Letter to the Federal Communications Commission

From: Chase Martin, Chairman, American Resolve
To: Federal Communications Commission
RE: WC Docket Nos. 26-133, 13-184, 21-93, 21-455; FCC to Review E-Rate Program to Ensure Congress’s Vision

Comment in Support of Proposed Rule

American Resolve Institute (ARI) is committed to a future grounded in the values on which our nation was founded. We advance these ideals through research, education, and thoughtful dialogue, working alongside leaders across the country who believe America thrives when it rewards opportunity, fosters innovation, and protects freedom.

We write in support of this proposed rule and urge the FCC to adopt it with extensive reforms to the E-Rate program. The 30-year-old E-Rate program was originally designed to bring internet access to rural and poor schools at a time when students’ online activities were limited to the occasional use of a dedicated computer lab or library for typing or research skills. Since then, remote internet access has expanded massively and so has the number of hours per day students spend staring at screens, to their detriment. The program has also become rife with fraud and abuse. It is time to reduce schools’ reliance on this flawed program.

Chairman Carr, in his statement accompanying this proposal, rightly raises concerns about screen time, noting that from 2019 to 2024 alone, the share of eighth graders reporting screen usage in all or most classes increased from 30 to 50 percent. More than 80 percent use screens in at least half of their classes. The chairman points to a corresponding decline in academic achievement among students in brick-and-mortar public schools. These are concerning trends that should make us reconsider subsidizing a failing model for classroom instruction.

Furthermore, when schools are reimbursed for up to 90 percent of the cost of internet services, they have a disincentive to select the services that are most cost-effective and limited to their actual needs. The subsidy serves as a tool to pad their budgets elsewhere, including the increasingly large share of school administrative spending that does not find its way into the classroom. From 2002 to 2020, school revenues from all sources increased by 25 percent after adjusting for inflation, while student enrollment grew just 6.6 percent and teacher salaries stayed flat.¹ Staffing growth doubled student enrollment growth, and a strong majority of new hires were non-teachers.² This funding growth showed no consistent relationship with academic outcomes.³ Public school enrollment has declined since Covid and is projected to continue declining through 2031.⁴ In short, American schools do not have a revenue problem.

Heavily funded and complicated government sectors like education attract fraudsters. The E-Rate program, with billions in funding and complex reimbursement arrangements involving not only internet subscriptions but consultants, bidding processes, equipment, and infrastructure, has become a magnet for abuse.

This year, under new regulatory authorities, the FCC barred more than a dozen people from doing business with the Commission after their convictions for bribing and overbilling school systems to steer E-Rate revenue to themselves. The schemes cost schools and ratepayers millions: $3.2 million in withheld reimbursements in Ohio and $6 million from forged documents in Tennessee, for example.⁵ In just one conspiracy in New York, seven fraudsters were convicted and sentenced in 2023 for defrauding $14 million from the program.⁶ The FCC in May launched an investigation into E-Rate abuse in the now-familiar fraud haven of Minnesota.⁷

For the past two years, thanks to the Trump Administration and courageous citizen-journalists, the nation has been stunned by revelations of the longtime, rampant waste and fraudulent conversion of funds through federal programs. This rulemaking proposal, with its focus on program integrity, is further proof of the administration’s commitment to rectify those abuses.

Supporters of the status quo are quick to note that the E-Rate program is not paid for with federal tax dollars, but with private carrier fees. This is a meaningless distinction. E-Rate is not a corporate charity for schools. The American people pay for the E-Rate program through government-imposed fees added to each monthly cell phone bill they receive. Limiting the program would support President Trump’s affordability agenda by directly reducing consumers’ bills.

For these reasons, ARI strongly encourages the FCC to proceed with implementing a rule that improves program integrity and reduces destructive excess screen time for students in brick-and-mortar schools. The FCC has the authority to prevent the E-Rate program from continuing to pad bloated school budgets and invite fraud. Limiting the program’s scope would provide American ratepayers with much-needed financial relief while delivering more effective and efficient education for American students.

Respectfully submitted,

Chase Martin

Footnotes:

1. Reason Foundation, “Public education at a crossroads: A comprehensive look at K-12 resources and outcomes,” February 29, 2024, https://reason.org/k12-ed-spending/crossroads-report/.
2. Ibid.
3. Ibid.
4. National Center for Education Statistics, “Public School Enrollment,” May 2024, https://nces.ed.gov/programs/coe/indicator/cga/public-school-enrollment.
5. FCC, “FCC Bans Seven Convicted Criminals from E-Rate Program,” Press Release, September 3, 2026, https://docs.fcc.gov/public/attachments/DOC-424713A1.pdf.
6. FCC, “FCC Bans Seven Convicted E-Rate Fraudsters from USF Programs,” Press Release, March 20, 2026, https://docs.fcc.gov/public/attachments/DOC-419986A1.pdf.
7. Office of Chairman Brendan Carr, “FCC Investigating Potential Fraud in E-Rate Program in Minnesota,” Press Release, May 15, 2026, https://www.fcc.gov/document/fcc-investigating-potential-fraud-e-rate-program-minnesota.