The government has helped narrow the K-12 digital divide for nearly two decades through the Federal Communications Commission’s E-rate program. E-rate provides up to $4.768 billion annually in discounts on essential broadband services for schools and libraries nationwide.
While the program continues to fund high-speed internet and Wi-Fi services on school and library campuses, the FCC recognizes that in today’s “learn from anywhere” environment there is more work to be done. This year, the commission added school bus Wi-Fi to the program’s list of eligible services, and has put forth proposals to enhance off-campus connectivity and advanced cybersecurity protections for K-12 students and public library patrons.
E-rate fuels school buses
To close the equity gap for rural and low-income students, E-rate is accepting applications in the 2024 funding cycle from applicants who want to add Wi-Fi to their school buses. Many studies have shown that providing Wi-Fi on school buses can help close the homework gap for underprivileged students. After soliciting comments late last year, the FCC in December issued new guidance to support this effort.
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Category One E-rate funding is available for both the equipment and monthly service needed to outfit school buses with Wi-Fi capability. Applicants seeking discounts on bus Wi-Fi services will be required to supply information about the number of buses being served, and the program administrator has provided specific instructions to applicants seeking funding for the service.
Schools and libraries must allow enough time to select the most cost-effective provider(s) based on their bid evaluation factors, with price of the eligible equipment and services being the primary bid factor, and adhere to the 28-day competitive bidding waiting period required by E-rate.
Hotspots get the cold shoulder?
Although E-rate has opened up applications for school bus Wi-Fi, off-campus hotspots are not yet eligible for funding. The FCC issued a Notice of Proposed Rulemaking late last year soliciting comments as it considered off-campus Wi-Fi hotspot services in the E-rate program. During the initial comment period, the commission received more than 60 comments that revealed mixed support for funding off-site hotspots.
While commenters agreed students could benefit from off-campus internet services, they disagreed about how it should be funded. Some of the input expressed concern over the total cost of adding hotspots to the program, others supported per-applicant device counts or funding amount caps. Funds For Learning estimates that adding hotspot services to E-rate would increase the total demand for E-rate funds by 6.67%, or $198 million.
FCC gathers more input on cybersecurity struggles
E-rate has yet to fund most school and library cybersecurity efforts, even though leaders continue to ward off network intruders. To address these concerns, in late 2023 the Federal Communications Commission proposed the creation of a Schools and Libraries Cybersecurity Pilot Program that would fund a 3-year pilot program for K-12 schools and libraries. The Commission issued a Notice of Proposed Rulemaking soliciting comments from the public.
So far, commenters have unanimously agreed the FCC should move forward with the pilot, citing an urgent and critical need for advanced cybersecurity protections. The public comment period ended in February.
Funds For Learning and other commenters provided input on the following themes:
- Shorten the duration of the pilot: The FCC should expedite the pilot, allowing it to institute E-rate changes or create a private cybersecurity program sooner. Three years is too long of a pilot, and the FCC might consider running the program for 12 to 18 months. We believe this would still allow the FCC to collect adequate data while speeding up the opportunity to support more schools and libraries through future E-rate applications.
- Add more funding: The current $200 million funding level would not be enough to fund the number of projects required to establish enough data for analysis. We suggested the FCC raise the budget by $112 million to provide the right level of funding needed, based on a previous analysis we conducted in 2021. We estimated the average cost per cybersecurity applicant would be $146,682. If you multiply that number by the 21,000 applicants who submitted in 2023, $312 million over two years would allow for an adequate pilot program sample size of about 5% of all applicants. This would allow the FCC to evaluate a range of applicants and solutions.
- Keep a broad definition of eligible services: We also suggested that applicants be asked to follow a set of guiding principles rather than ascribe to a set menu of eligible products and services. This would allow them to innovate, while still keeping the scope of projects narrow enough to review. Several commenters also suggested the FCC refrain from creating an eligibility list of specific products, services, or technologies schools could seek funding to support via the pilot program.
- Track successes: Some comments proposed that the FCC measure pilot program success by requiring applicants to commit to a specific cybersecurity framework, reporting the effect pilot funds would have on their progress towards full implementation. They argue that this tracking method would be more objective given the uncertain nature of cyberattacks on schools and libraries.
- Address privacy concerns: The FCC should carefully consider the information they collect in pilot program applications and the information they make public, commenters said. Public disclosure of applicants’ cybersecurity systems could expose them to attack vectors that were previously undisclosed.
Although it’s a positive sign that the FCC considers off-site internet access and cybersecurity as key priorities, the commission must act quickly. We can only close the digital divide if we can do so quickly, safely and securely.
