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Subgrants Possible?

Groups Seek to Leverage Local Efforts in ACP Outreach Programs

Industry and consumer advocacy organizations urged the FCC to leverage local governments and nonprofit organizations in its outreach efforts to boost enrollment in the affordable connectivity program (see 2203170048). The FCC received reply comments Friday in docket 21-450 on how the agency should design its outreach grant program and pilot program to boost enrollment for households receiving federal public housing assistance.

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The record shows the FCC should allow a “diverse range” of entities to apply for grants, and flexibility in recipients’ outreach strategies, said NATOA, saying it backs the use of subgrants. There’s “no one-size-fits-all outreach program that will work in every community,” NATOA said. Subgrants would help "resource-strapped" organizations "conduct planning, education, and outreach on broadband access," said the Latino Community Foundation. Groups must be able to carry out "clear, culturally competent, and linguistically diverse messaging," the group said, which requires "bold resources, staffing, and multilingual capacity."

Grant applications and reporting requirements should be “reasonable and predictable,” said the National Lifeline Association. Many commenters agree “transparency and accountability are also essential components of a successful outreach grant program,” NaLa said. Outreach efforts should include “strong local partnerships that leverage trusted community partners,” said the Local Initiatives Support Corp. Allowing the use of subgrants “would simplify the administration” and “more equitably allow for resources to be directed to smaller, community-based organizations,” LISC said. EducationSuperHighway said some funding should go toward the FCC’s one-year test pilot program that gives certain entities access to the national verifier to assist households in enrollment.

Prioritize agency partnerships” to “maximize the reach of the pilot program … in all types of federally-assisted housing programs,” advised Starry. The ISP said community-based organizations are also “well-positioned to provide one-on-one enrollment support and in-person guidance” on how to enroll.

Many local governments and organizations “have become a trusted voice for government-funded services and programs” throughout the COVID-19 pandemic, said Los Angeles Deputy Mayor-Budget and Innovation Jeanne Holm. “The commission should leverage methods that cities have used with trusted community partners to increase outreach to FPHA [Federal Public Housing Authority] beneficiaries,” Holm said. Groups with an “existing relationship with the communities in need” should be eligible for funding, said USTelecom.

Let grant recipients use funding to "provide technology training before and after enrollment,” said the American Association of Service Coordinators. It would “give confidence to eligible households who are currently uninterested in the program because of a lack of digital knowledge,” AASC said. It also backed efforts to “encourage [ISPs] to better accommodate eligible households who are new to devices and the internet.”

Consider “automatic eligibility” for households living in multifamily assisted housing, said EducationSuperHighway, noting that change could help 1.37 million households enroll. Boston; Montgomery County, Maryland; Washington, D.C.; and the Texas Coalition of Cities for Utility Issues said the FCC should “lead by example in identifying and removing structural barriers” to ACP enrollment by removing the requirement that consumers use an email to receive the benefit: It “prevents more older adults, low-income families, and disadvantaged communities” that aren't online from signing up.