Wireless Internet: FCC Should Assess Making Off-School-Premises Access Eligible for Additional Federal Support

School-age children without internet access may have difficulty in completing homework. Those without in-home fixed access may go online wirelessly outside the home to do homework. A provision was included in statute for GAO to review wireless internet access for school-age children in lower-income households.

This report examines (1) challenges lower-income school-age children who lack in-home fixed internet face in doing homework involving internet access, and (2) selected school district efforts to expand wireless access for students and the federal role in those efforts. GAO analyzed 2017 CPS data; reviewed six local projects that were selected based in part on education industry stakeholders' recommendations, that included a range of geographic locations, and that took steps to address the homework gap; compared FCC efforts to federal standards for internal controls and pilot-program design best practices; reviewed FCC and Department of Education documents; and interviewed 17 stakeholders, including school districts.

According to GAO's analysis of 2017 Census Bureau Current Population Survey (CPS) data, children ages 6 to 17 in lower-income households are more likely than peers in higher-income households to lack high-speed in-home internet and rely on mobile wireless service. GAO found that students who use mobile wireless for homework may face challenges, including slower speeds and limitations smartphones present in completing tasks like typing papers. These “underconnected” students may seek out ways to access wireless internet outside of the home to do homework; however, these methods also pose challenges (see figure). The inequity in internet access—and therefore in the ease of doing homework involving access—between students of varying income levels is known as the “homework gap.”

Efforts by six selected projects involving seven school districts expanding wireless access for students who may lack it at home varied. According to officials with most school district projects GAO reviewed, rules for the Federal Communications Commission's (FCC) E-rate program, which allows schools to purchase discounted internet equipment, may limit schools' ability to provide wireless access off-premises. Specifically, off-premises access is not eligible for E-rate support, and schools that provide such access using existing services supported by E-rate must reduce their E-rate discounts. FCC conducted a pilot project in 2011 and 2012 to help decide whether to make wireless off-premises access eligible for E-rate support, but FCC did not determine and execute a methodology to assess the potential costs, benefits, and challenges of doing so. In 2016, FCC received two requests from school districts seeking waivers of rules to allow them to use E-rate program support to provide off-premises access, but FCC has not made a decision on the waivers. Determining and executing a methodology to analyze data about the potential benefits, costs, and challenges of easing E-rate rules on off-premises use and publishing the results could provide transparency to stakeholders such as school districts. This step could also help FCC act on pending and future waiver-of-rule requests and broader changes to rules that may help schools address the homework gap.

GAO recommends that FCC take steps to assess and publish the potential benefits, costs, and challenges of making off-premises wireless access eligible for E-rate support.

Internet access is crucial for communication, economic activity, and  education, including for students at the elementary and secondary school  levels. According to the National Telecommunications and Information  Administration (NTIA), part of the Department of Commerce, the internet  has taken on an increasingly prominent role in schools, and students who  lack access are at risk of missing opportunities to advance their  education. Internet access is crucial not only inside the classroom— where it enables teachers to provide a richer learning experience—but  also outside the classroom, because access is frequently necessary for  doing homework. “Underconnected” students—those with limited or no  access at home—may have difficulty doing homework, putting them at  risk of falling behind better-connected peers, a condition known as the  “homework gap.”

School-age children from lower-income households are more likely to be  underconnected and therefore to face the homework gap. According to  an analysis of 2015 survey data, lower-income households with school- age children are more likely to lack a high-speed internet connection at  home than higher-income households with school-age children. School- age children without in-home high-speed internet may use other means of  accessing the internet—such as mobile wireless or public Wi-Fi at  libraries or coffee shops—to do homework. However, these alternative  methods may pose challenges to students using them to do homework.  As a result, some schools have begun to take steps to address the  homework gap by providing internet access to underconnected students.

The Consolidated Appropriations Act, 2018 included a provision for us to  review wireless internet for low-income school-age children. This report  examines:  challenges lower-income school-age children who lack in-home fixed  internet face in doing homework that involves internet access, and what selected school districts are doing to expand wireless internet  access for their students, and the federal role in such efforts.

To examine challenges lower-income school-age children who lack in- home fixed internet face in doing homework that involves internet access,  we analyzed data on internet access and use from the Census Bureau’s  November 2017 Current Population Survey (CPS): Computer and Internet  Use Supplement, sponsored by NTIA. Specifically, we used data on the  ages of all household members to determine if the household had one or  more school-age children and analyzed data on the use of in-home fixed  and mobile wireless internet and use of various computing devices. We  included variables on household income to report results based on  different income ranges. To determine the reliability of these data, we  reviewed technical documentation on the survey, interviewed NTIA  officials, and compared our estimates of certain variables with estimates  presented by NTIA on its website. We found these data were sufficiently  reliable for assessing household internet use and access by income.

We also conducted a literature search for studies published between  2013 and 2018, and used relevant publications to support data we  collected from other sources, including interviews. We interviewed  officials with the Department of Education (Education), the Federal  Communications Commission (FCC), and NTIA. We also interviewed  eight education or technology-industry associations or advocacy  organizations, one education researcher, one technology industry  researcher, and one technology company that provides internet services  and products to schools. Finally, we reviewed a non-generalizable sample  of six projects through which seven school districts provide wireless  internet access outside of school to students who may lack internet  access at home. We selected those projects that were frequently cited in  the press or by others we interviewed and to cover a variety of  geographic locations, including those in both urban and rural areas, and  to include a variety of approaches to addressing the homework gap.  Specifically, we interviewed officials from five school districts and one  technology company working with two school districts. We conducted  semi-structured interviews with these 17 stakeholders, including the  industry associations, researchers, and school districts detailed above,  and analyzed the content of the interviews to identify key challenges. The  results of these interviews are not generalizable.

To examine what selected school districts are doing to expand wireless  internet access for students and the federal role in such efforts, we  conducted semi-structured interviews with officials at the five school  districts and one technology company mentioned above regarding  relevant efforts. We reviewed documentation from FCC and Education  regarding relevant federal efforts, including rulemaking documents and  documents about FCC’s Schools and Libraries Universal Service Support  Mechanism (also known as the E-rate program), which provides schools  with discounts on telecommunications and internet services. We also  interviewed officials with Education and FCC about their efforts related to  school initiatives to expand wireless access for students. We compared  FCC efforts to federal internal control standards related to using quality  information and communicating externally and pilot-program design best  practices. For a more detailed description of our scope and  methodology, see appendix I.

We conducted this performance audit from May 2018 to July 2019 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

School-age children can access the internet in a number of ways. Their  households may subscribe to in-home fixed internet, which is generally  provided by cable television or telephone companies. School-age  children, and other users, can connect a variety of devices to in-home  fixed service through a wired connection or a Wi-Fi connection. They  may also access the internet through mobile wireless service, which is  provided through cell towers, with data transmitted over radio frequency  spectrum. Mobile service providers usually sell internet access as an  option in mobile telephone-service plans. A number of devices may  connect to mobile wireless, such as smart phones, tablets, and mobile  devices that enable laptops to connect to mobile wireless service. Finally,  school-age children and others may access the internet outside the home  through other ways, including publicly available Wi-Fi access at places  such as libraries and coffee shops.

FCC has found that Americans in lower-income areas are less likely to  have access to both in-home fixed and mobile wireless internet than  those in higher-income areas. Similarly, according to our analysis of  data from the November 2017 CPS: Computer and Internet Use  Supplement, among all school-age children, those in lower-income  households are less likely to use the internet at home than those in  higher-income households (see fig. 1).

A number of factors explain the digital divide, or the varying levels of  access among different populations. For example, as we have reported in  the past, rural areas tend to have conditions such as low population  density or difficult terrain that can increase the costs for internet providers  to deploy and maintain internet networks. Furthermore, lower-income  households with access to the necessary infrastructure for internet  service may not be able to afford it. (See fig. 2.) While some in-home  fixed internet providers offer low-cost service for lower-income  households with school-age children, according to a 2016 survey, an  estimated 5 percent of households with school-age children ages 6 to 13  and incomes at or below the federal poverty guidelines had ever signed  up for such programs.

Lower rates of internet access by lower-income households may make it  more difficult for school-age children in those households to do  homework. According to a 2018 Pew Research Center survey, a higher  percentage of surveyed teens in lower-income households said that the  lack of a dependable computer or internet connection sometimes  prevents them from finishing their homework compared to teens in higher- income households. In addition, according to the Consortium for School  Networking, the lack of in-home access makes it more difficult for parents  to support their children academically. Specifically, as much  communication between schools and parents has moved online, the lack  of access may make it difficult for parents to stay connected to teachers  and be informed about school notices, homework assignments, and other  important information.

FCC, which regulates commercial and other nonfederal spectrum,  conducts activities that affect the ability of schools to address the  homework gap. Specifically, it plays a role in expanding internet access  by assigning licenses for Educational Broadband Service (EBS)  spectrum, which permits schools and other eligible entities to transmit  educational materials electronically. Currently, EBS license holders are  allowed to lease excess capacity to others, including commercial wireless  providers, for up to 30 years as long as the license holder has 20 hours of  educational use per week per licensed channel and reserve the right to  access 5 percent of the capacity for educational use. Schools that have  such leases may need to wait years to regain full use of their EBS  license. Furthermore, the last opportunity for school districts to apply for  new EBS licenses was in 1995, and according to FCC, EBS licenses  cover about half the geographic area of the United States, with rural  areas west of the Mississippi River generally lacking licenses. However,  FCC recently adopted a Report and Order with rules that, once effective,  will change the eligibility requirements for EBS licenses, among other  things.

In addition, FCC supports internet investments at schools through the E- rate program, which provides discounts on telecommunications and  internet access services, internal connections, and basic maintenance of  internal connections. This program provides schools with higher  percentages of lower-income students greater discounts on these  services; for example, the most disadvantaged schools, where at least 75  percent of students are eligible for free or reduced price school lunch,  receive a 90 percent discount. All services supported by the E-rate  program must be used primarily for “educational purposes,” which FCC  has defined as meaning “activities that are integral, immediate, and  proximate to the education of students.”

Education’s Office of Educational Technology also plays a role related to  internet access for students by developing national educational- technology policies and providing guidance to schools and school districts  on technology use in schools. For example, in January 2017 the office  issued a letter to schools and school districts about Education grant funds  that could be used to support the use of technology to improve instruction  and student outcomes. It also issued a report in 2017 on the use of  technology in schools; the report provided guidance on how to modernize  the technology needed for digital learning, such as schools’ internet  networks and internet-enabled devices.

Education also collects, analyzes, and reports on a range of data from  schools and school districts. For example, every year from 1994 to 2005  (except 2004 due to a lack of funding according to Education officials),  the department collected data on internet access in schools and  classrooms. In 2008, Education conducted three similar surveys at the  district, school, and teacher levels on the availability and use of a range of  educational technology resources, such as networks, computers, devices  that enhance the capabilities of computers for instruction, and computer  software. Due to a lack of funding, Education did not conduct additional  similar surveys. However, the department recently finished administering  a different survey effort, funded from different sources, that we discuss  later in this report.

School-Age Children in Lower-Income Households Face Challenges in Doing Homework Involving Internet Access and May Be More Likely to Rely on Mobile Wireless

According to our analysis of November 2017 CPS: Computer and Internet  Use Supplement data, lower-income households with school-age children  may be more likely than those in higher-income households to be reliant  on mobile wireless service, such as through smart phones, for internet  access. As seen in figure 3, among all households with school-age  children, an estimated 22 percent with incomes of less than $25,000 per  year use mobile wireless to access the internet but not in-home fixed  high-speed internet service, in contrast to 8 percent with incomes of  $75,000 or more per year.

School-age children whose households only have mobile wireless internet  access may face challenges in using it for homework, including:

Device limitations. Students in mobile wireless-only households may  have to rely on devices like smartphones that may not be well suited  for academic tasks. A recent Pew survey found that an estimated 45  percent of teenagers in lower-income households say they sometimes  have to do homework on a smartphone. However, most of the  stakeholders we interviewed told us that smartphones are not  adequate for doing homework for various reasons, including that they  are too small for typing papers and that not all educational websites  are compatible with smartphones. According to these stakeholders,  other devices such as desktops or laptops are better suited for  homework; however, among all school-age children, those in lower- income households are less likely than those in higher-income  households to use these devices (see fig. 4).

Data limitations. A majority of the stakeholders we interviewed said  that wireless plans’ data caps—a limitation on the amount of data the  subscriber can download and upload per month—could make it  difficult for school-age children to do homework, because, for  example, once the data cap is reached, the provider may decrease  connection speeds or impose additional costs for further data use,  which could hinder completion of homework. A 2016 survey found  that an estimated 39 percent of lower-income households with school- age children—in this case those with incomes less than the federal  poverty guidelines—had reached a data cap, compared to 25 percent  of higher-income households.

Varying service quality. Mobile wireless may be less reliable and slower  than in-home fixed service, which can make doing homework more  challenging. In 2018, FCC concluded that mobile wireless services are  not full substitutes for in-home fixed service, because mobile wireless  quality can be affected by user location, indoor obstructions, outdoor  foliage, and weather, among other factors. In addition, we reported in  2015 that the availability and quality of mobile wireless service  connections vary based on location and terrain. For example, according  to officials with Albemarle County Public Schools in Virginia, while most  students who participated in a recent survey indicate that they have  mobile wireless internet access at home, that access may only offer poor  quality connections and slow speeds due to mountainous terrain. As a  result, mobile wireless access may have limited usefulness for homework  purposes.

A 2018 survey by the Pew Research Center found that about 20 percent  of teens from lower-income households say that they sometimes have to  use public Wi-Fi for homework given a lack of access at home. As  shown in figure 5, stakeholders we interviewed and literature we reviewed  identified a number of potential challenges students may encounter in  using methods to access the internet outside the home to do their  homework.

Efforts by Selected School Districts to Increase Wireless Internet Access for Underconnected Students Varied, with Limited Federal Involvement

School Districts, with Limited Federal Involvement, Have Taken Various Steps to Increase Wireless Internet Access for Underconnected Students

The six selected school district projects we reviewed have taken various  approaches to address the homework gap by providing wireless internet  service to students who may lack access at home. Most of these projects  provide wireless internet access to students who lack in-home fixed  internet and do not necessarily limit it to students in lower-income  households. In addition, all but one of these projects provide filtered  access, meaning that students using these services are subject to the  same usage restrictions as if they were on-site in school. Approaches  included:

Provide wireless hot-spot devices. The Green Bay Area Public  School District in Wisconsin loans out mobile wireless hot-spot  devices to students throughout the district who do not have access at  home, providing them filtered internet access in their homes or  elsewhere in the community. The hot-spot devices are available on  loan from school libraries to any student who claims a need for one  regardless of household income. Students may use district-issued  Chromebooks or other internet-enabled devices, which then connect  to the district’s internet resources via the hot-spot device using service  provided by a commercial mobile-wireless provider.

Build or use a private network. Some districts have built new or  expanded existing networks to provide internet access to students  using a variety of approaches. Albemarle County Public Schools in  Virginia uses EBS spectrum to provide access to students in  community centers in mobile home parks in this mountainous district  where, according to school district officials, many students lack  service at home. The district also plans to install wireless receiver  devices in selected students’ homes through which those students will  be able to connect internet-enabled devices via Wi-Fi. Desert Sands  Unified School District in California also built out an EBS network to  provide internet access to students who lack service at home.  According to officials with that district, the benefit of this approach is  that it involved only a one-time cost to build the network, rather than  recurring annual payments to a commercial mobile-wireless provider  for service.

Two rural, low-income school districts in Virginia—Charlotte County  Public Schools and Halifax County Public Schools—partnered with  Microsoft to provide service through unlicensed white space devices  (which operate on frequencies not being used by television  broadcasters or 600 MHz wireless providers) to students who lack  access at home, regardless of income . According to Microsoft, the  use of unlicensed white space devices is a good solution to providing  wireless access in rural areas where other technologies may be  uneconomical and such frequencies tend to be available. Students  who use this service receive a device that is installed in their home  that wirelessly connects to the district’s network and transmits to other  devices in the home via Wi-Fi.

The Boulder Valley School District in Colorado allowed a local  wireless provider to build antennas on some school buildings in order  to serve its customers in exchange for providing free service to lower- income students, determined based on student eligibility for free or  reduced price lunch. According to a school district official, the provider  has installed antennas at three schools, providing access to students  living within a 3-mile radius, and plans to install antennas at most  remaining schools in the district. That official told us that this model  may not work in many other school districts, as there may not be  sufficient population density to make it economically beneficial for a  commercial provider to agree to provide such service.

Equip school buses with Wi-Fi. The Coachella Valley Unified  School District, which covers a large geographic area in California  where many students lack in-home fixed access, equipped its fleet of  about 100 school buses with Wi-Fi in 2014, enabling students to do  homework during long bus rides. A commercial mobile-wireless  provider connected the Wi-Fi router on the bus to the district’s  network. In order to access Wi-Fi on the buses, students had to use  district-issued devices that they were allowed to bring home after  school. The district also parked Wi-Fi-equipped school buses and  other district vehicles overnight in neighborhoods with a high  proportion of students who brought district-issued tablets home in  order to provide access to students who likely lacked internet at  home. However, the district stopped this initiative in 2017 due to  limited funding and is now seeking out alternative funding sources to  reactivate the program.

While none of the projects described above used any funding from  Education, the department has identified six existing grants that schools  and districts could use under certain conditions to support internet  investments, although not necessarily wireless investments specifically.  While the purpose of each of these grant programs isn’t specific to  internet investments, Education identified specific types of internet  investments that these grant funds can be used for. We did not make a  determination as to whether any of the grant funds could have supported  the efforts we reviewed. Representatives of two of the school districts we  met with stated that they would like to see additional information on  Education grants that could be used to support internet investments.  Education officials said the department has taken the first step to  developing a strategy to share information about these grants by  developing a coordinated communications strategy through its Office of  Rural Engagement. They added that the department will then continue to  build a broader strategy.

Education is also finalizing data collection on a survey that will collect  some data regarding the homework gap. As mentioned earlier, until 2008  Education collected survey data over a number of years about information  technology and internet access in schools and classrooms. According to  Education officials, the department stopped collecting such data due to a  lack of funding. However, the department is now finalizing a survey that is  collecting nationally representative data about public school teachers’ use  of computers and the internet, and their knowledge of students’ access to  computers and the internet outside the classroom. The survey is  collecting data that pertain to the homework gap, including the extent to  which schools provide wireless hot-spot devices to students to take  home; the extent to which teachers think students access the internet  outside of school, such as at home, libraries, or businesses; and the  extent to which teachers think smartphones are useful for doing  homework. According to Education, the department finished administering  the survey in June 2019 and plans to release the results in April 2020.  The survey data may provide Education and others, including FCC and  Congress, with useful information that can inform policy and other  decisions related to the homework gap, such as how best to support  schools’ efforts to expand wireless access for underconnected students.

FCC had a minor role in some of the school district projects by having  previously granted EBS licenses to some districts that use EBS spectrum  to provide wireless access. However, according to FCC documentation,  many schools and school districts do not have EBS licenses—such as  those in rural areas in the western United States—and some that have  obtained a license now lease their capacity out on a long-term basis to  commercial providers. As a result, school districts may be limited in using  EBS to provide wireless access to students or have to take additional  steps to use EBS. Desert Sands Unified School District officials said that  the district did not have an EBS license and that the local license holder  had leased it out to a commercial provider, so the district worked with that  provider to build out its EBS network. Albemarle County Public Schools  had leased out its EBS license to a commercial provider years ago, but  because that provider was not utilizing that spectrum, the school district  was able to reclaim it.

FCC has taken recent steps that may affect the extent to which school  districts are able to use EBS to provide wireless access. In May 2018,  FCC issued a Notice of Proposed Rulemaking seeking comment on  proposed changes to how it manages EBS to encourage and facilitate its  efficient use. In July 2019, FCC adopted a Report and Order that makes  a number of changes to the EBS spectrum and its use. Specifically, once  effective, these rules will eliminate eligibility restrictions for EBS licenses  and eliminate the educational use requirement of the spectrum.

FCC Has Not Fully Evaluated the Possibility of Expanding the E-Rate Program to Include Off- Premises Wireless Access

While FCC’s E-rate program supports schools’ connectivity by providing  discounts for eligible services, program rules may limit the ability of  schools and school districts to address the homework gap. Specifically,  program rules specify that off-premises use of such services is not eligible  for E-rate support and require that any off-premises traffic must be cost  allocated out of school districts’ E-rate discounts. For example, any off- premises traffic supported by existing E-rate-supported products or  services requires a reduction in the E-rate discount for those existing E- rate supported products and services. This reduction may increase costs  for school districts as they would no longer receive all their potential E- rate discounts. Officials representing all six of the school district projects  we reviewed suggested that program rules limiting eligibility for off- premises use and requiring cost-allocation may inhibit the ability of school  districts to expand off-premises wireless access, and thus address the  homework gap.

For districts that do provide wireless access off-premises, E-rate program  restrictions may still pose challenges. For example, according to an  official with Desert Sands Unified School District, the district had to buy a  separate line of internet access to avoid having that off-premises traffic  travel through the district’s existing E-rate-supported network, which  would have required cost-allocation and a reduction of the E-rate discount  for that existing E-rate supported network. According to officials with  Microsoft, Charlotte County Public Schools and Halifax County Public  Schools had to separate their off-premises unlicensed white space device  traffic from internet traffic that passed through E-rate-discounted access  in the schools. An official with Boulder Valley School District said that the  district had to terminate an earlier effort to extend access to students in a  housing development after being told that it could not provide off- premises access with program-discounted equipment without cost- allocation.

In September 2016, FCC issued a Public Notice requesting public  comment on two petitions filed with the agency seeking to allow the  petitioning school districts to use existing E-rate-program-supported  services and equipment for off-premises access without having to cost- allocate that traffic out of their existing E-rate discounts. Cost allocating  out that traffic would result in reduced E-rate discounts for school districts,  and therefore higher costs, for existing services and equipment supported  by E-rate. FCC rules allow parties to petition for waivers of rules if they  can demonstrate that special circumstances warrant deviation from the  existing rules and doing so serves the public interest. According to FCC  officials, the petitions are pending and the agency has not yet taken  further formal action on this Public Notice. The petitions are described in  more detail below.

In May 2016, the Boulder Valley School District filed a petition  requesting a waiver of the cost allocation rules in order to use its E- rate-program-supported network to provide internet access to  students at public housing facilities after school hours. In the  petition, the district argued that because traffic on its E-rate program- supported network dramatically decreased after school hours, using  that network to provide access during that time would not impose any  additional costs on the E-rate program.

Microsoft and others—including the school districts in Charlotte and  Halifax counties—filed a petition in 2016 to obtain clarification that  those school districts could provide wireless access to students’  homes for educational purposes by extending the districts’ existing E- rate-supported services using the districts’ unlicensed white space  device network without cost allocating that traffic from the existing E- rate discounts. The petition stated that the infrastructure to provide  service to unlicensed white space devices would not be funded with  E-rate program funds, and that these districts were not well served by  commercial internet providers. In comments filed with FCC, Microsoft  argued that projects covered by both petitions would provide in-home  access for students without imposing any additional costs to the E- rate program and that the projects would increase the productivity of  E-rate by using existing resources more efficiently.

Previously, FCC explored the possibility of making wireless off-premises  access an allowable E-rate program expense—which would eliminate the  requirement to cost-allocate such traffic—in a 2011 to 2012 pilot  program. When establishing this pilot program, FCC noted commenter  concerns regarding the potential administrative, legal, technological, and  procedural challenges of expanding E-rate funding to off-campus  premises. The pilot program provided funding from July 2011 to June  2012 and sought to “investigate the merits and challenges of wireless off- premises connectivity services” and to “gain a better understanding of  operation and administrative issues associated with off-premises use and  connectivity, as well as the financial impact on the E-rate program  overall.” Furthermore, the pilot program sought to help FCC determine  whether off-premises connectivity services “should ultimately be eligible  for E-rate support.”

FCC provided a total of $9 million in grants to 20 pilot-program  participants—19 schools or school districts and one community library  system—to implement projects enabling innovation in learning outside the  boundaries of school buildings and the traditional school day, including  those that provided off-premises wireless access and wireless devices to  students. Recipients were not required to cost allocate the off-premises  traffic as part of the pilot.

FCC required all pilot participants to file interim and final reports that  included information about project benefits, such as the extent to which  students provided with wireless devices used them and the effect of  increased internet access on academic outcomes; project costs; the  effectiveness of measures to prevent project waste, fraud, and abuse, to  filter content, and to ensure that students only used the devices for  educational purposes; and lessons learned. According to FCC, those  reports would allow it to assess the impact of selected pilot projects on  the schools and to gather lessons learned that would help others  implement similar projects in the future. In addition, FCC said it would  evaluate the effectiveness of the pilot program to determine whether off- premises wireless access should be eligible for E-rate program support.

While FCC received interim and final reports from most pilot participants,  it did not determine a methodology for evaluating the data provided in  those reports. Furthermore, FCC did not publish a report evaluating the  effectiveness of the pilot program, including the potential costs, benefits,  and challenges of off-premises wireless access to make a determination  regarding whether off-premises access should be eligible for E-rate  program support. Although the order establishing the pilot did not require  FCC to determine an evaluation methodology and publish a formal  analysis, according to FCC officials, staff reviewed the interim and final  reports prior to the Commission adopting a 2013 Notice of Proposed  Rulemaking that sought input on ways to modernize the E-rate program,  including input on using E-rate-supported wireless hot-spots for  community use.

In two subsequent E-rate program modernization orders in 2014, the  Commission did not expand the E-rate program’s support for off-premises  access. FCC officials explained that given the changes in technology,  costs, and student learning in recent years, the data collected from the  pilot may have some limitations. FCC has not announced any plans to  conduct another pilot program, and aside from its consideration of the  petitions previously mentioned, FCC has not announced an intention to  revisit whether off-premises wireless access should be eligible for E-rate  support.

Federal internal control standards state that agencies should use quality  information to make decisions and communicate information to external  parties. Specifically, agencies should collect data from reliable sources  in a timely manner, process these data into quality information, and use  that information to make informed decisions. Agencies should also  communicate such information to external parties that can help the  agencies achieve their objectives. Furthermore, in previous work we  identified as pilot-program design best practices: determining a methodology for gathering and evaluating data, evaluating pilot results to make conclusions on whether to integrate  pilot activities into broader efforts, and  communicating with stakeholders—such as by publishing results.

As discussed earlier, school districts we met with said that existing E-rate  program rules that require cost-allocation of off-premises access to E-rate  discounts limit their ability to address the homework gap and providing  off-premises access remains a challenge for schools and school districts.  Determining and executing a methodology for collecting and analyzing  data on the potential costs, benefits, and challenges of making schools’  efforts to expand off-premises wireless access eligible for program  funding could help inform FCC decisions regarding the two pending  petitions and any future petitions. As petitions may only cover petitioning  entities, determining and executing such a methodology could also help  inform more widespread changes to E-rate rules regarding off-premises  access that would affect all E-rate program recipients. FCC could collect  such data through another pilot program or from school districts now  providing off-premises wireless access. Publishing the results of this  analysis could help FCC ensure that such information will be accessible  to inform future related efforts and provide transparency to external  stakeholders, including school districts.

The differences in internet access—and therefore in the ease of doing  homework—between school-age children in lower-income households  and those in higher-income households that are more likely to be well  connected has resulted in a “homework gap” that could inhibit the  academic success of underconnected students. While school districts  have made efforts to address the homework gap, such efforts may be  inhibited by existing restrictions in FCC’s E-rate program. Although FCC  explored the possibility of making wireless off-premises access an  allowable E-rate program expense in a 2011 to 2012 pilot program, FCC’s  lack of an analysis of the data it collected at the time or since then means  that it may not have sufficient and relevant information to make a decision  on pending petitions from local school districts regarding off-premises  access. Determining the best way to collect and analyze data on the  potential benefits, costs, and challenges of making off-premises wireless  access eligible for E-rate program support; conducting such analysis; and  publishing the results could provide relevant information and transparency  to external stakeholders. Doing so could also enable FCC to make a  determination on whether it would be appropriate to ease restrictions on  off-premises access, a step that may give school districts more flexibility  in addressing the homework gap.

We are making the following recommendation to FCC:  The Chairman of the Federal Communications Commission should  determine and execute a methodology for collecting and analyzing data— such as conducting a new pilot program regarding off-premises wireless  access or analyzing other data—to assess the potential benefits, costs,  and challenges of making off-premises wireless access eligible for E-rate  program support, and publish the results of this analysis.  (Recommendation 1)

We provided a draft of this report to FCC, Education, and the Department  of Commerce for review and comment. FCC provided written comments,  which are reproduced in appendix II. In these written comments, FCC  stated that it agreed with our recommendation and noted steps it plans to  take to assess the potential benefits, costs, and challenges of making off- premises broadband access eligible for E-Rate program support. FCC  also provided technical comments, which we incorporated as appropriate.  Education provided written comments, which are reproduced in appendix  III and also provided technical comments that we incorporated as  appropriate. The Department of Commerce reviewed our report and told  us it did not have any comments.

We are sending copies of this report to interested congressional  committees, the Chairman of the FCC, the Secretary of Commerce, and  the Secretary of Education. In addition, the report will be available at no  charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or vonaha@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix IV.

Our objectives for this report were to examine: (1) challenges lower- income school-age children who lack in-home fixed internet face in doing  homework that involves internet access and (2) what selected school  districts are doing to expand wireless internet access for their students,  and the federal role in such efforts.

To examine challenges lower-income school-age children who lack in- home fixed internet face in doing homework that involves internet access,  we analyzed data from the Census Bureau’s November 2017 Current  Population Survey: Computer and Internet Use Supplement, which is  sponsored by the National Telecommunications and Information  Administration (NTIA). The Computer and Internet Use Supplement  collected household information from all eligible Current Population  Survey households, as well as personal information from household  members age 3 and older. The supplement provided data about  households’ computer and internet use, and about each household  member’s use of the internet from any location during the previous six  months. One member of a household was generally interviewed and  answered questions on behalf of every other member. Interviews were  conducted from November 12–18, 2017. The probability sample selected  to represent the universe consisted of approximately 56,000 households.

We included variables on ages of household members to determine if the  household had one or more school-age children. We considered a  household to have school-age children if it had any children between the  ages of 6 and 17, an age range used in other analyses of internet use by  school-age children, such as analyses by NTIA and Pew Research  Center. We analyzed data on the use of in-home fixed and mobile- wireless internet, as well as of various computing devices. In our analysis  we also included variables on household income, to allow us to report  results based on different income ranges. When analyzing responses by  household income, we grouped household income into similar ranges that  NTIA publishes on its Data Explorer website, but we consolidated the top  two ranges used by NTIA into one range. To determine the reliability of  these data, we reviewed NTIA technical documentation on the survey,  interviewed NTIA officials, and compared our estimates of selected  variables with estimates presented by NTIA on its website. We found  these data were sufficiently reliable for reporting on data on internet and  computing device use by household income levels.

In addition, we conducted a literature search to review challenges lower- income school-age children who lack in–home internet face in doing  homework that involves internet access. We searched multidisciplinary  databases using relevant terms such as “low-income,” “wireless,”  “internet,” and “school-age children.” We searched for scholarly articles,  including working and conference papers, government reports, think tank  publications, and trade publications published between 2013 and 2018.  We reviewed the abstracts of results from the search for publications  most relevant to our work and fully reviewed publications that, based on  their abstract, were most suited to this engagement. We used relevant  publications to support findings we collected from other sources, including  interviews.

We also conducted semi-structured interviews with a range of  stakeholders, including education industry associations, researchers, and  advocacy organizations we selected based on literature, internet  searches, and recommendations from those we interviewed. Specifically,  we interviewed eight education or technology industry associations or  advocacy organizations, one education researcher, one technology  industry researcher, and representatives of one technology company that  provides internet services and products to schools. In addition, we  interviewed officials with the Federal Communications Commission (FCC)  and Department of Education (Education).

We also reviewed a non-generalizable sample of six projects involving  seven local school districts taking steps to provide wireless internet  access outside of school for students who may lack internet at home. We  identified these projects based on keyword searches and  recommendations from other interviewed associations and researchers,  as well as officials with FCC, NTIA, and Education. From this list, we then  selected those projects that were frequently cited in the press or by others  we interviewed; that covered a variety of geographic locations, including  those in both urban and rural areas; and that included a variety of  approaches to addressing the homework gap. During these interviews,  we asked interviewees about a range of topics, including the extent to  which school-age children have access to in-home and wireless internet  and challenges faced by students who may only have mobile wireless  access. In total we interviewed 17 stakeholders, including the industry  associations, researchers, and school districts detailed above. We  analyzed the content of the interviews to identify key challenges identified  by stakeholders. These interviews did not provide a complete list of all  challenges, and the results of these interviews are not generalizable but  do provide insight into a range of issues.

To determine what selected school districts are doing to expand wireless  internet access for their students and the federal role in such efforts, we  conducted semi-structured interviews with officials at the school districts  listed above and officials at Microsoft regarding its efforts to expand  wireless access for students who may lack internet at home. During these  interviews, we asked the districts about what steps they are taking to  expand wireless access, the goals and challenges of the relevant project,  and the federal role in the effort. We analyzed the content of the  interviews to identify key themes.

We also interviewed officials with FCC and Education to determine and  review federal efforts related to school initiatives to expand wireless  access for students. We reviewed documentation from FCC and  Education regarding relevant federal efforts including rulemaking  documents such as FCC’s 2018 Notice of Proposed Rulemaking and  2019 Report and Order regarding Educational Broadcast Service  spectrum. We reviewed other relevant FCC documents related to the  Schools and Libraries Universal Service Support Mechanism (also known  as the E-rate program), which provides schools with discounts on  telecommunications and internet services. E-rate documents we reviewed  included reports related the 2011 E-rate pilot program exploring off- premises wireless access. We compared FCC efforts to federal internal  control standards related to using quality information and communicating  externally and pilot program design best practices. We reviewed  information, provided to us by department officials, on existing Education  grant programs that can be used by schools and school districts to  support internet investments. We also reviewed information on  Education’s relevant survey efforts.

Appendix II: Comments from the Federal Communications Commission

Appendix III: Comments from the Department of Education

Appendix IV: GAO Contact and Staff Acknowledgments

Andrew Von Ah at (202) 512-2834 or vonaha@gao.gov.

In addition to the contact above, Mark Goldstein (Director); Derrick Collins  (Assistant Director); Matthew Rosenberg (Analyst in Charge); Dwayne  Curry; Sherri Doughty; Rachel Frisk; Hayden Huang; Gina Hoover; Dan  Luo; Josh Ormond; Cheryl Peterson; Matt Ray; Hai Tran; and Laurel  Voloder made key contributions to this report.

Internet access is crucial for students both in and out of the classroom. School-age children with little or no access at home may have difficulty completing homework, putting them at risk of falling behind better-connected peers—a condition known as the “homework gap."

The Federal Communications Commission's (FCC) E-rate program allows schools to purchase discounted internet equipment. However, schools cannot use these funds to provide wireless access off school grounds.

We recommended that FCC assess and report on the potential benefits, costs, and challenges of making wireless access off school grounds eligible for E-rate.


Emergency Transportation Relief: Federal Transit Administration and FEMA Took Actions to Coordinate, but Steps Are Needed to Address Risk of Duplicate Funding

In August and September 2017, Hurricanes Harvey, Irma, and Maria made landfall in Texas, Florida, the U.S. Virgin Islands, and Puerto Rico, causing hundreds of millions of dollars in damage to public transit facilities. Access to transit plays an important role in a community's post-disaster recovery. FTA has primary responsibility for providing disaster assistance funding to transit agencies if it receives an appropriation from Congress. If FTA does not receive an appropriation, transit agencies can apply to FEMA for funding.

GAO was asked to evaluate the federal government's response and recovery efforts related to the 2017 hurricanes. This report provides information on FTA's emergency relief allocations and examines FTA's and FEMA's coordination. GAO reviewed FTA's allocation of emergency relief funds; conducted site visits to Texas, Florida, and Puerto Rico; obtained survey responses from 44 of 52 transit agencies; and interviewed and reviewed documentation from FTA and FEMA officials.

In response to hurricanes in 2017, the Federal Transit Administration (FTA) announced in May 2018 that it would allocate about $233 million of appropriated emergency relief funds to 52 transit agencies for response, recovery, and rebuilding projects, with most of that funding going to Puerto Rico ($198 million). Most of Puerto Rico's funds, and around half the funds FTA allocated ($116 million), will be distributed to one transit system—Tren Urbano—San Juan's rail-transit service provider (see figure below).

While FTA and the Federal Emergency Management Agency (FEMA) shared information and coordinated efforts, both agencies still approved about $35,000 to one applicant for the same expenses. GAO found that FTA awarded a grant in April 2019 that included expenses for which FEMA had already obligated funds in January 2019. Although FTA contacted FEMA prior to the award to inquire whether the applicant had received FEMA funding, FEMA did not respond within 5 days, and per an agreement between FTA and FEMA, FTA processed the application. After GAO identified the duplicate funding, FTA and FEMA took steps to limit the potential for duplicate funding; FTA, for example, changed its policy of moving applications forward after 5 days if FEMA does not respond. FTA and FEMA officials noted challenges they face in identifying transit expenses in the applications they receive. For example, they may be unaware that a transit agency received FEMA funds if it received those funds through a larger entity such as a city, county, or state government. Although the amount of funding FEMA and FTA approved for the same expenses was relatively small, without addressing these challenges, FTA and FEMA will continue to face the risk that both agencies will approve funding for the same expense in the future.

GAO recommends that FTA and FEMA identify and develop controls, such as methods to more easily identify transit expenses within larger applications, to address the risk of duplicate funding. The Department of Transportation agreed with the recommendation and noted steps FTA has taken to address it. However, GAO believes FTA would benefit from identifying additional internal controls to address the risk of duplicate funding. The Department of Homeland Security agreed with the recommendation and outlined steps FEMA plans to complete in 2020.

In August and September 2017, Hurricanes Harvey, Irma, and Maria  made landfall in Texas, Florida, the U.S. Virgin Islands, and Puerto Rico,  causing hundreds of millions of dollars in damage to public transit  facilities. The loss of transit during a disaster can exacerbate the  difficulties a community faces by impeding access to community services  and medical care, and access to transit is important in a community’s  post-disaster recovery. Two agencies play an important role in providing  funding to transit agencies following a disaster: the Federal Emergency  Management Agency (FEMA) within the Department of Homeland  Security (DHS), and the Federal Transit Administration (FTA) within the  Department of Transportation (DOT).

Prior to 2012, the primary source of federal funding for transit agencies  working to recover after a disaster was FEMA’s Public Assistance  Program. In 2012, the Moving Ahead for Progress in the 21st Century  Act (MAP-21) authorized FTA’s Public Transportation Emergency Relief  program. Because the FTA program is focused on public transportation  specifically—unlike FEMA’s more general program—FTA has primary  responsibility for reimbursing emergency response and recovery costs  after an emergency or major disaster that affects a public transportation  system if FTA receives funds for the program in an annual or  supplemental appropriation, or continuing resolution. In February 2018,  Congress appropriated $330 million to FTA’s Public Transportation  Emergency Relief program in a supplemental appropriation—the second  time funding has been appropriated to the program—to provide funding to  transit agencies affected by the 2017 hurricanes (Harvey, Irma, and  Maria). We have previously noted the importance of FTA and FEMA  coordination, given the fact that both agencies may provide funding for  transit-related expenses following a disaster.

We were asked to evaluate the federal government’s response and  recovery efforts related to the 2017 natural disasters, including  Hurricanes Harvey, Irma, and Maria. This report provides information on the amount of emergency relief funds FTA  allocated to repair and replace transit facilities damaged by hurricanes  Harvey, Irma, and Maria, and the purposes of these allocations, and examines the extent to which transit agencies applied to FEMA for  funding as well as FTA’s and FEMA’s coordination.

To determine the amount of funds FTA allocated to repair and replace  transit facilities damaged by the 2017 hurricanes, we reviewed FTA’s May  31, 2018, notice of allocation of emergency relief funds, in which FTA  described the amount of funding it would provide to each municipality and  public transit provider. To understand the purpose of the allocations and  how FTA funds would be used, we reviewed FTA’s damage assessment  reports for the 2017 hurricane. These reports describe the location and  type of damage in specific areas as well as the estimated costs to  address the damage. One analyst categorized the types of expenses into  specific categories and summed the total amount of funding provided for  various types of expenses (such as repairs to bus terminals), and a  second analyst verified the categorizations. To assess the reliability of the  data, we shared our analysis with FTA and incorporated its proposed  updates, where appropriate. We did not independently verify the  estimated damage costs. In addition, we conducted site visits to Texas,  Florida, and Puerto Rico (the states and territory receiving the largest  FTA allocations following the 2017 hurricane) to tour damaged facilities  and interview officials from a non-generalizable selection of two to four  transit agencies in each state or territory. Sites were selected to include  transit agencies with the largest allocations as well as those within driving  distance of one another, for logistical reasons.

To examine whether transit agencies applied to FEMA for funding, we  interviewed the transit agencies mentioned above and we conducted a  web-based survey of the 52 transit agencies that received a direct  allocation of emergency relief funding from FTA (FTA grantees). Forty- four of the 52 FTA grantees (85 percent) completed our survey. We  asked about the level of their engagement with FEMA. We initially fielded  the survey from December 10, 2018, to January 15, 2019, and continued  to accept responses from a few grantees until March 12, 2019. To assess  FTA and FEMA’s coordination, we interviewed officials from FTA  headquarters and division offices responsible for administering the Public  Transportation Emergency Relief program, as well as FEMA officials at  headquarters and regional offices responsible for administering FEMA’s  Public Assistance program for the selected states and territories. We  reviewed documentation from FTA and FEMA coordination meetings, as  well as emails regarding specific applications between FTA and FEMA  staff. We compared FTA’s and FEMA’s coordination against federal  internal control standards as well as statutory requirements in MAP-21  and FTA and FEMA guidance regarding how the agencies should  coordinate.

We conducted this performance audit from April 2018 to November 2019  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

When a disaster overwhelms the ability of state, local, or voluntary  agencies to adequately provide essential services on their own, the  federal government, when requested, supports disaster response and  recovery, providing selected resources where they are needed. The  federal government has provided significant funds for transit services  following past catastrophic disasters. For example, Congress provided  roughly $232 million in response to the 2005 Gulf Coast hurricanes and  over $10 billion in response to Hurricane Sandy.

FEMA is the federal government’s primary agency for disaster response.  In addition to coordinating disaster response and recovery operations,  FEMA’s Public Assistance Program provides funding to state and local  governments and some nonprofit organizations for recovery efforts after a  disaster, including removing debris, implementing emergency protective  measures, and repairing or replacing damaged public equipment or  facilities. Once the President has declared a disaster, FEMA; the state or  territorial government (the recipient); and the local or territorial entities  (the subrecipient) work together to develop damage assessments and  formulate project worksheets for eligible projects. Project worksheets  detail the scope of work and estimated cost for repairing or replacing  disaster-damaged infrastructure. After a project has completed FEMA’s  review process and is approved, funding is available to FEMA for  obligation from the Disaster Relief Fund. The recipient draws down—or  withdraws—funding to pay the subrecipient for eligible work upon  completion.

Because FTA’s Public Transportation Emergency Relief Program is  focused on public transportation specifically—unlike FEMA’s more  general program—FTA has primary responsibility for reimbursing  emergency response and recovery costs after an emergency or major  disaster affects a public transportation system if FTA receives funds for  the program in an annual or supplemental appropriation or continuing  resolution. The Public Transportation Emergency Relief program is a  reimbursable grant program and allows FTA to make grants for capital  projects to protect, repair, reconstruct, or replace equipment and facilities  of a public transportation system as well as for eligible operating costs.  Such costs include reestablishing, expanding, or relocating public- transportation route service in the event of a natural disaster that affects a  wide area or a catastrophic failure from any external cause.

Congress has not provided an annual appropriation for FTA’s Public  Transportation Emergency Relief Program but has provided supplemental  appropriations following a specific event. Eligible recipients (referred to in  this report as “FTA grantees”) of FTA’s Public Transportation Emergency  Relief funding are entities that receive funds directly from FTA. Following  the appropriation for the 2017 hurricanes, FTA staff and contractors  visited sites to develop damage assessments—these assessments  provide information on, among other things, the specific location, type of  facility or equipment, nature and extent of damage, and a preliminary cost  estimate to restore, replace, or reconstruct the damaged system. FTA  then uses the information in these damage assessments to determine  how to allocate funding among the affected FTA grantees. After FTA  announces the allocations, FTA grantees can submit an application for  funding to FTA. After FTA has approved the application and obligated  funds, recipients must execute the grant agreement to draw down funding  for reimbursement of eligible expenses.

As required by MAP-21, FTA and FEMA have entered into a  memorandum of agreement (MOA) to delineate the roles and  responsibilities of the two agencies and establish procedures to  coordinate assistance for public transportation following a disaster. We  reported in 2014 that because FTA’s Public Transportation Emergency  Relief Program is inherently limited by its inability to fund any activities  without specific congressional action (in contrast to the other emergency  program we examined), FTA and FEMA face challenges clearly  delineating the responsibilities and costs each agency will assume during  future disasters. We recommended that FTA and FEMA establish  specific guidelines to monitor, evaluate, and report the results of  collaborative efforts for future disasters. FEMA concurred with this  recommendation and FTA took no position. The agencies addressed the  recommendation by: (1) implementing a communications protocol to  coordinate the two agencies in providing funding to transit agencies and  (2) committing to jointly monitoring, evaluating, and reporting on the  effectiveness of agency collaboration following events in which both  agencies provided funding.

In August and September 2017, Hurricanes Harvey, Irma, and Maria  made landfall in Texas, Florida, the U.S. Virgin Islands, and Puerto Rico,  affecting over 28 million people and causing significant damage to public  transit infrastructure (see fig. 1). FEMA funding was made available  through presidential disaster declarations. In February 2018, 6 months  after the first hurricane made landfall, Congress appropriated funds to  FTA’s Public Transportation Emergency Relief Program for the 2017  hurricanes.

FTA Allocated Over $230 Million to Repair and Replace Transit Infrastructure, with Most of the Funds Allocated to Puerto Rico

FTA announced on May 31, 2018, that it would allocate about $233  million of appropriated emergency relief funds to 52 transit agencies for  response, recovery, and rebuilding projects, with approximately 85  percent of the funds ($198 million) going to Puerto Rico. Most of Puerto  Rico’s funds, and around half the funds FTA allocated for response,  recovery, and rebuilding ($116 million), will be distributed to San Juan’s  rail transit service provider, Tren Urbano (see fig. 2).

FTA allocated emergency relief funding to transit agencies based on  preliminary cost estimates that the agencies submitted to FTA in damage  assessment reports. Transit agencies developed these preliminary cost  estimates through field surveys, which are meant to determine the  general type and extent of damages. As shown in table 1, FTA allocated  funds for various purposes including repairs to rail stations and bus  terminals, repair and replacement of vehicles, and repairs to transit  buildings and facilities.

As previously noted, after FTA allocates funds, transit agencies must  submit grant applications with detailed information about each eligible  project activity and expense. As of October 2019, 19 transit agencies had  submitted grant applications to FTA, and FTA approved and obligated  funding for each of the 19 applicants. FTA officials told us they are  working with the remaining transit agencies on submitting and finalizing  their grant applications.

Many FTA Grantees Applied to FEMA for Funding, and FEMA and FTA Faced Challenges in Coordinating to Avoid Duplicate Funding

More Than Half of the FTA’s Grantees Responding to Our Survey Reported Some Interaction with FEMA

Uncertainty regarding whether FTA will receive an appropriation can lead  to FTA grantees’ applying to FEMA for funding since FEMA is the federal  government’s primary agency for disaster response and recovery and can  fund transit. This situation increases the importance of FEMA and FTA  coordination. FTA did not receive an appropriation until roughly 6 months  after the first hurricane’s landfall. FTA grantees, unaware of when or  whether FTA would receive an appropriation, could apply during this  period to FEMA’s Public Assistance Program for funding. Indeed, more  than half of FTA grantees that responded to our survey (25 of 44)  reported some interaction with FEMA’s Public Assistance Program by the  time of our survey (see fig. 3). Fourteen reported reaching the quality  assurance step on a grant application—the final step before receiving  funds from FEMA. Six transit agencies received FEMA funds.

Once FTA received an appropriation, FTA and FEMA instructed transit  agencies to work with FTA, rather than FEMA, on funding requests. As a  result, some transit agencies that initially worked with FEMA had to begin  a new application with FTA. Fourteen FTA grantees in our survey  reported spending more than 3 months working on their FEMA  application; however, 10 stated that they could use the work from the  FEMA application toward their FTA emergency relief application. In  addition, most of the transit agencies we interviewed anticipated this  issue, noting that FTA or FEMA officials explained the situation to them  before FTA received an allocation.

FTA and FEMA Shared Information with One Another but Faced Challenges Coordinating on Screening Applications to Avoid Duplicate Funding

FTA and FEMA Took Steps to Coordinate and Share Information

After Congress appropriated funds to FTA for the 2017 hurricanes, FTA  and FEMA initiated their communication and coordination agreements,  including the MOA and the communications protocol, which define  coordination activities between the two agencies. Federal agencies, such  as FTA and FEMA, that administer programs as a result of a major  disaster or emergency, cannot provide funding for losses that have been  covered by insurance or other programs, but are not prohibited from  awarding funds to any entity that could receive funding from another  agency so long as that entity has not yet received these funds and  promises to repay any duplicate assistance. FTA’s and FEMA’s  communications protocol also states that it may be appropriate for an  agency to receive funding from both FTA and FEMA in a situation where  the grantee provides both public transportation services and services  other than public transportation. Thus, FTA’s and FEMA’s MOA states  that the agencies will coordinate to avoid duplicate funding and to ensure  a streamlined reimbursement process.

When implementing coordination activities such as FTA’s and FEMA’s  MOA and communications protocol, federal internal control standards  state that management should design control activities to achieve  objectives and respond to risks, such as the risk of providing duplicate  funding. FTA and FEMA officials informed us of, and provided  documentation of, their coordination efforts, such as biweekly conference  calls, and email correspondence among staff. For example, when  Congress appropriated funds to FTA, FEMA provided FTA a list of  agencies that had applied to FEMA for funding. In addition, when FTA  reviewed grant applications, FTA staff emailed FEMA staff to inquire whether applicants had already requested funding from FEMA. To avoid  delays in processing applications, FEMA and FTA established an  agreement that if FEMA did not respond to such requests in 5 days, then  FTA could proceed with processing the application. Based on our  document reviews, we found that FTA staff also emailed FEMA staff a  copy of the final award. Finally, transit agencies applying to FTA for  funding were required to certify whether they had received any transit  funding from FEMA and that they would reimburse FTA for any federal  funds that duplicated funding provided by FEMA.

FTA and FEMA Faced Challenges Coordinating on Screening Applications to Avoid Duplicate Funding

While FTA and FEMA took steps to coordinate, both agencies approved  about $35,000 in funding to one applicant for the same expenses. In June  2019, we found a case in which FEMA and FTA both approved roughly  $6,000 to repair a light pole at a bus stop in Collier County, Florida.  Specifically, although FEMA had obligated funds to Collier County for the  light pole in January 2019, FTA awarded funds for the same light pole in  April 2019. One month prior to FTA’s award to Collier County, we notified  FTA that Collier County had indicated in our survey that it had been in  contact with FEMA. Subsequently, FTA staff twice emailed FEMA staff to  inquire as to whether Collier had requested funds from FEMA, but FEMA  staff did not respond. Per their agreement, FTA moved the application  forward after receiving no response from FEMA within the 5-day  timeframe. FTA awarded the funding to Collier County in April 2019. After  we notified FTA and FEMA that they both appeared to have awarded  funds for the same expense, FEMA de-obligated the funds for Collier  County. In addition, FEMA conducted an additional review and found that  both agencies had also approved $29,000 in funding for repairs to a  transit facility in Collier County. FEMA officials stated they were in the  process of de-obligating those funds as well. Although both agencies  awarded funds to Collier County, the County had not yet executed the  FTA grant or drawn down any of the funds.

FTA and FEMA officials noted that both agencies can face challenges in  identifying transit expenses submitted to both agencies. For example,  FTA may be unaware of transit agencies receiving FEMA funds if these  agencies are not direct recipients of such funds, but rather receive funds  through a larger entity such as a city, county, or state government. Thus,  although FEMA provides FTA with a list of entities that applied for FEMA  funds, the list may only show a county’s name, rather than the name of a  transit agency. In addition, while FTA also asks applicants whether they  have received FEMA funds, applicants may be unaware of the status of  their FEMA reimbursement. For example, officials from Collier County’s  public transit department told us they were unaware that FEMA had  obligated funding for their transit expenses until May 2019 (one month  after the FTA award), because it took several months for the funding from  FEMA to be processed at the state and county level.

While FTA officials shared proposed and final awards with FEMA, we  identified 10 cases, including Collier County, in which FEMA officials did  not respond within the established 5-day time frame. When we asked why  FEMA did not respond within the 5-day time frame, FEMA regional staff  stated that the responsible person had since left that office. However,  officials noted challenges they face identifying transit expenses contained  within applications sent to FEMA by larger entities that may contain  hundreds of pages, while at the same time processing a large number of  applications related to the hurricanes. Specifically, in order to identify  transit expenses within an application, FEMA staff may need to search  these hundreds of pages using various transit-related word searches. For  example, according to FEMA officials, Collier County currently has a total  of 126 active ongoing and obligated projects and 86 inactive projects that  were either withdrawn or determined ineligible.

After we notified FTA and FEMA that they had approved funding to Collier  County for the same expense, both agencies took steps to limit the  potential for duplicate funding in future awards. As noted above, FEMA  conducted an additional review of applications for which FEMA had not  responded to FTA’s inquiries within the 5-day time frame and identified  the $29,000 for transit facility repairs that FTA and FEMA both approved  for Collier County. In addition, FTA officials updated their internal grants  guidance to indicate that FTA staff should not process an application if  FEMA has not responded and FTA has reason to believe there may be a  potential for duplicate funding (for example, the recipient notifies FTA that  it had previously worked with FEMA to reimburse transit expenses). In  such cases, FTA may only proceed after FEMA has replied in writing that  they have not identified any expenses in the FTA grant that are also in a  FEMA grant, or, if FEMA does identify duplicate funding, after one agency  removes such expenses from their grant to the recipient.

In 2014, we noted that evaluating and reporting the results of  collaborative efforts can identify areas for improvement and  recommended that FTA and FEMA establish specific guidelines to  monitor, evaluate, and report the results of collaborative efforts. FTA and  FEMA implemented this recommendation and committed to jointly  monitoring, evaluating, and reporting on the effectiveness of the agencies’  collaboration following future events in which both agencies provide  funding. In addition, FTA and FEMA took action to address the duplicate  award of funding we identified in our review. Nonetheless, FEMA staff  continue to face challenges identifying transit expenses within  applications submitted by larger entities, and FTA may be unaware of  whether transit entities are included in such applications. Without  identifying and implementing systematic measures to detect duplicate  expenses, FTA and FEMA are at risk of awarding funds for the same  expenses.

Given that FTA may not receive an appropriation until months after a  disaster, transit agencies will continue to submit applications to FEMA  when it is unclear whether Congress will provide funding to FTA. This  underscores the importance of FTA’s and FEMA’s coordination to avoid  providing duplicate funding. FTA and FEMA have taken important steps  to coordinate, including establishing an MOA and communications  protocol that outline how FTA and FEMA staff should share information.  Although FEMA and FTA both approved a relatively small amount of  funding for the same expenses in Collier County, the issues that  contributed to this outcome involve a risk of providing duplicate funding in  the future. FTA took steps to strengthen its processes after we identified  this duplicate funding, and FEMA conducted additional retroactive  reviews to identify any additional duplicate funding. However, FEMA will  continue to face challenges in identifying transit expenses when they are  included in the application of a larger entity such as a city, county, or state  government. Moreover, FTA may continue to be unaware when transit  entities are included in FEMA applications. FEMA and FTA have  committed to monitor, evaluate, and report the results of collaborative  efforts on an ongoing basis. Without identifying and addressing the  factors that contributed to duplicate funding in the federal response to the  2017 hurricanes, FTA and FEMA will continue to face the risk that both  agencies will approve funding for the same expense in the future.

We are making two recommendations, including one to DOT and one to  DHS.

The Secretary of Transportation should direct the Administrator of FTA to  identify and develop controls, such as methods to more easily identify  transit expenses within applications submitted by larger entities, such as  a city, county, or state government, to address the risk of duplicate  funding. (Recommendation 1)

The Secretary of Homeland Security should direct the Administrator of  FEMA to identify and develop controls, such as methods to more easily  identify transit expenses within applications submitted by larger entities  such as a city, county, or state government, to address the risk of  duplicate funding. (Recommendation 2)

We provided a draft of this report to DOT and DHS for review and  comment. We received written comments from DOT and DHS that are  reproduced in appendixes I and II. In comments, reproduced in appendix  I, DOT concurred with our recommendation. DOT described some of the  steps that FTA has taken to coordinate with FEMA, which we note in our  report, such as updating its procedures to ensure that an FTA grant does  not contain any expenses for which the applicant may have previously  requested reimbursement. We continue to believe FTA would benefit from  identifying additional internal controls to address the risk of duplicate  funding, particularly since FTA and FEMA may still face challenges  identifying entities that have applied to both agencies for funding.

In comments, reproduced in appendix II, DHS concurred with our  recommendation. DHS stated that FEMA is enhancing its Public  Assistance Grants Manager System to address the risk of duplicate  funding we identified in our report. This includes implementing a new  functionality for data exporting, sorting, and filtering to better identify  transit-related damages and improved tracking to identify projects that  have received FTA funding. DHS estimates these improvements will be  completed September 30, 2020.

DOT and DHS both provided technical comments, which we incorporated  as appropriate.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of the Department of Transportation, the  Secretary of the Department of Homeland Security, the Administrator of  FTA, the Administrator of FEMA, and other interested parties. In addition,  the report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or flemings@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix III.

Appendix I: Comments from the Department of Transportation

Appendix II: Comments from the Department of Homeland Security

Appendix III: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Steve Cohen (Assistant Director);  Crystal Huggins (Analyst in Charge); Matt Cook; Christopher Currie;  Danielle Ellingston; Susan Irving; Kathryn Godfrey; Janet McKelvey;  Cheryl Peterson; Brenda Rabinowitz; Malika Rice; Amy Rosewarne;  Rebecca Shea; Joe Thompson; Matthew Valenta; and Elizabeth Wood  made key contributions to this report.

The 2017 hurricanes—Harvey, Irma, and Maria—caused hundreds of millions of dollars in damages to public transit facilities in Texas, Florida, the U.S. Virgin Islands, and Puerto Rico. In response, the Federal Transit Administration said it would provide $233 million in relief to 52 local transit agencies.

Transit agencies can apply to FTA or the Federal Emergency Management Agency for funding after a disaster. These agencies coordinate their efforts but we found one case in which both agencies approved a small amount of funding for the same expenses.

We recommended ways both agencies can reduce the risk of duplicate funding.