Affordable Broadband: FCC Could Improve Performance Goals and Measures, Consumer Outreach, and Fraud Risk Management
Fast Facts
Access to broadband—high-speed internet—has become critical for everyday life. But its cost may keep some people from having access to it.
To make it more affordable for low-income Americans, the FCC's Affordable Connectivity Program offers monthly discounts on broadband service to eligible households. As of Sept. 2022, over 14 million households had enrolled—about a third of the estimated eligible households.
FCC could strengthen the program's goals and measures, consumer outreach, and fraud-risk management to better ensure the program is meeting goals and protecting its funds from potential fraud. Our recommendations address these issues.
Highlights
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.
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 without 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) conducting 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 officials; and compared FCC's efforts in each area to applicable leading practices identified in prior GAO work or other federal sources.
Recommendations
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 implement various processes for managing fraud risks. FCC agreed with our recommendations and described its plans to address each one.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Federal Communications Commission | The Chair of FCC should ensure that ACP performance goals and measures align with key attributes of effective performance goals and measures. (Recommendation 1) | FCC's Affordable Connectivity Program (ACP) 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. In 2023, we reported that FCC established some performance goals and measures for the program. However, the goals and measures did not fully align with key attributes of effective performance management, which we identified from our prior reports. For example, FCC's goals and measures lacked specificity and clearly defined targets, raising questions about how effective these... goals and measures would be at helping FCC gauge the program's achievements and identify improvements. Consequently, we recommended that FCC ensure that ACP performance goals and measures align with key attributes of effective performance goals and measures. In February 2024, we confirmed that FCC had implemented this recommendation, making changes to better align the program's performance metrics with key attributes of performance management. Specifically, FCC revised the performance measures for the program to include specific, numeric targets and timeframes, making their performance metrics more objective, clear, and measurable. Additionally, although FCC did not revise the ACP's performance goals, clarifying how the goals would be measured made it clearer how the goals are results-oriented and contribute to the crosscutting nature of ACP and other FCC efforts, such as the Lifeline program. Having updated its performance metrics, FCC will be better able to assess and effectively demonstrate ACP's achievements to Congress and other stakeholders.
View More |
| Federal Communications Commission | 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) | FCC's Affordable Connectivity Program (ACP) 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. In 2023, we reported that FCC has 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, we reviewed a selection of these materials and the process to translate them and found that they did not fully align with leading practices for...
|
| Federal Communications Commission | 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) | FCC's Affordable Connectivity Program (ACP) 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. In January 2023, we reported that FCC had completed a variety of outreach activities to raise awareness of ACP, but it had not developed an outreach plan to guide those activities. According to FCC officials, FCC has largely leveraged the outreach infrastructure from the program's predecessor, the Emergency Broadband Benefit (EBB) program. to inform its new, ACP outreach...
|
| Federal Communications Commission | 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) | The Federal Communications Commission's (FCC) Affordable Connectivity Program (ACP) 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 to households that subscribe to the program. In January 2023, we reported that FCC had taken steps to manage fraud risks in ACP. For example, FCC assessed fraud risks in ACP in May 2022. However, some of FCC's efforts did not fully align with selected leading practices in GAO's Fraud Risk Framework. Specifically, FCC had not developed a process to conduct fraud risk assessments at regular intervals or when there...
|
| Federal Communications Commission | 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) | FCC's Affordable Connectivity Program (ACP) 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. We and others have previously reported on another similar FCC program's susceptibility to fraud, and some stakeholders have raised concerns about program integrity for ACP. In January 2023, we reported that FCC had taken steps to manage fraud risks in ACP, but that its efforts did not fully align with leading practices in GAO's Fraud Risk Framework. Specifically, while FCC...
|
| Federal Communications Commission | The Office of the Managing Director should develop and implement processes to monitor antifraud controls related to preventing duplicate subscribers in ACP. (Recommendation 6) | FCC's Affordable Connectivity Program (ACP) offers eligible low-income households discounts on the cost of broadband and reimburses providers who offer the discount. The program includes over 14 million subscribers. In January 2023, we reported that FCC had not developed processes to monitor certain antifraud controls including those for preventing duplicate subscribers. FCC's efforts to manage ACP fraud risks did not fully align with leading practices in GAO's Fraud Risk Framework. While FCC assessed ACP fraud risks in May 2022, we identified concerns related to FCC's consideration of how its existing antifraud controls mitigated identified risks. Specifically, we identified issues...
|
| Federal Communications Commission | The Office of the Managing Director should develop and implement processes to monitor antifraud controls related to subscriber identity verification in ACP. (Recommendation 7) | FCC's Affordable Connectivity Program (ACP) offers eligible low-income households discounts on the cost of broadband and reimburses providers who offer the discount. The program includes over 14 million subscribers. In January 2023, we reported that FCC had not developed processes to monitor certain antifraud controls including identity verification. FCC's efforts to manage ACP fraud risks did not fully align with leading practices in GAO's Fraud Risk Framework. While FCC assessed ACP fraud risks in May 2022, we identified concerns related to FCC's consideration of how existing controls mitigate identified risks. Specifically, we identified issues related to major controls for ACP,...
|
| Federal Communications Commission | The Office of the Managing Director should develop and implement processes to monitor antifraud controls related to subscriber address validation in ACP. (Recommendation 8) | FCC's Affordable Connectivity Program (ACP) offers eligible low-income households discounts on the cost of broadband and reimburses providers who offer the discount. The program includes over 14 million subscribers. In January 2023, we reported that FCC's efforts to manage ACP fraud risks did not fully align with leading practices in GAO's Fraud Risk Framework. While FCC assessed ACP fraud risks in May 2022, we identified concerns related to FCC's consideration of how its existing antifraud controls mitigated identified risks. Specifically, we identified issues related to major antifraud controls for ACP and found that FCC had not developed processes to monitor certain controls,...
|
| Federal Communications Commission | 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) | FCC's Affordable Connectivity Program (ACP) offers eligible low-income households discounts on the cost of broadband and reimburses providers who offer the discount. The program includes over 14 million subscribers. In January 2023, we reported that FCC's efforts to manage ACP fraud risks did not fully align with leading practices in GAO's Fraud Risk Framework. While FCC assessed ACP fraud risks in May 2022, we identified concerns related to FCC's consideration of how its existing controls mitigated identified risks. Specifically, we identified issues related to major antifraud controls for ACP, and found that FCC had not developed processes to monitor these controls, including those...
|