In a recent letter to the FCC, USTelecom made several positive recommendations concerning implementation of the Congressional Emergency Broadband Benefit Program. Its measured and practical approach included:
Using existing resources, most notably the Commission’s significant changes to the Lifeline Program for verification of eligibility. All providers should have the option to use the National Verifier as their sole means of determining eligibility for program benefits.
Keeping it simple, because “if the program becomes too complex, the implementation timeline will grow, ultimately delaying when customers can take advantage of the broadband benefit. Clear compliance guidelines…are critical.”
Building flexibility into program implementation, recognizing “the emergency nature of this program.” Participants “will require some level of flexibility and optionality to adapt it to their existing plans and systems.”
Planning for transition from the outset, to clearly specify how carriers enter and exit the program. “There is a finite amount of money that will last an indeterminate amount of time…(so) it is important for customers and providers alike to understand their responsibilities once…funding is fully expended.”
USTelecom has given the FCC a very reasonable set of guidelines for implementation of an extremely important program. We hope the Commission takes their advice, rather than overly complicating a process that needs to be implemented as quickly as possible.