The early threat of COVID-19 has already led to a rash of school closings throughout the United States in what could lead to what one expert described as “a vast unplanned experiment in home schooling.” Although E-rate provides limited financial support for virtual schools, there is little in the current funding rules to assist traditional schools in quickly transitioning to a remote learning environment.
Last week, two FCC Commissioners, Jessica Rosenworcel and Geoffrey Starks, both suggested emergency steps that the FCC could take in a number of its programs to support “telework, telehealth, and tele-education.” In the educational arena, both Commissioners focused on funding to “rapidly increase the number of lendable hotspots available through schools and libraries.”
E-rate funding of mobile hotspots* would be a step in the right direction but falls far short of addressing all the remote technology issues schools will be facing in the coming weeks and months. In particular:
- Hotspots in student homes would need to be tied into wireless Internet services. Monthly data usage fees, even if assumed by schools and libraries, are not currently E-rate eligible.
- Some form of device (laptop, tablet, etc.) is necessary for effective distance learning. Such devices have never been E-rate eligible.
- Existing school Internet bandwidth may not be sufficient to support a large number of concurrent remote users. Additional bandwidth, if properly deployed (essentially making regular schools into virtual schools), would be E-rate eligible. To provide E-rate funding, however, the FCC would have to further extend or reopen the application window for FY 2020 (and the remainder of FY 2019).
- Most schools would have to fund, procure, and implement LMS (Learning Management System) software. Such software has never been E-rate eligible.
Besides funding mobile hotspots, other actions that the FCC should consider, at least temporarily, include:
- Supporting off-campus Internet access for students in lower-income families.
- Encouraging service provider provision of free or reduced-priced equipment and/or services by easing gift rules and Lowest Corresponding Price (“LCP”) restrictions.
- Opening a second filing window that would allow applicants to refile for funding once a true assessment of their needs has been determined.
As of the end of last week, we began to see requests of this nature being made to the FCC. We expect to see a number of additional requests being filed this week.
FCC Chairman Ajit Pai, to his credit, announced last Friday that he had launched the Keep Americans Connected Pledge program and has been personally asking broadband and telephone service providers (and their trade associations), apparently with great success, for a 60-day voluntarily agreement to:
- Not terminate service to residential or small business customers because of their inability to pay their bills due to the disruptions caused by the coronavirus pandemic;
- Waive any late fees that residential or small business customers incur because of their economic circumstances related to the coronavirus pandemic; and
- Open their Wi-Fi hotspots to any American who needs them.