Administrative and Legislative Solutions to Reduce Overlap, Fragmentation, and Duplication

• Program Alignment: As GAO wrote in its report, “Federal broadband efforts are fragmented and overlapping, with more than 100 programs administered by 15 agencies.”³⁶ Congress authorizes programs with different timelines, performance requirements, and deployment obligations. As broadband technology evolves to meet new consumer and business needs, grant programs should, too. Flexibility, then, is inherently critical in broadband programs. Whenever possible, however, programs should be standardized to reduce complexity and unnecessary variation for applicants and other stakeholders.
• Coordinating the Impact of Funding: The ABA directs agencies to coordinate with NTIA to ensure that “a program does not duplicate any other Federal broadband support program.”³⁷ NTIA has taken a leadership role in the effort to develop a common process that respects each agency’s resources, statutory obligations, and leadership preferences. Each successive wave of funding has improved this process, but more work can be done to promote the most efficient uses of federal broadband funding for locations with unmet need. Agencies should also work to document these standard operating procedures.
• Data and Mapping: Good data and accurate maps will be crucial to ensure that federal dollars for broadband deployment are spent efficiently and effectively and to guard against duplicative federal funding. The ABA, the Broadband DATA Act, the BICA, and IIJA all created new agency obligations to collect and share data, but agencies may need support and resources as they attempt to navigate these new expectations. NTIA envisions a future state of interagency data collaboration in which different data sources and resources feed into one another and multiple agencies contribute based on their statutory responsibilities and data expertise.

Legislative Solution

• Impose consistent data collection requirements at authorization: New federal broadband support programs, if mandated, could include regular reporting requirements in line with the data standards required for the Broadband Funding Map and NTIA’s annual ABA report on federal broadband funding for any project that will fund broadband-related activities, including deployment, planning, and digital inclusion. Congress could consider aligning definitions of broadband infrastructure between IIJA Section 60105 and the ABA, which would encourage all agencies with responsive data to report into the Broadband Funding Map.

Administrative Solutions

• Continue to move to common policies: NTIA has developed a set of common application, award, and reporting policies, such as including “de-scoping” powers in the award conditions in the case of inadvertent duplication and including Tribal consent requirements as a requirement for the award of federal funding. Building common policies takes time, especially across different agencies. NTIA will continue to support agencies which wish to adopt these standard policies.
• Impose reporting requirements on grant recipients in award documents: When creating programmatic documents, agencies should include data reporting requirements for the Broadband Funding Map and NTIA’s data collection obligations under the ABA. As NTIA continues to develop digital equity standards, agencies should ensure the reporting expectations for any digital equity programs conform to those standards. As appropriate, agencies may consider instructing recipients to provide data directly to the FCC or NTIA for reporting to reduce administrative costs for the awarding agency.
• Support key ongoing federal data collections and the development of new data products: Comprehensive program evaluation and policy research can benefit substantially from consistent data on broadband adoption, digital equity, and related issues in addition to reporting from the programs themselves. For example, the NTIA Internet Use Survey has served as a vital data source for understanding challenges to digital equity since 1994—with early reports even helping popularize the term “digital divide,” and more recent data serving as a legally-required input into the state Digital Equity Act funding formula. Support for the development of other federal data products that complement reported program data, such as small-area estimates of key metrics, could also prove valuable to programs and policy development across agencies.
• Support a state-federal confidential data-exchange ecosystem: States, Internet service providers, and federal agencies all have roles to play in making broadband data transparent, accessible, and informative—all of which are key to ensuring the efficient use of federal funds and guarding against duplicative federal funding. NTIA will continue to explore ways to encourage or incentivize states to contribute data to the Broadband Funding Map. Without accurate data about state investments, it may be difficult for federal agencies to make fully informed decisions about the most efficient uses of federal broadband funding.
• Enshrine a deduplication process in an MOU: Although agencies have worked together to create effective deduplication process, those agreements are largely not formalized. The agencies should consider revising the 2021 Interagency Agreement and the 2022 MOU to establish a single, consistent deduplication review process that includes a review period for other broadband agencies before the funding agency makes final commitments. The MOU should establish an expedited process to add other agencies to the MOU, to ensure a quick pathway to coordinate the efforts of other agencies that administer funding programs and develop related policy goals.

Conclusion