore, in reviewing selected
addresses to visit, we identified one PO Box and one commercial
mailbox at locations that have closed or been demolished, with
service initiation dates that appear to be after the locations were
closed or demolished. Finally, we identified subscribers using
commercial mailboxes as primary addresses and participating
provider retail locations as mailing addresses. This type of
arrangement could misdirect efforts to contact the household or mask
a fictitious enrollment. We identified 10 different provider retail
locations in our review of commercial mailbox addresses. Across the
enrollment data, we identified over 275 households with one of these
provider retail locations as either a primary or mailing address.
70
Figure 8 shows examples of these issues.
67
We also identified addresses that did not match U.S. Postal Service records and
addresses flagged as vacant.
68
According to U.S. Postal Service guidance, a Commercial Mail Receiving Agency
receives and handles mail for a client. An example of this type of entity is a United Parcel
Service store. For purposes of this report, we refer to Commercial Mail Receiving
Agencies as commercial mailboxes.
69
An address flagged as a commercial mailbox may not be inherently indicative of
potential fraud. For example, a homeless shelter may be designated as a commercial
mailbox if it collects and distributes mail.
70
We did not conduct a comprehensive review of ACP enrollment data to identify provider
retail location addresses.
Page 46 GAO-23-105399 Affordable Broadband
Figure 8: Examples of Issues Related to PO Box and Commercial Mailbox Addresses in Affordable Connectivity Program
Enrollment Data
• Missing or invalid secondary address information. Secondary
address information includes elements like apartment or floor number.
This information is important for FCC to identify potentially duplicative
subscribers and enforce the one-per-household rule. Our analysis
identified over 289,000 subscriber addresses flagged as missing
expected secondary address information. Additionally, we identified
over 514,000 subscriber addresses flagged when dropping the
secondary information entered (i.e., primary addresses were valid, but
secondary address information was invalid).
71
• Unique ZIP codes. According to the U.S. Postal Service, unique ZIP
codes are assigned to companies, government agencies, or other
entities with sufficient mail volume. Our analysis flagged over 700
ACP subscriber addresses with unique ZIP codes. Use of a unique
ZIP code is not inherently indicative of potential fraud. For example,
college campuses may have unique ZIP codes, and Pell grant
recipients are eligible for ACP. However, some of the unique ZIP
71
Invalid secondary address information may not be inherently indicative of potential fraud.
For example, subscribers listing the address of a homeless shelter or health care facility
like a nursing home may include information beyond U.S. Postal Service address records.
Page 47 GAO-23-105399 Affordable Broadband
codes flagged in our analysis raise questions about the corresponding
subscribers. For example, we identified subscribers with unique ZIP
codes related to prisons, commercial sites like banks, and Business
Reply Mail services.
72
FCC did not consider these types of issues related to significant antifraud
controls as part of its fraud risk assessment because it has not
established monitoring processes for these controls (specifically,
duplicate subscriber prevention, identity verification, and address
validation). As noted above, the Fraud Risk Framework calls for
managers to monitor and evaluate the effectiveness of antifraud activities,
including fraud risk assessment and antifraud controls. Additionally,
another leading practice in the Fraud Risk Framework is to use the results
of monitoring and evaluations to improve the design and implementation
of fraud risk management activities. For example, monitoring processes
can produce useful information to support efforts to consider how existing
controls mitigate fraud risks as part of a fraud risk assessment.
According to FCC officials, FCC has not established monitoring
processes because most of the controls identified above are automated.
They explained that some manual controls are monitored. For example,
manual review of ACP applications includes a quality assurance review to
ensure that eligibility decisions were made appropriately. Additionally,
FCC officials noted that USAC’s program integrity reviews may capture
quality assurance information for specific controls, although these reviews
are not specifically designed for this purpose. These efforts can result in
useful information for monitoring certain controls, but they do not enable
FCC to comprehensively monitor its antifraud controls.
Without sufficient monitoring of its antifraud controls, including automated
controls, FCC lacks assurance that its antifraud efforts are effectively
preventing, detecting, and responding to fraud, and safeguarding program
funds. Further, such monitoring processes can produce information to
more effectively assess inherent fraud risks and consider the effect of
antifraud controls in reducing those risks.
ACP represents a significant investment in closing the digital divide, and
FCC has made significant progress in quickly implementing the program
under the timelines required by the IIJA. FCC’s efforts to establish
72
Business Reply Mail is a service that enables a sender to provide a recipient with a
prepaid method for replying to a mailing and is frequently used by direct marketers,
researchers, publishers, and other businesses.
Conclusions
Page 48 GAO-23-105399 Affordable Broadband
program performance goals and measures, dedicate funds to outreach
and translate its outreach materials into non-English languages, and
conduct a program fraud risk assessment demonstrate its commitment to
the program’s success. As FCC continues to implement and mature the
program, including refining its goals and measures, translation process
and outreach planning, and fraud risk management activities, it could
strengthen the program’s effectiveness—and its ability to clearly
demonstrate program accomplishments—by better aligning these efforts
with leading practices. For example, by aligning its goals and measures
with key attributes of effective goals and measures, revising the language
translation process, and developing a plan to guide consumer outreach
activities, FCC will be better positioned to ensure the program’s success.
Similarly, by developing and implementing an antifraud strategy and
monitoring antifraud controls (and then using information from monitoring
to regularly assess fraud risks and evaluate fraud risk management
activities), FCC will be better positioned to manage fraud risks to the
program and, ultimately, ensure the best use of the program’s funds.
We are making the following nine recommendations to FCC:
The Chair of FCC should ensure that ACP performance goals and
measures align with key attributes of effective performance goals and
measures. (Recommendation 1)
The Chair of FCC should revise the language translation process (for
both “in-house” and contracted translations, as appropriate) for
developing ACP non-English outreach materials to include the following
steps: (1) develop a plan for designing and producing translated products;
(2) incorporate review and quality assurance steps into the translation
process and document completion of these steps during each process;
(3) develop and test the products with others who represent the intended
audience; and (4) update and finalize the products based on development
and testing results. (Recommendation 2)
The Chair of FCC should develop a consumer outreach plan, which aligns
with leading practices for consumer outreach planning, to educate eligible
consumers about ACP. (Recommendation 3)
The Office of the Managing Director should develop and implement a
process, with clearly defined responsibilities and sources of information
on fraud risks, for conducting fraud risk assessments for ACP at regular
intervals and when there are changes to the program or operating
environment. (Recommendation 4)
Recommendations for
Executive Action
Page 49 GAO-23-105399 Affordable Broadband
The Office of the Managing Director should develop and implement an
antifraud strategy for ACP that aligns with leading practices in the Fraud
Risk Framework. These practices include documenting and
communicating the program’s activities for preventing, detecting, and
responding to fraud and establishing roles and responsibilities of those
involved in fraud risk management activities. (Recommendation 5)
The Office of the Managing Director should develop and implement
processes to monitor antifraud controls related to preventing duplicate
subscribers in ACP. (Recommendation 6)
The Office of the Managing Director should develop and implement
processes to monitor antifraud controls related to subscriber identity
verification in ACP. (Recommendation 7)
The Office of the Managing Director should develop and implement
processes to monitor antifraud controls related to subscriber address
validation in ACP. (Recommendation 8)
The Office of the Managing Director should use information obtained from
monitoring processes to improve the design and implementation of fraud
risk management activities in ACP, including its fraud risk assessment
and subsequent antifraud strategy. (Recommendation 9)
We provided a draft of this report to FCC for review and comment.
In its comments, reproduced in appendix IV, FCC agreed with our
recommendations and described its plans to address each one. For
example, regarding our recommendation to ensure that ACP performance
goals and measures align with key attributes of effective performance
goals and measures, FCC described actions to collect information and
establish targets. Regarding our recommendation to revise the language
translation process for ACP outreach materials, FCC described actions it
is taking or plans to take in line with the steps detailed in the
recommendation, such as developing a quality control process for internal
translations. Similarly, regarding our recommendation to develop a
consumer outreach plan, FCC described its ongoing and planned actions,
such as developing a national strategy to promote ACP. Finally, regarding
our recommendations related to various processes for managing fraud
risks, FCC also described various implementation steps, such as
updating its policies and procedures and working with a contractor to
develop an antifraud strategy.
Agency Comments
and Our Evaluation
Page 50 GAO-23-105399 Affordable Broadband
Although FCC agreed with our recommendation related to ACP
performance goals and measures, it disagreed with two aspects of the
related analysis.
• First, regarding the measure on overall consumer burden and FCC’s
monthly-dollar-figure metric, FCC disagreed that using the monthly
dollar figure to measure overall consumer burden will be distorted by
increased participation. The ACP final rules establish that FCC will
calculate this metric by dividing the annual expenditures of the
program by the number of households in the U.S., with the total being
a monthly dollar amount. However, in its comments on the draft
report, FCC appears to describe a different calculation related to the
program’s administrative costs per subscriber. Our report notes that
FCC’s goals and measures lack clarity and this example (i.e., the
difference between what is described in the final rules versus in FCC’s
comments) further illustrates that FCC’s goals and measures could be
strengthened by additional clarity.
• Second, FCC disagreed that its goals do not meet the crosscutting
criteria. FCC notes, for example, areas where performance
information it captures for ACP could also be relevant for Lifeline. We
agree that performance information for ACP could also be relevant for
Lifeline, given that ACP and Lifeline share similarities. However, as
stated in our report, the lack of specificity regarding what targets FCC
is measuring means it is unclear how FCC will gauge the performance
of ACP and Lifeline relative to each other. In its comments on the draft
report, FCC describes actions it will take to implement our
recommendation, including actions that will help to clarify what,
specifically, it is measuring and what the targets are. These actions
could, in turn, aid in making it clearer how exactly FCC is gauging
ACP and Lifeline relative to each other and permit FCC to compare
results.
We also provided relevant report excerpts related to the Enumeration
Verification System to the Social Security Administration for technical
comment. The Social Security Administration provided technical
comments, which we incorporated as appropriate.
As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 7 days from the
report date. At that time, we will send copies to the appropriate
congressional committees, the Chairwoman of FCC, and other interested
parties. In addition, the report will be available at no charge on the GAO
website at https://www.gao.gov.
Page 51 GAO-23-105399 Affordable Broadband
If you or your staff have any questions about this report, please contact
me at (202) 512-2834 or [email protected]. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this report
are listed in appendix V.
Andrew Von Ah
Director, Physical Infrastructure
Appendix I: Objectives, Scope, and
Methodology
Page 52 GAO-23-105399 Affordable Broadband
This report examines the extent to which the Federal Communications
Commission’s (FCC) Affordable Connectivity Program (ACP) efforts align
with relevant selected leading practices in: (1) establishing performance
goals and measures; (2) conducting outreach; and (3) managing fraud
risks.
To assess FCC’s ACP performance goals and measures, we reviewed
documentation and interviewed officials from FCC and the Universal
Service Administrative Company (USAC), the not-for-profit entity that
administers various programs on behalf of FCC. For example, we
reviewed public notices, orders, and other records in FCC’s proceedings
for ACP and ACP’s predecessor, the Emergency Broadband Benefit
program (EBB).
1
We also reviewed relevant planning documentation,
such as FCC’s Strategic Plan and Equity Action Plan,
2
and the laws
establishing EBB and ACP—the Consolidated Appropriations Act, 2021
and the Infrastructure Investment and Jobs Act (IIJA).
3
Due to the
similarities between ACP and FCC’s other broadband affordability
program, Lifeline, we also reviewed the orders establishing Lifeline’s
performance goals and measures and modernizing the Lifeline program,
as well as our prior work on Lifeline.
4
For additional context on household participation in ACP, we also
analyzed FCC enrollment data for ACP, EBB, and Lifeline. We analyzed
Lifeline data due to similarities between ACP and Lifeline and because
Lifeline is FCC’s other broadband affordability program. We analyzed
enrollment data from May 2021 to September 2022, which represents the
beginning of EBB to the end of the third quarter following the launch of
1
In the Matter of Affordable Connectivity Program, FCC WC Dkt. No. 21-450; In the Matter
of Emergency Broadband Benefit Program, FCC WC Dkt. No. 20-445.
2
FCC, Strategic Plan: Fiscal Years 2022-2026 (Washington, D.C.: Mar. 29, 2022); and
Equity Action Plan Pursuant to the President’s Executive Order On Advancing Racial
Equity and Support for Underserved Communities Through the Federal Government
(Washington, D.C.: Apr. 14, 2022).
3
Consolidated Appropriations Act, 2021, Pub. L. No. 116-260, div. N, tit. IX, § 904, 134
Stat.1182, 2129-36; IIJA, Pub. L. No. 117-58, 135 Stat. 429, 1238. The program is now
codified at 47 U.S.C. § 1752.
4
In the Matter of Lifeline and Link Up Reform and Modernization, Report and Order and
Further Notice of Proposed Rulemaking, 27 FCC Rcd 6656 (8) (2012); In the Matter of
Lifeline and Link Up Reform and Modernization, Third Report and Order, Further Report
and Order, and Order on Reconsideration, 31 FCC Rcd 3962 (5) (2016); and see, for
example, GAO, Telecommunications: FCC Should Evaluate the Efficiency and
Effectiveness of the Lifeline Program, GAO-15-335 (Washington, D.C.: Mar. 24, 2015).
Appendix I: Objectives, Scope, and
Methodology
Appendix I: Objectives, Scope, and
Methodology
Page 53 GAO-23-105399 Affordable Broadband
ACP. We analyzed various characteristics from these data, including the
method used to verify the subscriber’s program eligibility and geographic
indicators (such as subscribers’ state and whether they live on program-
qualifying tribal lands).
To estimate the number of ACP-eligible households, we used relevant
U.S. Census Bureau American Community Survey and Puerto Rico
Community Survey data from 2019, the most current available at the time
of our analysis (excluding 2020 survey data, which the U.S. Census
Bureau has deemed experimental due to the impacts of the COVID-19
pandemic). Specifically, we analyzed data elements that provide
information about household income and the use of certain government
assistance programs to create a minimum estimate of the eligible
population nationally and in each state. We identified households as
eligible if their previous year’s total income was less than or equal to 135
percent of the federal poverty thresholds
5
or if any household member in
the past 12 months participated in the Supplemental Nutrition Assistance
Program, received income from various public assistance programs
targeting low-income households, received supplemental security income,
or—at the time of the surveys’ data collection—was covered by Medicaid
(or any other government-assisted health insurance program for those
with low incomes or a disability).
6
We assessed the reliability of these
data by reviewing relevant system documentation, interviewing agency
officials, or conducting electronic testing, where possible. We determined
that the data elements we used from these data sets were sufficiently
reliable for the purposes of our reporting objective.
We assessed FCC’s efforts to establish goals and measures against
applicable leading practices for effective performance management that
we identified from our prior reports, particularly our Government
Performance and Results Act assessment and evaluation guides and key
5
We used the 135 percent threshold because ACP’s predecessor, EBB, required
household income to be 135 percent or less of the federal poverty level to qualify for the
program based on income.
6
Additional qualifying eligibility criteria, such as receiving a Pell grant; participation in the
Special Supplemental Nutrition Program for Women, Infants, and Children; or participation
in other qualifying programs cannot be identified in the American Community Survey data.
As the estimate for eligibility is based on household incomes less than or equal to 135
percent of the federal poverty level (as opposed to 200 percent under ACP) and we are
not able to capture all qualifying eligibility criteria, the estimate for eligibility represents a
minimum.
Appendix I: Objectives, Scope, and
Methodology
Page 54 GAO-23-105399 Affordable Broadband
attributes of successful performance measures.
7
The Government
Performance and Results Act, as enhanced by the Government
Performance and Results Act Modernization Act, establishes the
importance of agencies using performance goals and measures as a way
to improve the management of federal programs by focusing on the
results of programs.
8
While the Acts’ requirements apply at the
departmental level, we have previously stated that they can serve as
leading practices at the program level.
9
The leading practices we
identified included 11 attributes of effective performance goals and
measures, and we assessed FCC’s efforts against all 11 attributes. One
analyst assessed the relevant information about each goal and measure
against each of these attributes, and other reviewers reviewed this
assessment. Based on these assessments, we determined whether the
goal or measure either aligned with the elements that an attribute entailed
or did not fully align with the elements that an attribute entailed.
To assess how FCC conducted outreach to raise awareness for ACP, we
reviewed documentation and interviewed officials from FCC and USAC.
For example, we reviewed FCC documentation related to the number and
types of outreach events completed between November 2021 and
September 2022. We also reviewed ACP outreach materials. These
materials included the program’s main webpage and the consumer
frequently-asked-questions webpage, as well as items from the program’s
outreach toolkit, such as flyers, one-pagers, and public service
announcement scripts. In addition, we interviewed FCC and USAC
officials to obtain greater context on the agency’s outreach efforts.
7
GAO, Agencies’ Annual Performance Plans Under the Results Act: An Assessment
Guide to Facilitate Congressional Decisionmaking, GAO/GGD/AIMD-10.1.18
(Washington, D.C.: February 1998); The Results Act: An Evaluator’s Guide to Assessing
Agency Annual Performance Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 1998);
and Tax Administration: IRS Needs to Further Refine Its Tax Filing Season Performance
Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). These reports establish
guides for assessing and evaluating agency performance plans and attributes of effective
performance goals and measures, and we have reiterated these practices in our reporting
on agencies’ efforts to manage for results. See https://www.gao.gov/leading-practices-
managing-results-government.
8
Pub. L. No. 103-62, 107 Stat. 285 (1993), as enhanced by Pub. L. No. 111-352, § 3, 124
Stat. 3866, 3867 (2011) codified at 31 U.S.C. § 1115(b)(2), (6).
9
See, for example, GAO, Telecommunications: FCC Should Enhance Performance Goals
and Measures for Its Program to Support Broadband Service in High-Cost Areas,
GAO-21-24 (Washington, D.C.: Oct. 1, 2020).
Appendix I: Objectives, Scope, and
Methodology
Page 55 GAO-23-105399 Affordable Broadband
To obtain additional context on how participating providers advertised
ACP on their websites, we used two selection processes to identify a total
of 20 provider websites to review.
10
First, we used FCC data from
November 2021 (the most readily available at the time of our selection) to
identify the 10 largest participating providers as measured by subscriber
enrollment in EBB. Although the data did not account for providers that
joined the program after the launch of ACP, we still found the data to be
appropriate given that the 10 largest participating providers at this time
accounted for nearly 80 percent of program subscribers.
We used a combination of random sampling and judgmental selection to
identify 10 additional providers, so we could review websites from
providers that may be smaller than the ones identified in our initial
selection. We randomized FCC’s list of participating providers and
identified the first 10 providers on the randomized list as our sample. If
the providers listed in this sample had similar characteristics—such as all
of them offering the same type of broadband service or not offering a
device discount—we considered the next provider listed (number 11) to
substitute into the sample. We repeated this process until we achieved a
variety of these characteristics in the sample. These two selection
processes allowed us to identify a variety of provider websites that, while
non-generalizable, provided useful insights on how some participating
providers are advertising the program; the 20 providers we identified are
listed in the table below.
Table 6: List of Participating Providers Selected for Website Review
Providers identified based on number of subscribers
Providers identified using randomized judgmental selection
Assurance Wireless
Arctic Slope Telephone Association Cooperative, Inc.
AT&T
Arrowhead Communications Corporation
Charter Communications (doing business as Spectrum)
Cathect Communications, Inc.
Comcast Cable Communications
Cellspan Inc.
Dish Wireless LLC
Commnet Four Corners, LLC
Excess Telecom Inc.
Franklin Telephone Co., Inc.
Global Connection Inc. of America
Gen Mobile, Inc.
10
At the time of our selection, the program had approximately 1,300 participating
providers.
Appendix I: Objectives, Scope, and
Methodology
Page 56 GAO-23-105399 Affordable Broadband
Providers identified based on number of subscribers
Providers identified using randomized judgmental selection
Q Link Wireless LLC
North Central Telephone Cooperative
Sage Telecom Communications, LLC (doing business as
TruConnect)
Sano Health, LLC
Tracfone Wireless Inc.
The Preston Telephone Company
Source: GAO. | GAO-23-105399
We identified program information related to household eligibility and
similar information that would help consumers understand ACP. For each
provider website, two analysts reviewed each website for this program
information to determine if it was present on the website and reconciled
any differences in findings. Based on this analysis, we were able to obtain
greater context on how these providers advertised the program online
and the level of information that these websites provided to the consumer.
We also reviewed a selection of FCC’s non-English ACP outreach
materials. To determine which non-English languages to review, we
analyzed 2019 American Community Survey data (the most current
available at the time of our selection) and found that Spanish, Chinese,
Vietnamese, Korean, and French (including Haitian or Cajun) accounted
for the highest number of limited-English-speaking households in the
United States.
11
FCC has translated ACP outreach materials into these
languages, with the exception of Cajun. We then identified analysts
across our agency who spoke these languages to assist in our review of
the non-English materials.
12
We selected materials for review based on (1) the availability of the
material in non-English languages; (2) the means by which the material is
consumed (i.e., online, such as a webpage, or in print, such as a flyer);
and (3) the type of information on the material. (See table 7.) For
example, we reviewed the ACP main webpage and Consumer FAQ
webpage because they were available for online audiences and, in some
cases, these materials conveyed information excluded from the print
materials. We did not review certain flyers from the outreach toolkit
because they contained similar information to other toolkit items we
reviewed. We also reviewed additional materials that were only available
in Spanish; we reviewed the Spanish audio public service announcement
script, newsletter blurb, and select social media images, as they are
11
U.S. Census Bureau, American Community Survey 1-Year Estimates Detailed Tables,
B16002 (Washington, D.C.: 2019).
12
We were unable to identify analysts who spoke Haitian, so we only reviewed materials
translated into French.
Appendix I: Objectives, Scope, and
Methodology
Page 57 GAO-23-105399 Affordable Broadband
consumed differently than other materials included in our review. We
reviewed these materials in March 2022.
Table 7: Federal Communications Commission’s (FCC) Non-English Affordable Connectivity Program (ACP) Outreach
Materials Reviewed
Source
Material
Non-English language selected for review
FCC website
ACP main webpage
Traditional Chinese, Korean, Spanish, Vietnamese
Consumer FAQ webpage
Traditional Chinese, Korean, Spanish, Vietnamese
Outreach toolkit
Fact sheet
Simplified Chinese, French, Korean, Spanish, Vietnamese
Consumer handout (9”x5”)
Simplified Chinese, French, Korean, Spanish, Vietnamese
Consumer handout (4”x4”)
Simplified Chinese, French, Korean, Spanish, Vietnamese
Public service announcement script
Spanish
Newsletter blurb
Spanish
Social media images
Spanish
Source: GAO. | GAO-23-105399
We assessed the non-English ACP outreach materials we reviewed
against applicable leading practices for consumer-oriented content. We
identified relevant leading practices for consumer-oriented content from
various federal sources that we have previously used in prior work.
13
We
then identified four key attributes—clarity and accuracy, completeness,
practicality, and, for online content, managing users’ expectations—from
these leading practices that were relevant to our work. We used these
attributes to gauge each materials’ alignment with the practices. To
review the materials, analysts worked in pairs; each pair spoke one of the
five non-English languages reviewed. For each non-English language,
one analyst completed an initial review of each material, followed by a
second analyst performing an additional review. If the two analysts
disagreed, they discussed and reached a consensus on how well the
material aligned. We scored each material as “Met,” as in the material
met that attribute; “Partially met,” as in the material met some, but not all
elements of the attribute; and “Did not meet,” as in the material did not
meet any elements of the attribute.
13
U.S. Digital Service, Digital Services Playbook, accessed Dec. 10, 2021,
https://playbook.cio.gov/; U.S. Web Design System, Design Principles, accessed Dec. 10,
2021, https://designsystem.digital.gov/design-principles/; and General Service
Administration, Top 10 Best Practices for Multilingual Websites, accessed Dec. 10, 2021,
https://digital.gov/resources/top-10-best-practices-for-multilingual-websites/.
Appendix I: Objectives, Scope, and
Methodology
Page 58 GAO-23-105399 Affordable Broadband
We also assessed FCC’s language translation process for ACP outreach
materials against recommended practices from U.S. Census Bureau
guidance for developing public-facing translated products.
14
We reviewed
this guidance and identified four broad recommended practices that
reflect the 2020 Census translation workflow phases and that encompass
language translation efforts from planning to completion. According to
FCC officials, they also considered U.S. Census Bureau best practices for
the language translation process for ACP outreach materials. One analyst
assessed FCC’s translation process against each of the identified
practices and other reviewers reviewed this assessment. Based on these
assessments we determined whether the process aligned, partially
aligned, or did not align with the elements the practice entailed.
Finally, we reviewed FCC’s outreach plan for EBB, ACP’s predecessor,
and assessed it against the nine leading practices for consumer
education planning identified in our previous work.
15
One analyst
assessed the plan against each of the practices and other reviewers
reviewed this assessment. Based on these assessments, we determined
whether the plan met, partially met, or did not meet the elements the
practice entailed.
To obtain additional context on FCC’s ACP goals, measures, and
outreach, we sought additional perspectives from relevant stakeholders.
We reviewed a selection of stakeholder comments filed in the record for
FCC’s ACP proceeding to identify comments related to key performance
goals and measures and outreach themes. We limited our review of
stakeholder comments to exclude certain categories of filings that are
often duplicative (such as filings that disclose and summarize meetings a
stakeholder held with FCC staff). We also selected 27 stakeholders—
specifically, 8 industry associations; 5 state, local, and tribal entities; and
14 advocacy groups—to interview. To select knowledgeable stakeholders
that represent a variety of viewpoints from a cross-section of interests, we
considered various factors including the alignment of the stakeholders’
14
U.S. Census Bureau, Developing Public-Facing Language Products: Guidance From the
2020 Census Language Program (Washington, D.C.: Nov. 3, 2021). According to this
guidance, the bureau developed this product to share detailed information on how the
agency successfully developed and executed the 2020 Census language program, which
translated over 7 million words for more than 2,500 projects.
15
GAO, Digital Television Transition: Increased Federal Planning and Risk Management
Could Further Facilitate the DTV Transition, GAO-08-43 (Washington, D.C.: Nov. 19,
2007).
Appendix I: Objectives, Scope, and
Methodology
Page 59 GAO-23-105399 Affordable Broadband
missions or activities with the issues under our review, their engagement
in the proceeding, and how broad their representations are. Table 8 lists
these stakeholders. Because stakeholders vary in their expertise with
various topics, not every stakeholder provided an opinion on every topic.
Accordingly, their views are not generalizable to those of all stakeholders,
though they provided us with a variety of perspectives.
16
Additionally, not
all selected stakeholders accepted our requests for interviews or were
responsive to our requests.
Table 8: List of Stakeholders Interviewed
Industry associations
ACA Connects – America’s Communications Association
American Association of Service Coordinators
CTIA
National Lifeline Association
NCTA – The Internet & Television Association
USTelecom – The Broadband Association
Wireless Internet Service Providers Association
WTA – Advocates for Rural Broadband
State, local, and tribal entities
National Association of Regulatory Utility Commissioners
National Association of Telecommunications Officers and Advisors
National Congress of American Indians
National Tribal Telecommunications Association
Native American YesWeCan Foundation
Advocacy groups
AAPI Tech Table
AARP
Benton Institute for Broadband and Society
Common Cause
Consortium for Citizens with Disabilities’ Technology and Telecommunications Task
Force
EducationSuperHighway
Free Press
Multicultural Media, Telecom, and Internet Council
National Coalition on Black Civic Participation, Black Women’s Roundtable
16
Throughout this report, we refer to “some” stakeholders if representatives from 2–5
entities expressed the view (and “several” if 6–10, and “many” if 11 or more).
Appendix I: Objectives, Scope, and
Methodology
Page 60 GAO-23-105399 Affordable Broadband
National Consumer Law Center
National Hispanic Media Coalition
New America
Public Knowledge
United Church of Christ
Source: GAO. | GAO-23-105399
To assess FCC’s fraud risk management activities, we reviewed relevant
documentation and interviewed FCC and USAC officials. For example, in
addition to the documentation described above, we reviewed FCC’s fraud
risk assessment for ACP, its Antifraud Directive,
17
and relevant program
policies and guidance. Because of similarities between ACP and Lifeline,
we also reviewed FCC Office of Inspector General reports and our prior
reports on Lifeline and documentation related to prior Lifeline program
violations.
18
We assessed FCC’s fraud risk management activities against selected
leading practices in our Fraud Risk Framework.
19
Initially, because the
program is new, we selected leading practices from the Commit and
Assess components of the framework to evaluate FCC’s efforts.
However, because FCC conducted a fraud risk assessment for ACP
during our audit work, we also selected certain practices from the Design
and Implement component and the Evaluate and Adapt component of the
framework. We selected these additional leading practices because they
are important steps in addressing the fraud risks FCC identified and
assessed. Table 9 shows the selected leading practices from the Fraud
Risk Framework used in this review.
17
FCC, Policy for Detecting and Deterring Fraud and Promoting Ethical Conduct within the
FCC, FCCINST 1102.6 (Washington, D.C.: July 2020).
18
See, for example, FCC Office of Inspector General, Advisory Regarding Provider Efforts
to Deceive Lifeline Consumers to Enroll for Unwanted Government-Subsidized ACP
Services (Mar. 11, 2022).
19
GAO, A Framework for Managing Fraud Risks in Federal Programs, GAO-15-593SP
(Washington, D.C.: July 2015).
Appendix I: Objectives, Scope, and
Methodology
Page 61 GAO-23-105399 Affordable Broadband
Table 9: Selected Leading Practices for Fraud Risk Management
Component
Leading practice
Commit
Designate an entity to design and oversee fraud risk management activities that
• understands the program and its operations, as well as the fraud risks and controls throughout the program;
• has defined responsibilities and the necessary authority across the program;
• has a direct reporting line to senior-level managers within the agency; and
• is located within the agency and not the Office of Inspector General, so the latter can retain its
independence to serve its oversight role.
Assess
Plan to conduct fraud risk assessments at regular intervals and when there are changes to the program or
operating environment, as assessing fraud risks is an iterative process.
Identify specific tools, methods, and sources for gathering information about fraud risks, including data on fraud
schemes and trends from monitoring and detection activities.
Identify inherent fraud risks affecting the program.
Assess the likelihood and impact of inherent fraud risks.
• Involve qualified specialists, such as statisticians and subject-matter experts, to contribute expertise and
guidance when employing techniques like analyzing statistically valid samples to estimate fraud losses and
frequency.
• Consider the nonfinancial impact of fraud risks, including impact on reputation and compliance with laws,
regulations, and standards.
Determine fraud risk tolerance.
Examine the suitability of existing fraud controls and prioritize residual fraud risks.
Document the program’s fraud risk profile.
Design and
Implement
Develop, document, and communicate an antifraud strategy to employees and stakeholders that describes the
program’s activities for preventing, detecting, and responding to fraud, as well as monitoring and evaluation.
Evaluate and Adapt
Monitor and evaluate the effectiveness of preventive activities, including fraud risk assessments and the
antifraud strategy, as well as controls to detect fraud and response efforts.
Use the results of monitoring and evaluations to improve the design and implementation of fraud risk
management activities.
Source: GAO. | GAO-23-105399
As part of this review, we analyzed a snapshot of ACP enrollment data as
of April 1, 2022.
20
The enrollment data contain information on
approximately 11.2 million subscribers enrolled in ACP as of that date,
including name, address, date of birth, enrollment method, and
broadband service type. Additionally, we matched relevant elements of
the enrollment data against data in the U.S. Postal Service’s Address
Management System.
21
For a non-generalizable sample of households,
20
We plan to share the results of our data analytics with FCC for additional review and
action, as appropriate.
21
The Address Matching System application program interface is a commercially available
software package that standardizes addresses and provides specific flags, such as
commercial mailboxes, vacant, or invalid addresses.
Appendix I: Objectives, Scope, and
Methodology
Page 62 GAO-23-105399 Affordable Broadband
we conducted additional reviews of addresses flagged as PO Boxes,
commercial mailboxes, and unique ZIP codes. In certain cases, we
reviewed ACP reimbursement claims data to determine whether providers
had received reimbursements for a non-generalizable sample of
households. Although not representative of all cases, these non-
generalizable samples provide important illustrations of potential issues
with ACP subscribers.
We also compared ACP enrollee identity information to the Social
Security Administration’s Enumeration Verification System to identify
enrollees whose identity information may not have been accurate.
Specifically, we submitted enrollment information for individuals whose
enrollment data included the last four digits of their Social Security
number.
22
If the name and date of birth information corresponded to at
least one Social Security Administration record, we were able to then
identify the full Social Security number(s) for that record. We then
compared the partial Social Security numbers in the enrollment data to
the full Social Security number.
23
This comparison helped to identify
enrollees who have potentially invalid identity information in their
enrollment record. We assessed the reliability of the data by reviewing
relevant system documentation, interviewing agency officials, or
conducting electronic testing, where possible. We determined that the
data elements we used from these data sets were sufficiently reliable for
the purposes of our reporting objective.
We conducted this performance audit from October 2021 to January 2023
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.
22
As of April 1, 2022, the enrollment data contained partial Social Security numbers for
approximately 8.5 million of the total 11.2 million ACP subscribers (76 percent).
23
We performed this analysis because, per Social Security Administration policy, to verify
a Social Security number, the full number and name for the record are required. A partial
number cannot be submitted through the Enumeration Verification System in order to
obtain a verification. Matching on a partial number has a higher risk of error than matching
a full number and may result in individuals incorrectly being identified as a match.
Appendix II: Analysis of ACP and EBB
Enrollment Data
Page 63 GAO-23-105399 Affordable Broadband
For additional context on the status of household participation in the
Federal Communications Commission’s (FCC) Affordable Connectivity
Program (ACP), we analyzed enrollment data from May 2021 to
September 2022. The Emergency Broadband Benefit program (EBB)
began in May 2021,
1
and in response to the Infrastructure Investment and
Jobs Act, ACP replaced EBB on December 31, 2021.
2
Due to the
similarities between ACP and FCC’s other broadband affordability
program, Lifeline, we also analyzed EBB and ACP enrollment relative to
Lifeline enrollment, for further context.
As shown in figure 9, about 14 million households were enrolled in ACP
as of September 2022 (with enrollment overtaking Lifeline enrollment
within EBB’s first 6 months), which constituted about a third of the
minimum estimated eligible population of about 42 million households.
3
1
EBB was authorized by the Consolidated Appropriations Act, 2021. Pub. L. No. 116-260,
div. N, tit. IX, § 904, 134 Stat.1182, 2129-36.
2
As such, May 2021 to September 2022 represents the beginning of EBB to the end of the
third quarter following the launch of ACP. The Infrastructure Investment and Jobs Act
(IIJA), Pub. L. No. 117-58, § 60502(a)(1)(A), (a)(2), 135 Stat. 429, 1238-39 (2020)
(authorizing the Affordable Connectivity Program); div. J, tit. IV, 135 Stat at 1382
(providing additional funding). This program is now codified in 47 U.S.C. § 1752. See also
In the Matter of Affordable Connectivity Program, Emergency Broadband Benefit Program,
Report and Order and Further Notice of Proposed Rulemaking, FCC 22-2 (2022).
3
For more detail regarding estimating eligibility, see appendix I.
Appendix II: Analysis of ACP and EBB
Enrollment Data
Appendix II: Analysis of ACP and EBB
Enrollment Data
Page 64 GAO-23-105399 Affordable Broadband
Figure 9: Enrollment in FCC’s Emergency Broadband Benefit Program (EBB),
Affordable Connectivity Program (ACP), and Lifeline, May 2021–September 2022
Note: The eligible population is estimated using data from the 2019 American Community Survey and
Puerto Rico Community Survey. Households were identified as eligible if their previous year’s total
income was less than or equal to 135 percent of the federal poverty thresholds or if any household
member in the past 12 months participated in the Supplemental Nutrition Assistance Program,
received income from various public assistance programs targeting low-income households, received
supplemental security income, or—at the time of the surveys’ data collection—was covered by
Medicaid (or any other government-assisted health insurance program for those with low incomes or
a disability). As additional qualifying eligibility criteria cannot be identified in the American Community
Survey and Puerto Rico Community Survey data, the eligibility estimate is a minimum.
In EBB’s first 6 months, subscribers who were concurrently enrolled in
Lifeline represented the majority of subscribers, but subscribers not
concurrently enrolled in both programs grew to represent the majority of
subscribers (specifically, representing about 63 percent of ACP
subscribers as of September 2022). (See fig. 10.)
Appendix II: Analysis of ACP and EBB
Enrollment Data
Page 65 GAO-23-105399 Affordable Broadband
Figure 10: Enrollment in FCC’s Emergency Broadband Benefit Program (EBB) and
Affordable Connectivity Program (ACP) by Lifeline Enrollment Status, May 2021–
September 2022
Note: EBB launched in May 2021. ACP replaced EBB on December 31, 2021.
ACP enrollment has varied throughout the country, with some states or
territories having a higher percentage of their minimum estimated eligible
population enrolled in the program than others. As shown in figure 11, as
of September 2022, the percentage of the minimum estimated eligible
population enrolled in the program across states and territories primarily
fell in the 16 to 40 percent range. From May 2021 to September 2022,
subscribers who live on qualifying tribal lands represented a small portion
of total EBB and ACP subscribers (averaging under 2 percent).
Appendix II: Analysis of ACP and EBB
Enrollment Data
Page 66 GAO-23-105399 Affordable Broadband
Figure 11: Enrollment in FCC’s Affordable Connectivity Program (ACP) by State as of September 2022
Note: The eligible population is estimated using data from the 2019 American Community Survey and
Puerto Rico Community Survey. Households were identified as eligible if their previous year’s total
income was less than or equal to 135 percent of the federal poverty thresholds or if any household
member in the past 12 months participated in the Supplemental Nutrition Assistance Program,
received income from various public assistance programs targeting low-income households, received
supplemental security income, or—at the time of the surveys’ data collection—was covered by
Medicaid (or any other government-assisted health insurance program for those with low incomes or
a disability). As additional qualifying eligibility criteria cannot be identified in the American Community
Survey and Puerto Rico Community Survey data, the eligibility estimate is a minimum.
Finally, regarding the criteria used to verify subscribers’ eligibility when
enrolling in ACP, as of September 2022, the National Verifier accounted
for about 39 percent of verifications, followed by participation in Lifeline
(35 percent), a participating provider’s alternative verification process (26
percent), and a provider’s reliance on schools for verification of eligibility
Appendix II: Analysis of ACP and EBB
Enrollment Data
Page 67 GAO-23-105399 Affordable Broadband
via participation in the free and reduced price school lunch or breakfast
programs (less than 1 percent). (See fig. 12.)
Figure 12: Enrollment in FCC’s Emergency Broadband Benefit Program (EBB) and
Affordable Connectivity Program (ACP) by Method Used to Verify Program
Eligibility, May 2021–September 2022
Note: EBB launched in May 2021. ACP replaced EBB on December 31, 2021.
Appendix III: Printable Versions of Interactive
Figure 3
Page 68 GAO-23-105399 Affordable Broadband
Figure 13: Printable Version of Interactive Figure 3 – Clarity and Accuracy
Appendix III: Printable Versions of Interactive
Figure 3
Appendix III: Printable Versions of Interactive
Figure 3
Page 69 GAO-23-105399 Affordable Broadband
Figure 14: Printable Version of Interactive Figure 3 – Completeness
Appendix III: Printable Versions of Interactive
Figure 3
Page 70 GAO-23-105399 Affordable Broadband
Figure 15: Printable Version of Interactive Figure 3 – Practicality
Appendix III: Printable Versions of Interactive
Figure 3
Page 71 GAO-23-105399 Affordable Broadband
Figure 16: Printable Version of Interactive Figure 3 – Managing Users’ Expectations
Appendix IV: Comment from the Federal
Communications Commission
Page 72 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Appendix IV: Comment from the Federal
Communications Commission
Page 73 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Page 74 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Page 75 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Page 76 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Page 77 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Page 78 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Page 79 GAO-23-105399 Affordable Broadband
Appendix IV: Comment from the Federal
Communications Commission
Page 80 GAO-23-105399 Affordable Broadband
Appendix V: GAO Contact and Staff
Acknowledgments
Page 81 GAO-23-105399 Affordable Broadband
In addition to the contact named above, Andrew Huddleston (Assistant
Director); Nalylee Padilla (Analyst in Charge); Melissa Bodeau; Emily
Crofford; Melanie Diemel; Gabrielle Fagan; Myra Francisco; James
Healy; Gina Hoover; Alec McQuilkin; Brenda Mittelbuscher; Rebecca
Shea; Royal Srem-Sai; and Janet Temko-Blinder made key contributions
to this report.
Appendix V: GAO Contact and Staff
Acknowledgments
GAO Contact
Staff
Acknowledgments
(105399)
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