OTI Files Comments to Inform the USF Working Group

New America’s Open Technology Institute submitted comments to inform the Working Group’s assessment of federal universal service policy and plans for reforming the Universal Service Fund (USF). OTI is committed to ensuring that every community has access to digital technology and its benefits, and promotes universal access to communications technologies that are both open and secure in service of that goal. OTI has a long record of proposing and supporting reforms to USF programs, from revitalizing the Lifeline program, to unlocking the potential of the E-Rate program for both schools and libraries to address the “homework gap.” Most recently, OTI has published briefs on key USF topics including affordability and the contribution system, providing context and analysis to assist policymakers in navigating the complexities of the USF and framing the tradeoffs that must be resolved. 

OTI highlighted the following key points that inform our comments to the Working Group: 

• We have not lived up to the promise of universal service contained in §254. To do so, policymakers must consider universal service policy holistically, as an evolving concept, and not just through the limited lens of amending existing programs. 
• Current USF policies are falling short of providing services at “just, reasonable, and affordable rates.” 
• USF cannot live up to its purpose without addressing adoption, including providing education and training in digital skills. 
• Recent E-Rate reforms should not be rolled back, but expanded to further close the Homework Gap. 
• USF funding should derive from these needs, not be capped arbitrarily, and must be scalable to meet program needs.