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Recommendations
The absence of any evidence that E-Rate improves outcomes, the potential downsides of device-based learning, and the disruptive effects of generative AI together reinforce the importance of reevaluating the E-Rate program. The program was built for an era in which the return on connectivity was presumed positive. Policymakers focused on getting connections to schools and libraries, without considering how those connections were used. That presumption cannot travel unmodified into an era in which most students have high-speed Internet access at home, screen time can adversely affect adolescent mental health and academic performance, and the marginal use of a subsidized connection may be an AI-generated essay rather than a research database.
The current proceeding offers an opportunity to move from presumption to proof. Both the program and the recipients that it supports should embrace a culture of assessment that justifies subsidy requests based on need and expected gains and then measures and evaluates the results as a condition of renewed funding. This feedback would reveal best practices for the use of E-Rate funds, eliminate those projects likely to harm student learning, and lead to a more comprehensive understanding of the pros and cons of digital education. Specific recommendations follow.
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Conclusion
In 2018, Congress passed the Foundations for Evidence-Based Policymaking Act. This bipartisan legislation requires federal agencies to build evidence generation into their operations, rather than treating program evaluation as optional or ad hoc. While the Act formally binds only executive branch agencies, guidance issued by the Office of Management and Budget encourages independent agencies such as the FCC to adopt the same practices and measure the effectiveness of programs within their charge. There is little reason why an agency trusted with billions of ratepayer dollars annually should ask less of itself than Congress asked of the Cabinet departments.
For almost thirty years, the Commission has failed to undertake this analysis for E-Rate and other universal service programs. As a result, we simply do not know whether the billions spent annually on classroom and library connectivity are in fact helping students learn. And in the current environment, the cost of not knowing is high, as the Anxious Generation continues to exhibit the strains of a digital lifestyle, and AI threatens a Schumpeterian disruption of the educational model.
The current rulemaking proceeding reflects the first time the Commission has confronted this reality. Nothing in this record requires the Commission to abandon E-Rate, or to accept it unexamined. It requires only that the Commission finally ask the question Congress and the GAO have posed for decades and commit to answering it with evidence rather than assumption. After thirty years of funding E-Rate on faith, the next chapter should be grounded in proof.
* Daniel A. Lyons, a Professor at Boston College Law School, is a Member of the Free State Foundation's Board of Academic Advisors. The Free State Foundation is an independent, nonpartisan free market-oriented think tank located in Potomac, Maryland. The views expressed in this Perspectives do not necessarily reflect the views of others on the staff of the Free State Foundation or those affiliated with it.
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