Tribal Broadband: FCC Should Undertake Efforts to Better Promote Tribal Access to Spectrum

In 2018, FCC estimated that 35 percent of Americans living on tribal lands lack broadband service compared to 8 percent of Americans overall. Broadband service can be delivered through wireless technologies using radio frequency spectrum. According to FCC, increasing tribal access to spectrum would help expand broadband service on tribal lands. GAO was asked to review spectrum use by tribal entities—tribal governments and tribally owned telecommunications providers.

This report examines (1) tribal entities' ability to obtain and access spectrum to provide broadband services and the reported barriers that may exist, and (2) the extent to which FCC promotes and supports tribal efforts to obtain and access spectrum. GAO interviewed 16 tribal entities that were using wireless technologies. Selected entities varied geographically, among other characteristics. GAO analyzed FCC's license and auction data as of September 2018, reviewed FCC's rulemakings on spectrum for broadband services, and interviewed other tribal and industry stakeholders and FCC officials. The information presented is not generalizable to all tribes or industry participants.

The tribal entities GAO contacted cited various barriers to obtaining spectrum licenses in bands that can be used to provide broadband services. According to its analysis of data from the Federal Communications Commission (FCC), GAO identified 18 tribal entities that held active spectrum licenses in such bands. For example, of these 18 tribal entities, 4 obtained licenses through secondary market transactions—that is, they bought or leased the license from another provider, and 2 obtained a license through an FCC spectrum auction. Licensed spectrum is generally preferred because it offers better quality of service compared to unlicensed spectrum; however, almost all of the tribal entities GAO contacted said that they are accessing unlicensed spectrum to provide Internet service. They identified barriers to obtaining licensed spectrum through auctions and secondary market transactions, barriers such as high costs and, in the case of secondary market transactions, a lack of information on who holds licenses over tribal lands. Because most spectrum allocated for commercial use has already been assigned, the secondary market is one of very few avenues available to tribal entities that would like to access licensed spectrum.

FCC has taken steps to promote and support tribal access to spectrum. For example, FCC issued proposed rulemakings in 2011 and 2018 that sought comment on tribal-specific proposals, such as establishing tribal-licensing priorities and initiating processes to transfer unused spectrum licenses to tribal entities. However, FCC has not finalized these rules and is in the process of responding to comments to the 2018 rulemaking. Also, while FCC has made additional spectrum available for broadband use in recent years, tribal stakeholders cited limitations with the spectrum FCC has made available. For example, FCC allows broadband providers to operate in unused television broadcast bands on an unlicensed basis. While stakeholders GAO interviewed cited some advantages of these bands, such as being useful to reach remote customers, they also noted technical and cost limitations that reduced the potential to improve tribal access to spectrum. FCC stated that it is implementing spectrum initiatives and recognizes the importance of promoting a robust secondary market to improve communications throughout the United States, including tribal lands. However, GAO found that FCC has not collected data related to tribal access to spectrum, analyzed unused licensed spectrum that exists over tribal lands, or made data available to tribal entities in an accessible and easy manner that could be beneficial in their efforts to obtain spectrum licenses from other providers. By collecting data on the extent that tribal entities are obtaining and accessing spectrum, FCC could better understand tribal spectrum issues and use this information as it implements ongoing spectrum initiatives. Further, given that the secondary market is one of few ways for tribal entities to access licensed spectrum to be able to provide Internet service, FCC could promote a more robust secondary market by analyzing unused licensed spectrum over tribal lands and using that information to inform FCC's oversight of the secondary market. Additionally, by making information available on who holds spectrum licenses over tribal lands, FCC could remove a barrier tribes may face in attempting to obtain spectrum through the secondary market.

FCC should (1) collect data on tribal access to spectrum; (2) analyze unused licensed spectrum over tribal lands; and (3) make information available in a more accessible manner that would promote tribes' ability to purchase or lease spectrum licenses over their lands from other providers. FCC agreed with the recommendations.

Broadband service is viewed as vital to economic growth and improved  quality of life across the country. In 2018, the Federal Communications  Commission (FCC) reported that an estimated 35 percent of Americans  living on tribal lands lack access to broadband services, compared to 8  percent of all Americans. Furthermore, the gap in broadband access  between rural areas and rural tribal lands is even larger. In particular,  FCC reported in 2018 that nearly 60 percent of Americans living on rural  tribal lands nationwide lack broadband access, compared to about 31  percent of rural Americans overall. We have previously reported that  tribal lands can have challenging terrain and low population densities that  increase the cost and reduce business incentives for high-speed Internet  deployment. According to FCC, this lack of service on tribal lands could  impede efforts by Indian tribes to achieve self-governance and promote  economic opportunity, education, public safety, and cultural preservation.  Broadband service can be delivered through wireless technologies using  radio frequency spectrum. According to FCC, wireless technologies are  cost-effective for some remote and sparsely populated areas compared to  wireline broadband technologies, such as buried fiber optic or copper  cables, which can be costly to install where there is challenging terrain.

According to FCC’s 2010 National Broadband Plan, some tribes have  successfully used wireless technologies to deliver Internet access, and  increasing tribal access to and use of spectrum would create additional  opportunities to expand broadband service on tribal lands. Congress has  delegated responsibility for regulating commercial and other nonfederal  spectrum use to FCC, and as part of its responsibilities, FCC assigns  spectrum licenses through auctions and other mechanisms; oversees  secondary market transactions, such as leasing a spectrum license; and  promulgates regulations for the use of licensed and unlicensed  spectrum. FCC has asserted that its authority to regulate nonfederal  spectrum use applies to the spectrum over tribal lands. In FCC’s 2000  policy statement on establishing its relationship with tribes, FCC stated  that it recognizes that the federal government has a fiduciary  responsibility in its dealings with tribes and has a longstanding policy of  promoting tribal self-sufficiency and economic development. As a result,  FCC has recognized its own general responsibility to tribes.

You asked us to review issues related to spectrum use by tribal entities— tribal governments and telecommunications providers owned by tribes.  This report examines (1) tribal entities’ ability to obtain and access  spectrum to provide broadband services on tribal lands and the reported  barriers that may exist, and (2) the extent to which FCC promotes and  supports tribal efforts to obtain and access spectrum for broadband  services.

To address these objectives, we reviewed relevant statutes and  regulations, FCC documents, including FCC’s Statement of Policy on  Establishing a Government-to-Government Relationship with Indian  Tribes, the National Broadband Plan, FCC’s current strategic plan,  and academic and government publications identified through a literature  search of spectrum-related issues on tribal lands.

To obtain information on tribal entities’ ability to obtain and access  spectrum, we identified tribal entities that have applied to participate in  FCC’s spectrum auctions or that have obtained spectrum licenses for  frequency bands that can be used for broadband services by analyzing  FCC data on (1) the participants in all relevant auctions, and (2) spectrum  license holders that were active as of September 6, 2018—the date that  FCC downloaded this data for our review. To identify tribal entities in  these data, we reviewed the list of federally recognized tribes and  identified search terms related to these tribes. We then identified partial  matches between the identified search terms and the FCC data on  auction applicants and license holders, and manually reviewed these  matches based on information from interviews, Internet research, and  professional judgment. Because tribal entities may have applied to  participate in a spectrum auction or may hold spectrum licenses under  names that did not include the search terms we identified based on the  names of federally recognized tribes, there may be additional tribal  entities that we did not include in our analysis. We also analyzed FCC’s  license data to determine how tribal entities obtained these licenses,  including through an FCC auction, administrative assignment, or a  secondary market transaction. To assess the reliability of FCC’s data, we  manually reviewed the data and interviewed FCC officials. Based on the  results of our analysis, we determined the data to be reliable for our  purpose to describe the extent that tribal entities have participated in  auctions and obtained spectrum licenses; however, our analysis does not  capture the extent that tribal entities may have obtained a license that is  no longer active. In addition, we obtained stakeholder views on the  barriers that tribal entities may face in obtaining spectrum licenses by  interviewing 24 tribal entities, 3 tribal associations, 7 private providers that  deliver Internet services over tribal lands, 3 industry associations that  represent rural and urban telecommunications providers, 3 regional  consortia, 3 companies that work with tribal entities, and 1 academic  group. Of the 24 tribal entities we selected to interview, 16 were using  wireless technologies to provide Internet service. We selected tribal  entities to have variation in geographic location, level of broadband  deployment, population size and density, and urban or rural distinction.  We selected other stakeholders to represent a range of views and those  with experience working with Indian tribes and broadband service. The  views presented in our report are not generalizable to those of all  stakeholders.

To determine the extent that FCC promotes and supports tribal entities’  efforts to obtain and access spectrum, we reviewed relevant FCC  rulemaking proceedings. We summarized stakeholder perspectives on  these rulemakings by interviewing the tribal entities, tribal associations,  regional consortia, industry associations, and private providers noted  above, and by reviewing public comments submitted by private providers,  industry and tribal associations, and tribal governments and providers.

We identified FCC’s efforts to provide tribal entities with spectrum-related  assistance and communications by interviewing FCC officials and  reviewing documentation, such as presentations provided at FCC-led  tribal training workshops, e-mail communications with tribal entities, and  public notices related to spectrum use over tribal lands. We also  interviewed FCC officials on the information that they collect, analyze,  and report related to tribal use of spectrum and reviewed related  documentation, including the FCC Office of Native Affairs and Policy’s  2012 Annual Report and FCC’s license and auction data. We compared  FCC’s efforts to increase tribal entities’ abilities to obtain and access  spectrum against recommendations made in FCC’s National Broadband  Plan, FCC’s current strategic plan, and Standards for Internal Control  in the Federal Government related to using quality information.  Appendix I describes our scope and methodology in greater detail.

We conducted this performance audit from November 2017 to November  2018 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.

The federal government has recognized 573 Indian tribes as distinct,  independent political communities with certain powers of sovereignty and  self-government, including some power to manage the use of their  territory and resources and control economic activity within their  jurisdiction. Some tribal lands include reservations—land set aside by  treaty or other agreement with the United States, executive order, or  federal statute or administrative action for the residence or use of an Indian tribe. Some tribal lands include parcels with different ownership;  for example, parcels may be held in trust by the federal government for  the benefit of a tribe or an individual tribal citizen. Trust and restricted  lands can affect a tribe’s ability to use their land as collateral to obtain a  loan. Tribal lands vary in size, demographics, and location. For example,  the smallest in size are less than one square mile, and the largest, the  Navajo Nation, is more than 24,000 square miles (the size of West  Virginia). Tribal land locations can range from extremely remote, rural  locations to urban areas. Indian tribes may form governments and  subsidiaries to help manage tribal affairs including schools, housing,  health, and economic enterprises.

Internet access in the United States is generally privately financed.  Broadband providers build infrastructure and sell broadband services to  individual consumers. We previously reported that tribal lands can have  conditions that increase the cost of broadband deployment, such as  remote areas with challenging terrain, which increases construction costs,  as well as relatively low population densities and incomes that make it  difficult to recoup deployment costs. These conditions may make it less  likely that a service provider will build or maintain a network. Some tribal  governments provide Internet access to their members, through an  information-technology or utility department, and others have created  their own telecommunications companies to provide services. FCC has  reported that in many instances, tribal governments must build and pay  for their own communications infrastructure to ensure Internet access will  be “delivered across Indian Country.”

The term “broadband” commonly refers to Internet access that is high  speed and provides an “always-on” connection, so users do not have to  reestablish a connection each time they access the Internet.  Telecommunications providers use a range of technologies to provide  broadband service, including cable, fiber, satellite, and wireless. Wireless  broadband connects users to the Internet using spectrum to transmit data  between the customer’s location and the service provider’s facility, and  can be transmitted using fixed wireless and mobile technologies, as  shown in figure 1.

Fixed wireless broadband technologies establish an Internet connection  between fixed points, such as from a radio or antenna that may be  mounted on a tower, to a stationary wireless device located at a home.  This technology generally requires a direct line of sight, and can be  delivered two ways: (1) as a point-to-point transmission—between two  fixed points—or (2) as a point-to-multipoint transmission—from one point  to multiple users. Mobile wireless broadband technologies also establish  a connection to the Internet that requires the installation of antennas, but  this technology provides connectivity to customers wherever they are  covered by service, including while on the move, such as with a cell  phone.

Spectrum is the resource that makes wireless broadband connections  possible. Spectrum frequency bands each have different characteristics  that result in different levels of ability to cover distances, penetrate  physical objects, and carry large amounts of information. For example,  lower frequency bands are able to transmit signals that travel greater  distances, thus requiring the use of fewer antennas, and are able to  penetrate solid objects. Higher frequency bands are able to transmit more  data, but are more easily obstructed.

FCC administers spectrum for nonfederal users—such as state, local  government, and commercial entities—through a system of frequency  allocation and assignment. Allocation involves segmenting the radio  spectrum into bands of frequencies designated for use by particular types  of radio services or classes of users, such as commercial and nonfederal  broadband services. Examples of some of the frequency bands that can  be used by commercial and nonfederal entities for broadband services  are shown in figure 2. Appendix II presents a full list of the auctioned  licensed frequency bands that FCC told us could be used to provide  broadband services.

The frequency bands that can be used for broadband services are either  licensed or unlicensed. For licensed spectrum, FCC can assign licenses  through auctions, in which prospective users bid for the exclusive rights to  transmit on a specific frequency band within geographic areas, ensuring  that interference does not occur. License holders may sell or lease their  license, in whole or in part, to another provider, a process that is known  as a secondary market transaction, with FCC’s approval. FCC requires  license holders to meet specified buildout requirements within a specified  amount of time or face penalties, typically termination of all or part of the  license. These buildout requirements are designed to ensure that  licensees put spectrum to use within a specific period rather than let it sit  idle and vary based on the type of license.

FCC has also assigned licenses administratively in two frequency bands  that can be used for broadband services. Specifically, prior to 1996 FCC  assigned geographic licenses for exclusive use in the Educational  Broadband Service (2496-2690 megahertz (MHz)), and from 2005 to  2015, FCC assigned non-exclusive nationwide licenses in the 3650-3700  MHz band, where use of the band may be shared by other license  holders. FCC also authorizes the use of some spectrum for broadband  services without a license on a non-exclusive basis. With unlicensed  spectrum, an unlimited number of users can share frequencies using  wireless equipment certified by FCC, such as wireless microphones, baby  monitors, and garage door openers. In contrast to users of licensed  spectrum, unlicensed users have no regulatory protection from  interference by other licensed or unlicensed users in the bands. If  multiple users are operating simultaneously on the same frequency band,  the transmissions may be susceptible to interference, which reduces the  quality of service.

FCC’s rulemaking process includes multiple steps as outlined by law with  opportunities for the public to participate during each step. In general,  FCC initiates a rulemaking in response to statutes, petitions for  rulemaking, or its own initiative, and releases a Notice of Proposed  Rulemaking (NPRM) to propose new rules or to change existing rules.  Any interested person may submit comments as part of the public record  through electronic filings and meetings with FCC officials. Following  internal analysis of the public record, FCC staff may propose actions for  consideration for a vote, such as adopting final rules, amending existing  rules, or stating that there will be no changes. All of FCC’s sitting  commissioners vote on these items.

The American Recovery and Reinvestment Act of 2009 directed FCC to  develop a plan to ensure every American had access to high-speed  Internet. In March 2010, an FCC task force issued the National  Broadband Plan that included a centralized vision for achieving  affordability and maximizing use of high-speed Internet. The plan made  many recommendations to FCC, including that FCC should take into  account the unique spectrum needs of tribal communities when  implementing spectrum policies and evaluate its policies and rules to  address obstacles to spectrum access by tribal communities. With regard  to tribal lands, the plan recommended that FCC increase its commitment  to government-to-government consultation with tribal leaders and  consider increasing tribal representation in telecommunications planning.  FCC established the Office of Native Affairs and Policy (ONAP) in July  2010 to promote the deployment and adoption of communication services  and technologies to all native communities, by, among other things,  ensuring consultation with tribal governments pursuant to FCC policy.

Selected Tribal Entities Reported Barriers to Obtaining Licensed Spectrum

Few Tribal Entities Have Obtained Spectrum Licenses, Although Representatives from Selected Tribal Entities Emphasized the Importance of Licensed Spectrum

Through our analysis of FCC license data as of September 2018, we  identified 18 tribal entities that held active spectrum licenses in bands that  can be used to provide broadband services. Because tribal entities may  hold licenses using entity names that do not include the search terms we  identified in our review of the list of tribes in the Federal Register, there  may be additional tribal entities that we have not identified. We found that  most of the tribal entities obtained the licenses through FCC  administrative assignment rather than through an FCC spectrum auction  or secondary market transaction.

Thirteen of the tribal entities we identified in FCC’s license data held  administratively assigned licenses, and these licenses are subject to  certain limitations and were only available to applicants for limited time  periods. Eleven of these administratively assigned licenses are non- exclusive nationwide licenses in the 3.65 GHz frequency band (3550- 3700 MHz) and were available between 2005 and 2015, when FCC  issued a new rule for this band and stopped accepting new applications  for these licenses. Two of the tribal entities we identified held  administratively assigned Educational Broadband Service licenses in the  2.5 GHz frequency band (2496-2690 MHz). These licenses allow for the  transmission of educational materials by accredited educational  institutions and government organizations, including tribes, engaged in  formal education and require that licensees use the spectrum for  educational purposes for a certain amount of time each week. Both of  these tribal entities obtained these licenses after the last filing window  closed in 1996 through a waiver and special temporary authority permit.

Four tribal entities we identified in FCC’s license data held a total of 13  active licenses obtained through secondary market transactions, such as  leases and sales of portions of partitioned licenses. Of these 13  secondary market transactions, 2 involved nationwide providers.

Two of the tribal entities we identified held active licenses in bands  available for broadband deployment that they obtained through an FCC  spectrum auction. One of these tribal entities won with a winning bid of  over $800,000 in a 2015 auction, and the other won two licenses with  winning bids of under $50,000 in a 2002 auction. This second tribal entity  also qualified for but did not win a 2003 auction. In addition to these two  tribal entities, we identified the following four tribal entities that had  applied to participate in auctions with varying results but did not hold  active licenses in frequency bands available for broadband deployment  as of September 2018:

Two tribal entities each won a single spectrum license. The first won  its license, which has since expired, in 2000, and the second won its  license, which it has since been transferred to a nationwide provider  through a secondary market transaction, in 2003. The first tribal entity  also applied but did not qualify to participate in a 2001 auction.

One tribal entity qualified to participate but did not win in a 2003  auction, and another tribal entity applied but did not qualify to  participate in a 2008 auction.

In addition, representatives from 2 of the 16 tribal entities we interviewed  that were using wireless technologies told us that they use licensed  spectrum that is owned by a private provider through a partnership  relationship. We have previously reported that some tribes have formed  partnership arrangements with other entities to increase broadband  access on tribal lands.

Most (14 of 16) of the tribal entities we contacted that were using wireless  technologies told us that they are accessing various unlicensed bands,  such as the 2.4 GHz and 5 GHz bands, to provide service.  Representatives from eight of these tribal entities reported using only  unlicensed spectrum for their fixed wireless networks. Representatives  from 13 tribal entities told us that unlicensed spectrum had the advantage  of being free, and representatives from one tribal entity told us that the  equipment needed to access these spectrum bands is less expensive  than equipment for accessing other spectrum bands. Representatives  from some tribal entities reported success in using unlicensed spectrum  in certain circumstances. For example, one tribal entity reported using  unlicensed spectrum for homes in remote areas where the only potential  signal degradation is from trees as well as to set up local hot spots that  can serve 5 to 10 users at a time. Another tribal entity reported using  primarily unlicensed spectrum to carry signals to end users together with  non-exclusive licensed spectrum (3.65 GHz band) for locations where  there is congestion in the unlicensed bands.

However, representatives from the tribal entities we contacted that were  using wireless technologies emphasized the advantages of licensed  spectrum and discussed their experiences with the limitations of  unlicensed spectrum. As described earlier, exclusive-use spectrum  licenses protect license holders from interference from other users,  whereas unlicensed spectrum provides no protection against interference.  Representatives from 13 of 16 tribal entities identified the fact that  unlicensed spectrum is available at no cost as an advantage of this type  of spectrum. However, representatives from 15 of the 16 tribal entities  identified limitations associated with unlicensed spectrum, such as  interference, as described in table 1.

Tribal associations, an academic group, a tribal consortium, and FCC  have all highlighted the importance of exclusive-use licensed spectrum for  tribal entities. Specifically, both a tribal association and an academic  group we contacted discussed interference and other challenges of  unlicensed spectrum. Representatives from one tribal association pointed  out that unlicensed spectrum might not be available in the future if it is  allocated for other purposes. Representatives from a tribal consortium we  contacted told us that they are already using all of the available  unlicensed spectrum for providing Internet access and that they cannot  expand service without encountering interference and capacity limitations.  Lastly, ONAP reported in 2012 that unlicensed spectrum is not an option  across all tribal lands and that tribal access to robust licensed spectrum is  a critical need.

Representatives from the stakeholders we interviewed told us that there  are also non-technological benefits for tribal entities to obtain greater  access to licensed spectrum. For example:

Enhanced ability to deliver additional Internet service.

Representatives from one of the tribal associations, an academic  group, and six of the tribal entities said that increased access to  licensed spectrum would enable them to deliver their own Internet  services and bridge service gaps, thus improving Internet access to  their members. For example, representatives from three of these tribal  entities said that such access would enable them to deploy in areas  where providers that currently hold licenses were not willing to deliver  services. In addition, representatives from another tribal entity said  that having access to licensed spectrum is one factor that would  enable the tribe to establish its own telecommunications company.

Ability to sell or lease spectrum for profit. Representatives from  one tribal association, an academic group, and two tribal entities told  us that holding spectrum licenses would enable tribal governments to  sell or lease their licenses. For example, we heard from one of these  tribal entities that it was able to sell portions of its license that did not  cover tribal lands and to use the profits from the sale to invest in its  own network infrastructure.

Opportunities for federal funding. Access to licensed spectrum may  also provide tribal entities with more opportunity to obtain federal  funding, specifically through two Universal Service Fund programs— the Mobility Fund and the Tribal Mobility Fund. These programs  provide funding to broadband service providers to expand service in  areas where it is not available, including tribal lands. However, service  providers must hold, lease, or show they have access to licensed  spectrum to participate in these programs, among other  requirements. For example, the National Congress of American  Indians stated that two tribal entities submitted applications to  participate in the Mobility Fund program but were not eligible to  participate in part because they did not hold a spectrum license.  Moreover, representatives from two of the tribal entities we  interviewed told us that they considered applying for one of these  programs but realized they were ineligible because they did not have  access to licensed spectrum.

Furthermore, representatives from one of the tribal associations, an  academic group, and seven of the tribal entities told us that having  access to licensed spectrum would enable tribes to exercise their rights to  sovereignty and self-determination. Representatives from three of the  tribal entities we contacted said that they view spectrum as a natural  resource that should be managed by the tribe. FCC officials, however,  told us that spectrum is not considered a reserved right under treaties  with Indian tribes, as it is not explicitly stated. In addition, representatives  from four of the tribal entities told us that having access to licensed  spectrum would ensure that spectrum is being used in a way that aligns  with tribal goals and community needs, further supporting their rights to  self-determination.

Representatives from Selected Tribal Entities Reported Cost and Other Barriers to Accessing Licensed Spectrum

Representatives from the tribal entities we contacted identified several  barriers to accessing licensed spectrum through spectrum auctions and  secondary market transactions. Regarding spectrum auctions,  representatives from tribal entities that provide wireless Internet service  most frequently (13 of 16) indicated that spectrum licenses are too  expensive for tribal entities. For example, over 60 percent (983 of 1,611)  of the winning bids from a 2015 spectrum auction, including bids for  spectrum over non-tribal lands, were over $1 million. Representatives  from one tribal entity explained that auction licenses are often too  expensive for tribal entities because these licenses cover large  geographic areas that may include non-tribal urban areas as well as rural  tribal areas. Moreover, representatives from eight tribal entities stated that  they are unable to obtain financing to participate in auctions because  tribal governments cannot use tribal lands as collateral to obtain loans. In  addition, representatives from eight tribal entities mentioned that  participating in spectrum auctions requires auction-specific expertise that  tribal entities may not have.

Tribal entities also face barriers obtaining spectrum through secondary  market transactions. Most of the spectrum allocated for commercial use  has already been assigned through spectrum auctions and other  mechanisms to private providers, including licensees that may not be  providing service on tribal lands. In a single geographic area, several frequency bands could be used to deploy broadband services, as shown  in figure 2, and licenses for these various frequency bands may be held  by different providers. There may be tribal areas where providers hold  licenses for bands but are not using the spectrum to provide Internet  access. In other tribal areas, services may be offered using one or two of  the spectrum licenses with the other licenses in the area remaining fallow  and inaccessible to tribal entities. All three of the tribal associations we  contacted confirmed that there are unused spectrum licenses over tribal  lands, and representatives from a nationwide provider indicated that they  only deploy services if there is a business case to support doing so.  Accordingly, the secondary market is one of few avenues available to  tribal entities that would like to access licensed spectrum. However,  representatives from tribal entities we contacted identified the following  challenges related to participating in the secondary market:

Lack of willing sellers. Representatives from eight of the tribal  entities, one of the tribal representative groups, and an industry  association we contacted indicated that spectrum license holders are  often unwilling to participate in secondary market transactions, citing a  variety of reasons. For example, representatives from one tribal entity  stated that large carriers have no business incentive to negotiate  secondary market agreements with tribal entities and that tribal  entities do not have the resources to make such transactions  sufficiently lucrative for license holders. Representatives from another  tribal entity stated that license holders may lack knowledge about the  areas covered by their licenses, including tribal areas, and therefore  may be unwilling to consider secondary market transactions.  Representatives from a tribal representative group told us that license  holders may be unwilling to consider secondary market transactions  with tribal entities because spectrum is a valuable resource that may  become even more valuable over time, and a representative from an  industry association indicated that transaction costs such as legal fees  outweigh any potential income from such transactions. None of the  private providers we contacted reported entering into a secondary  market transaction with tribal entities, but one of these providers  stated that it had never been approached by a tribal entity interested  in a secondary market transaction and was unaware of challenges  that are unique to tribal entities.

License holders unknown. Representatives from eight of the tribal  entities we contacted stated that it is difficult to determine who holds  spectrum licenses. For example, two tribal entities had to hire  consultants to identify who held licenses for spectrum over the tribes’  lands, and another tribal entity relied on the expertise of its non-tribal  partner to identify the license holders.

Unaware of secondary market transactions. Representatives from  six of the tribal entities we contacted were unaware of the possibility  of accessing licensed spectrum through a secondary market  transaction prior to our contacting them.

Accordingly, secondary market transactions involving tribal entities are  rare. As discussed above, our analysis of FCC license data identified four  tribal entities that have successfully accessed licensed spectrum in this  manner. Regarding one of these tribal entities’ experiences with the  secondary market, the tribal representative we contacted stated that an  Indian-owned telecommunications consulting company was pivotal in  identifying the license holder and facilitating the transaction and that the  transaction would not have happened without the consulting company.  Representatives from this company told us that they conducted an  analysis to identify unused spectrum licenses over the tribe’s land. The  company identified three providers holding such licenses, but only one of  those providers was willing to participate in a secondary market  transaction. Representatives from another of the tribal entities that  accessed licensed spectrum through the secondary market told us that  they relied on the expertise of their non-tribal partner to facilitate these  transactions.

FCC Has Some Efforts to Enhance Tribal Access to Spectrum, but FCC Does Not Collect or Communicate Key Information to Tribal Entities

FCC Has Taken Steps to Promote and Support Tribal Entities’ Ability to Obtain Spectrum, However These Efforts Are Not Likely to Address Tribal Spectrum Needs

We found that FCC has taken the following actions to increase tribal  access to and use of spectrum: (1) initiated proposed rulemakings on  promoting tribal access to spectrum, (2) adopted rules to increase  spectrum available for broadband use, and (3) conducted outreach and  training for tribal entities on spectrum-related issues.

Initiated Proposed Rulemakings on Promoting Tribal Access to Spectrum

FCC issued two NPRMs—one in March 2011 and one in May 2018—that  included policy options intended to enhance tribal access to spectrum. At  the time of our report, FCC had not adopted new rules or taken further  action on the 2011 rulemaking, and FCC had not taken further actions  since the comments period ended on September 7, 2018, on the May  2018 rulemaking. According to FCC officials, the 2011 NPRM  addressed several recommendations made in the National Broadband  Plan to promote the greater use of spectrum over tribal lands. Among  other things, the 2011 NPRM sought comments on three proposals to  create new spectrum access opportunities for tribal entities (see fig. 3).  FCC officials told us that they have reviewed public comments to the  proposed rulemaking, but have no current plans to take further actions.

We reviewed the public comments FCC received that pertained to the  three proposals, which included comments from tribal associations, tribal  governments, rural and nationwide industry associations, and tribal and  private providers. Based on our analysis of the comments that included  positions on the proposal for a tribal licensing priority, eight  stakeholders—including industry associations, private providers, and a  tribal government—were supportive of this proposal. However, we found  that stakeholder views differed on implementing good faith negotiations and on the build-or-divest processes. In general, the tribal stakeholders  indicated that they were supportive of these proposals, while the industry  associations and private providers were not. In addition to reviewing the  public comments, we asked representatives from the tribal and industry  associations and private providers that we interviewed about their views  of these proposals. Representatives from the three tribal associations  and two rural industry associations were generally supportive of all three  of the proposals, while representatives from one of the private providers  that we interviewed told us they did not support any of the three  proposals, because, for example, they said that there are more effective  ways to increase broadband service over tribal lands. Representatives  from another private provider said that they supported the tribal priority  process but did not indicate their views on the other two proposals.  Representatives from six tribal entities and a representative from a tribal  consortium told us that these types of proposals would help them obtain  spectrum.

In May 2018, FCC issued an NPRM that sought comments on  establishing a tribal priority window for tribal nations located in rural areas  as part of a process to re-license the Educational Broadband Service  spectrum band. As described above, FCC originally allocated this band  to qualifying educational institutions and government organizations for the  transmission of educational materials. While FCC permitted licensees to  lease their excess capacity to commercial providers, FCC reported that  significant portions of this band were not being used, primarily in rural  areas. In an effort to make additional spectrum available for broadband  use, FCC issued this NPRM seeking comments on options to promote the  use of this spectrum over tribal lands. One of the options included  implementing a local priority filing window so that tribal entities could get  access to unassigned spectrum prior to an FCC auction. In a June 2018  order, FCC extended the comment deadline for the NPRM to August 8,  2018, partly in response to a request for a deadline extension. As a result,  FCC also extended the deadline to respond to those comments to  September 7, 2018. Because FCC was in the process of responding to  these comments at the time of our review, we did not analyze these  comments.

Adopted Rules to Allocate Additional Spectrum for Broadband Use

FCC has made additional unlicensed and licensed spectrum available for  broadband use and has implemented rules that according to FCC, may  make it easier for rural providers to obtain licenses. However, these  efforts were not targeted to tribal entities, and according to ONAP’s 2012  report, allocating additional unlicensed spectrum may not be a technically  feasible solution for all tribal entities, and such spectrum may not have  the necessary capacity to handle an increase in users. In addition,  representatives from the tribal associations and entities we contacted told  us that there are limitations to the extent that these efforts can address  the spectrum needs of tribal entities. In particular, they discussed the  effect of FCC’s changes to the rules on the use of TV white space  spectrum and the Citizens Broadband Radio Service spectrum:

TV white space spectrum: In 2010, FCC made additional unlicensed  spectrum available for broadband use by allowing providers to  operate in the TV bands at locations where those frequencies were  not in use, known as TV white space, but none of the tribal entities  we interviewed was using this spectrum. A representative from a tribal  consortium said that it used TV white space spectrum, and  representatives from three of the tribal entities said that they were  considering using it in the future because TV white space spectrum  can better pass through some environmental barriers, such as trees,  reaching more remote customers. However, representatives from five  tribal entities, one tribal consortium, one academic group, and three  companies that we interviewed told us about several limitations to the  use of TV white space spectrum. For example:  limited bandwidth capacity, which causes lower speeds, high  latency, and limits the number of households that can be served; equipment needed to access TV whitespace spectrum is  expensive and less available;  the spectrum may not always be available; and  similar to other unlicensed frequency bands, as described above,  there is potential for interference and difficulty to pass through  extreme terrain.

Citizens Broadband Radio Service (CBRS) Spectrum: In 2015, FCC  made additional licensed spectrum available for broadband use when  it issued a new rule for the 3.65 GHz frequency band (3550-3700  MHz). However the tribal entities who held licenses in this band  indicated there are limitations to their ability to use this band and their  future use of this spectrum remains unknown. As described earlier,  FCC had allocated non-exclusive nationwide licenses in this band. In  the 2015 rule, FCC created the CBRS, increased the amount of  spectrum allocated for commercial broadband use, and implemented  a new licensing scheme. This three-tier priority licensing scheme for  spectrum sharing included auctioning exclusive-use geographic  licenses and allowing non-exclusive use of the band where a license  holder is not operating, an approach that is intended to provide a low- cost entry point for users, but will have no protections from  interference. Representatives from four of the five tribal entities that  we contacted that held licenses in this band said that there were  technical advantages to using it, such as the ability for a signal to  pass through dense forests. However, representatives from two tribal  entities said that the high cost of the equipment needed to access this  spectrum prevented them from either using the frequency band  extensively or at all. In addition, representatives from two tribal entities  said that they were not sure about their ability to access this band in  the future given the changes made in FCC’s 2015 rulemaking.  FCC’s 2015 rule also created small-sized and shorter-termed  licenses, which FCC stated would decrease the costs of obtaining a  license and help rural providers access it. However, FCC issued an  NPRM in 2017 that sought comments on suggested changes to  CBRS, including increasing the geographic area covered by licenses  and lengthening the license term. In October 2018, FCC adopted  rules that, among other changes, increased the license area from  census tracks to counties and extended the license term from 3 to 10  years, which FCC officials told us were modest changes made to  accomplish FCC’s goals of creating incentives for investment,  including in urban and rural areas, encouraging efficient spectrum  use, and promoting robust network deployments.

Conducted Outreach and Training for Tribal Entities on Spectrum-Related Issues

FCC’s ONAP conducts training, consultation, and outreach to tribal  entities on spectrum-related issues. For example, ONAP officials told us  that they have conducted 21 training and consultation workshops for tribal  entities on broadband and telecom since 2012, where spectrum has been  discussed in general in the introduction and has been addressed  specifically in separate sessions in some of the workshops. These  officials also told us that they communicate with tribal entities prior to  when FCC holds auctions or when implementing regulatory actions or  policies that will affect tribal governments and spectrum over their lands.  While representatives from 9 of the 16 tribal entities using wireless  technologies told us that they had received some outreach on spectrum- related issues from FCC, representatives from 2 of these entities said that  they had not. In addition, ONAP issued a report in 2012 to provide FCC  with a review of its work with tribal governments and organizations,  including information on its tribal broadband efforts, priorities, and tribal  consultations. Among other things, the report included case-study  information on tribal entities’ efforts to access spectrum. Although the  report stated that this would be the first of such annual reporting, this is  the only report that ONAP has issued on tribal issues. According to ONAP  officials, ONAP has not published subsequent reports because it provides  FCC with information on its work with tribal governments and  organizations, including spectrum-related matters, through more frequent  informal briefings and regular updates.

FCC Does Not Collect Key Information Related to Spectrum over Tribal Lands or Communicate It to Tribal Entities

FCC has not consistently collected information related to tribal access to  spectrum. For example, FCC does not collect data on whether holders of  spectrum licenses or auction applicants are tribal entities even though it  collects self-reported data on licensee type, such as corporation and  government entity. To obtain this information, FCC could include an  option for the licensee type, along with the other options, in applications  for future licenses and auctions that allows an applicant to identify as a  tribal government or tribally owned entity. FCC officials told us that they  use information on licensee type to determine eligibility for a license.  Because eligibility is not based on whether the applicant is a tribal entity,  FCC officials said this information is not needed. However, without this  information, FCC does not have a comprehensive understanding of the  extent that tribal entities are attempting to obtain or access licensed  spectrum or have been successful at obtaining and accessing it.

Additionally, FCC does not analyze information on unused licensed  spectrum that exists over tribal lands, even though FCC has  information—broadband availability data from providers and information  on geographic areas covered by spectrum licenses—that could be used  for such analysis. As we described earlier, representatives from all three  of the tribal associations we contacted reported that there are unused  spectrum licenses over tribal lands that could present opportunities  through the secondary market for tribal entities to obtain spectrum. When  we asked FCC officials why they do not analyze the extent that unused  spectrum licenses exists over tribal lands, they told us that the spectrum  data noted above is not specific enough to allow for a license by license  analysis of unused spectrum. For example, they said that broadband  availability data from providers is aggregated across wide spectrum  bands to minimize reporting burdens on the wireless industry, and the  data are not sufficiently detailed to identify which spectrum blocks and  licenses are being used in particular areas. However, FCC could use this  data to conduct, at a minimum, high-level analysis that would result in  useful information on the extent to which unused spectrum exists over  tribal lands. In addition, FCC officials told us that they evaluate the  effectiveness of FCC’s secondary markets policies, which FCC views as  a mechanism to promote the increased use of unused spectrum licenses,  but this approach does not include an analysis of unused spectrum  licenses as part of these efforts. As a result, FCC’s evaluations of the  secondary market may not accurately reflect how these policies affect  tribal access to spectrum. Because the secondary market is one of few  ways for tribal entities to access licensed spectrum, an analysis of unused  licensed spectrum that exists over tribal lands would enable FCC to better  promote a robust secondary market that provides additional opportunities  for tribes to access spectrum.

FCC’s 2010 National Broadband Plan stated that ongoing measurement  of spectrum utilization should be developed to better understand how  spectrum resources are being used because some studies indicated that  spectrum goes unused in many places much of the time. The plan also  stated that any spectrum utilization studies that FCC conducts should  identify tribal lands as distinct entities. In FCC’s February 2018 strategic  plan, FCC stated that it will implement ongoing initiatives that will assist in  spectrum policy planning and decision making, promote a robust  secondary market in spectrum, and improve communications services in  all areas of the United States, including tribal areas. Additionally,  Standards for Internal Control in the Federal Government state that  agencies should use quality information, including information that is  complete, to inform the decision-making processes.

FCC also does not make information on spectrum-license holders  available in an easy or accessible manner; such information could be  beneficial to the tribes in their efforts to obtain spectrum in the secondary  market. As described earlier, the secondary market is a significant  mechanism for tribal entities to obtain spectrum licenses, but  representatives from the tribal entities we interviewed reported challenges  related to participating in the secondary market, such as not knowing  whom to contact should they wish to engage in a secondary market  transaction to obtain a spectrum license. In July 2014, FCC stopped  updating its spectrum dashboard, which provided the public with a way to  identify who holds licenses in what areas, including features that allowed  users to identify spectrum allocated and assigned in tribal lands. ONAP  stated in its 2012 report that this feature represented the first step for  individual tribal entities to reach out to licensees and seek leasing,  partnership, or other arrangements that could ultimately result in the  provision of service over tribal lands. FCC officials told us that the public  may view electronic records of all wireless spectrum licenses in FCC’s  Universal Licensing System, using a wide range of license and  geographic parameters, such as licensee names, radio services,  spectrum bands, and geographic locations. However, we attempted to  navigate the Universal Licensing System to determine spectrum-license  holders for specific tribal lands using geographic parameters, but we were  unable to successfully do so because the system is so difficult to use.  Furthermore, as described above, representatives from eight of the tribal  entities that we contacted stated that it is difficult to determine who holds  spectrum licenses. When we asked FCC officials why they do not  communicate information to tribes about spectrum-related transactions  over tribal lands, FCC officials also told us that they issue public notices  on applications for all proposed spectrum transactions and on the winning  bidders of all auctions, but they have not made it a practice to reach out  directly to tribes to make them aware of when providers have obtained  spectrum licenses that cover tribal lands.

The National Broadband Plan stated that FCC should make data  available that would promote a robust secondary market for spectrum  licenses, such as information on how and to whom spectrum is allocated  on tribal lands. Additionally, Standards for Internal Control in the Federal  Government state the need for federal agencies to communicate with  external entities and to enable these entities to provide quality information  to the agency that will help it achieve its objectives. Tribal governments  are an example of such external entities. The ability of tribal governments to make informed spectrum planning decisions and to participate in  secondary market transactions is diminished without information from  FCC on the spectrum transactions that occur over tribal lands. Providing  this information in a manner that is accessible and easy for tribal entities  to obtain could enable them to enter into leasing, partnership, or other  arrangements to obtain spectrum.

Broadband service on tribal lands continues to lag behind the rest of the  country, especially on rural tribal lands, which could hinder tribal efforts to  promote self-governance, economic opportunity, education, public safety,  and cultural preservation. FCC has reported that wireless technologies  that access spectrum to deliver broadband services are cost-effective for  remote and sparsely populated areas, such as tribal lands. However,  FCC’s efforts to promote and support tribal entities’ access to spectrum  have done little to increase tribal use of spectrum, as only very few tribes  are accessing spectrum to be able to provide Internet service.  Additionally, FCC lacks information that could help inform its decision- making processes related to spectrum policy planning, which is intended  to improve communications services in all areas of the United States,  including tribal lands. By collecting data on the extent that tribal entities  are obtaining and accessing spectrum, FCC could better understand tribal  spectrum issues and use this information as it implements ongoing  spectrum initiatives. Furthermore, the secondary market is one of few  ways for tribal entities to access licensed spectrum to be able to provide  Internet service, and FCC has recognized the importance of promoting a  robust secondary market. FCC could promote a more robust secondary  market by analyzing data to better understand how much unused licensed  spectrum exists over tribal lands and using that information to promulgate  regulations and to evaluate how FCC policies affect tribal participation in  the secondary market. Additionally, by making information on who holds  spectrum licenses over tribal lands more accessible and easy to  understand, FCC could remove a barrier tribes may face in attempting to  obtain spectrum through the secondary market.

We are making the following three recommendations to the Chairman of  FCC.

The Chairman of FCC should collect data on the extent that tribal  entities are obtaining and accessing spectrum and use this  information as FCC implements ongoing spectrum initiatives.  (Recommendation 1)

The Chairman of FCC should analyze data to better understand the  extent that unused spectrum licenses exist over tribal lands, such as  by analyzing the data for a sample of tribal lands, and as appropriate  use this information to inform its oversight of the secondary market.  (Recommendation 2)

The Chairman of FCC should make information on spectrum-license  holders more accessible and easy to understand for interested  parties, including tribal entities, to promote their ability to purchase or  lease spectrum licenses from other providers. (Recommendation 3)

We provided a draft of this report to FCC for comment. In its comments,  reproduced in appendix III, FCC agreed with the recommendations. FCC  also provided technical comments, which we incorporated as appropriate.

We are sending copies of this report to the appropriate congressional  committees, the Chairman of FCC, 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 goldsteinm@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.

This report examines (1) what is known about the ability of tribal entities  to obtain and access spectrum to provide broadband services on tribal  lands and the reported barriers that may exist; and (2) the extent to which  the Federal Communications Commission (FCC) promotes and supports  tribal entities’ ability to obtain and access spectrum for broadband  services.

To address both objectives, we reviewed relevant statutes and  regulations and FCC documents, including FCC’s Statement of Policy on  Establishing a Government-to-Government Relationship with Indian  Tribes, the National Broadband Plan, and FCC’s current strategic plan.  We interviewed FCC officials and representatives from 3 tribal  associations, 7 private providers that deliver Internet services over tribal  lands, 3 industry associations that represent rural and urban  telecommunications providers, 3 regional consortia, 3 companies that  work with tribal entities, and 1 academic group. In addition, we selected  24 tribal entities—13 Indian tribes and nations and 11 tribally owned  providers—to interview.

To identify tribal entities that were using wireless technologies, we  obtained recommendations from stakeholders, reviewed data on relevant  federal grants, such as the Broadband Technology Opportunities  Program, and conducted Internet research. We then selected 16 tribal  entities considering (1) stakeholder suggestions, (2) population, (3)  population density, and (4) urban or rural designation. We visited 7 of  these tribes in Idaho, New Mexico, and Washington State. The views  represented in our report are not generalizable to those of all  stakeholders. See table 2 for a complete listing of the entities we  interviewed. We also conducted a literature review to identify relevant  academic, government, and media publications that were published  between January 1, 2013, and January 11, 2018, that discuss the  importance of and options to enhance tribal access to spectrum.

To identify tribal entities that applied to participate in spectrum auctions or  that held active spectrum licenses in bands that can be used to provide  broadband service, we analyzed (1) FCC data on entities that applied to  participate in auctions for spectrum in these bands and (2) FCC data on  spectrum licenses in these bands that were active as of September 6,  2018. We also analyzed FCC license data, together with license  information publicly available through FCC’s Universal Licensing System,  to determine whether the tribal entities that held active licenses obtained  those licenses through an FCC spectrum auction, administrative  assignment, or the secondary market. We then reviewed the list of  federally recognized tribes in the Federal Register and identified search  terms related to these tribes. For example, we identified the following  search terms based on the federally recognized tribe, Yurok Tribe of the  Yurok Reservation, California, “Reservation, Tribe, and Yurok.” We then  used the identified search terms to search for tribal entities in FCC’s data  on auction participants and spectrum license holders. We manually  reviewed these matches to identify tribal entities based on information  from interviews, Internet research, and professional judgment. Because  tribal entities may have applied to participate in spectrum auctions or may  hold spectrum licenses under names not associated with their tribes,  there may be additional tribal entities that we were unable to identify.  Through interviews with FCC officials and review of related  documentation, we determined that the license and auction participant  data are sufficiently reliable for our purpose of identifying some tribal  entities that have applied to participate in a spectrum auction or held  active spectrum licenses as of September 2018. However, our analysis  does not capture the extent that tribal entities may have obtained a  license that is no longer active. To identify tribal entities that used  unlicensed spectrum to deliver unlicensed service, we interviewed the  tribal entities identified above. In addition, we obtained stakeholder views  on the advantages and disadvantages of using unlicensed and licensed  frequency bands and any barriers that tribal entities face in obtaining  spectrum licenses by interviewing the selected stakeholders noted above.

To determine the extent to which FCC promotes and supports tribal  entities’ efforts to obtain and access spectrum, first, we reviewed FCC’s  proposals in its ongoing 2011 Notice of Proposed Rulemaking In the  Matter of Improving Communications Services for Native Nations by  Promoting Greater Utilization of Spectrum over Tribal Lands and its  ongoing 2018 Notice of Proposed Rulemaking In the Matter of  Transforming the 2.5 GHz Band. We summarized public comments  submitted, as of August 2018, by private and tribal providers, rural and  nationwide industry associations, tribal associations, and tribal  governments on FCC’s 2011 proposed rulemaking. We did not analyze  comments on FCC’s 2018 Notice of Proposed Rulemaking because FCC  was in the process of responding to these comments at the time of our  review. Second, we reviewed rules that FCC officials identified that  increased the availability of unlicensed and licensed frequency bands for  broadband use and that may be particularly useful for tribal entities.  These rules included FCC’s 2010 and 2012 rules related to TV white  space spectrum and its 2015 rule and 2017 Notice of Proposed  Rulemaking related to the Citizens Broadband Radio Services (CBRS)  spectrum. We identified tribal entities that had been using CBRS  frequency bands by reviewing FCC licensed data and TV white space  frequency bands through interviews with tribal entities and regional  consortia. Third, we identified FCC’s outreach activities to provide tribal  entities with assistance on spectrum-related issues by interviewing FCC  officials and reviewing documentation on the content of FCC-led trainings  and workshops, e-mail correspondences, and related publications, such as public notices. Lastly, we interviewed FCC officials on the information  that they collect, analyze, and report related to tribal use of spectrum and  reviewed related documentation, including FCC’s Office of Native Affairs  and Policy 2012 Annual Report and FCC’s license and auction data. We  interviewed stakeholders, as noted above, and summarized their views of  FCC efforts. We also compared FCC’s efforts against FCC’s 2018-2022  strategic plan, recommendations made in FCC’s National Broadband  Plan, and Standards for Internal Control in the Federal Government  related to using quality information.

Appendix II: Auctioned Licensed Spectrum Available for Commercial Broadband Services

We identified the spectrum frequency bands that the Federal  Communications Commission (FCC) has made available for commercial  broadband services and that FCC assigns licenses through auctions.  Table 3 describes these licenses, including the number and date of  related auctions.

Appendix III: Comments from the Federal Communications Commission

Mark L. Goldstein, (202) 512-2834 or goldsteinm@gao.gov.

In addition to the contact named above, Sally Moino (Assistant Director),  Anne Doré (Analyst in Charge), Enyinnaya David Aja, Katherine Blair,  Stephen Brown, Camilo Flores, Georgeann Higgins, John Mingus, Josh  Ormond, Frank Rusco, Rebecca Rygg, Jay Spaan, Andrew Stavisky,  James Sweetman, Jr., Hai Tran, and Michelle Weathers made key  contributions to this report.

Broadband Internet service is essential to many aspects of modern life, so it's important to make sure everyone has access. Yet tribal lands, especially in rural areas, are still underserved.

In such areas, wireless broadband can help keep people connected. However, the Federal Communications Commission has done little to promote and support tribes' access to radio frequency spectrum that can be used for such wireless service.

We made 3 recommendations to the FCC to help improve tribes' access.


Grants Management: Observations on Challenges and Opportunities for Reform

Federal outlays for grants to state and local governments totaled more than $674 billion in fiscal year 2017, equivalent to 3.5 percent of the gross domestic product in that year. GAO's previous work has found that growth in both the number of grant programs and level of funding has increased the diversity of federal grants to state and local governments.

GAO's work has also found that designing and implementing grants management policies that strike an appropriate balance between ensuring accountability for the proper use of federal funds without increasing the complexity and cost of grants administration for agencies and grantees presents a governance challenge. At the same time, several government-wide initiatives hold promise for advancing the transparency, efficiency, and effectiveness of federal grants.

This statement is based on GAO's prior reports on federal grants management and crosscutting issues related to managing for results across the federal government issued between 2005 and 2018. It addresses: (1) GAO's observations on long-standing challenges for federal grants management, and (2) opportunities to effectively advance current grant modernization initiatives.

GAO has identified challenges to federal grants management in its work spanning several decades. These challenges include:

Streamlining: Grants management requirements that are duplicative, unnecessarily burdensome, and conflicting require agencies to direct resources toward meeting them and can burden recipients of federal grants. GAO has reported on initiatives to streamline these requirements and address challenges grantees encounter throughout the grants lifecycle.

Transparency: The Digital Accountability and Transparency Act of 2014 (DATA Act) required the Office of Management and Budget, the Department of the Treasury, and other federal agencies to increase the types of information available on federal spending, including grants. GAO has reported on progress in standardizing and expanding reported data, but has found inconsistencies with the completeness and quality of the reported information.

Collaboration and consultation: Collaboration, particularly information sharing, is an important factor in effective grants management. GAO's work on interagency grants management reform initiatives found that inadequate ongoing communication with grantees sometimes resulted in poor implementation and prioritization of initiatives.

Duplication, overlap, and fragmentation : Agencies' grants management practices, such as requirements to avoid duplication and overlap among grants before awarding them, can help agencies achieve cost savings and result in greater efficiencies in grant programs.

Internal controls and oversight : GAO's work has identified weaknesses in grants oversight and accountability. For example, GAO has identified opportunities for agencies to more consistently close out grants when the grantee's period of performance has ended to ensure that grantees have met all requirements and identified opportunities to redirect or return unused funds.

Recent and proposed initiatives aimed at grants management reform present opportunities to improve the efficiency, effectiveness, and transparency of federal grants. GAO's work on federal grants management and managing for results has highlighted a number of key features for effectively implementing such crosscutting initiatives, which include: (1) establishing implementation goals and tracking progress, (2) identifying and agreeing on leadership roles and responsibilities, and (3) developing an effective communication strategy.

Further, given the number and diversity of grantor agencies and grant programs, it is important that any grant reform initiative integrate with other government-wide reform efforts on related issues across government, such as the grants-related Cross-Agency Priority goal, implementation of the DATA Act, and initiatives related to evidence-based policy. These efforts can be effective if they complement each other rather than run the risk of operating independently and potentially duplicating effort or working at cross-purposes.

Thank you for the opportunity to join you today to discuss issues related  to federal grants management. GAO’s previous work has found that  growth in both the number of grant programs and level of funding has  increased the diversity of federal grants to state and local governments  and complexity in federal grants management processes. At the same  time, several government-wide initiatives hold great promise for  advancing the transparency, efficiency, and effectiveness of federal  grants. These are important and challenging issues and I am pleased to  have the opportunity to share observations from our large body of work  on federal grants management as well as suggestions for moving forward  with grant reform initiatives.

As we have previously reported, federal grants to state and local  governments are an important tool of government. This policy tool  provides funding for national priorities in many areas including health  care, transportation, education, and social services. Federal outlays for  grants to state and local governments totaled more than $674 billion in  fiscal year 2017, equivalent to 3.5 percent of the gross domestic product  (GDP) in that year. Grants vary greatly in numerous ways including size,  the nature of their recipients, and the type of programs they fund. In  addition, substantial variation in the way federal agencies administer  these programs has further increased their complexity. This diversity and  complexity contributes to the challenge of government-wide efforts to  address crosscutting grants management reforms.

Recent initiatives—including the administration’s establishment of the  Results-Oriented Accountability for Grants Cross-Agency Priority (CAP)  goal through the President’s Management Agenda (PMA)—present an  opportunity for the federal government to help address long-standing  grants management challenges. Congress has often asked us to evaluate  grants management issues to inform efforts that focus on accountability,  while maximizing the investment of billions of dollars in federal grant  funding. Our work also reflects the intergovernmental perspectives  inherent in the administration of these grants and includes insights from  reviews of federal government agencies as grantors as well as the  perspectives of grantees in their role as implementers of these grants.

Drawing on our prior federal grants management work as well as our  work on managing for results across the federal government, my remarks  today address: (1) observations on long-standing challenges for federal  grants management and (2) opportunities to effectively advance current  grant modernization initiatives. My testimony is based on our prior reports  and testimonies on federal grants management, fiscal controls, and grant  reporting as well as crosscutting work on government performance and  transparency issued between 2005 and 2018. We used multiple  methodologies to develop the findings, conclusions, and  recommendations for the prior products serving as the foundation for this  statement. A more detailed discussion of the prior reports’ objectives,  scope, and methodologies, including our assessment of data reliability, is  available in the reports cited throughout this statement.

The work upon which this testimony is based was conducted 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.

Observations on Grants Management Challenges

Streamlined Grants Management is Critical to Effective Use of Federal Funds

Our work has shown that when grants management requirements are  duplicative, unnecessarily burdensome, and conflicting, agencies must  direct resources toward meeting them—which can make the agency’s  programs and services less cost effective and increase burden for grant  recipients. For example, in 2016, we reviewed administrative  requirements for federal research grants. Officials from universities and  stakeholder organizations we interviewed identified common factors that  added to their administrative workload and costs for complying with  selected requirements. These factors included:  variation in agencies’ implementation of requirements, pre-award requirements for applicants to develop and submit detailed  documentation for grant proposals, and  increased prescriptiveness of certain requirements.

We have also reported on a number of initiatives intended to address the  challenges grantees encounter throughout the grants lifecycle. These  initiatives include consolidating and revising grants management  circulars, simplifying the pre-award phase, promoting shared information  technology solutions for grants management, and improving the  timeliness of grant closeout and reducing undisbursed balances. Our  work includes reviews of efforts to submit the Consolidated Federal  Financial Report through a single system and to standardize notices of  award to reduce reporting burden. In addition, the Digital Accountability  and Transparency Act of 2014 (DATA Act) required the Office of  Management and Budget (OMB) to establish a pilot program to develop  recommendations for reducing reporting burden for recipients of federal  awards. In 2016 and 2017, we reported on the design and  implementation of the OMB pilot program, known as the Section 5 Pilot,  aimed at developing recommendations for reducing reporting burden for  grant recipients and contractors. We made a number of  recommendations to improve the design of the Section 5 Pilot to ensure  its consistency with leading practices for pilot design, which OMB has  implemented. We continue to monitor implementation of the Section 5  Pilot through ongoing work and look forward to keeping the subcommittee  informed about our findings.

Transparency of Grant Spending Can Inform Decision Making

To provide increased transparency to agencies, Congress, and the public,  the DATA Act required OMB, the Department of the Treasury (Treasury),  and other federal agencies to increase the types of information available  on the more than $3.7 trillion in annual federal spending, including federal  spending on grants. The law requires OMB and Treasury to establish  data standards to enable the reporting and tracking of agency spending at  multiple points in the spending lifecycle. Since enactment, OMB,  Treasury, and federal agencies have addressed many of the policy and  technical challenges presented by the act’s requirements, including  standardizing data elements across the federal government, linking data  contained in agencies’ financial and award systems, and expanding the  types of data reported. However, in a 2017 report, we found  inconsistencies in key award data elements and issues with the  completeness and quality of the information reported. We made a number  of recommendations to OMB and Treasury to clarify guidance to help  agencies fully comply with DATA Act requirements and report accurate  data and to disclose known data quality issues. OMB and Treasury  generally agreed with our recommendations. Once the accuracy of these  data are improved, federal managers should be better able to make data  driven decisions to address ongoing government management challenges  and improve the effectiveness and efficiency of government programs.

Effective Grants Management Benefits from Collaboration and Consultation

The process of distributing federal assistance through grants is  complicated and involves many different parties—both public and  private—with different organizational structures, sizes, and missions. A  lack of collaboration among and between federal agencies, state and  local governments, and nongovernmental grant participants presents a  challenge to effective grants implementation. Given the complexity of  managing intergovernmental grants, collaboration among the grant  participants, particularly with regard to information sharing, is an  important factor in effective grants management. For example, one of the  lessons learned in our work on the American Recovery and Reinvestment  Act of 2009 (Recovery Act) is that increased accountability requirements  and aggressive timelines require coordination—both vertically among  levels of government and horizontally within the same level of  government—to share information and work toward common goals during  implementation. Intra- and intergovernmental networks facilitated efforts  to achieve the purposes of the act in an effort to efficiently and effectively  spend the grant funds.

Our work on interagency grants management reform initiatives also found  that inadequate ongoing communication with grantees sometimes  resulted in poor implementation and prioritization of initiatives. Our 2014  work on the Recovery Act illustrated how agencies can effectively  approach ongoing communication. For example, the developers of  Recovery.gov used input from user forums, focus groups, and usability  testing with interested citizens to collect feedback and  recommendations. This information then informed the development of  the website from its initial stages. More recently, in our 2014 work on the  DATA Act, we have noted OMB and Treasury efforts to allow the public to  share their views and comment on the development of federal data  standards.

Identifying Fragmentation, Overlap and Duplication Could Result in Greater Efficiencies

Our prior work has shown that numerous federal grant programs created  over time without coordinated purposes and scope can result in grants  management challenges. Addressing these challenges may achieve cost  savings and result in greater efficiencies in grant programs. Our work has  underscored the importance of identifying fragmentation, overlap, or  duplication in a number of federal programs, including grants  management practices. For example, in January 2017, we found that  the National Park Service, Fish and Wildlife Service, Food and Nutrition  Service, and Centers for Disease Control and Prevention had not  established guidance and formal processes to avoid duplication and  overlap among grants in their agencies before awarding grants. We  recommended that these agencies do so, and they agreed. In response,  these agencies have taken a number of actions to address the  recommendation. For example, the Department of the Interior provided us  documentation showing that the Fish and Wildlife Service now requires  that discretionary grant applicants provide a statement that addresses  whether there is any overlap or duplication of proposed projects or  activities to be funded by the grant. The Fish and Wildlife Service also  updated its guidance to grant awarding offices instructing them to perform  a potential overlap and duplication review of all selected applicants prior  to making grant awards.

Strong Internal Controls and Oversight Facilitate Effective Use of Grant Funds

Our prior work has shown that when awarding and managing federal  grants, effective oversight and internal control is important to provide  reasonable assurance to federal managers and taxpayers that grants are  awarded properly, recipients are eligible, and federal grant funds are used  as intended and in accordance with applicable laws and regulations.  Internal control comprises the plans, methods, and procedures agencies  use to be reasonably assured that their missions, goals, and objectives  can be met. In numerous reviews, we and agency inspectors general  identified weaknesses in agencies’ internal controls for managing and  overseeing grants. Specifically, we found that when such controls are  weak, federal grant-making agencies face challenges in achieving grant  program goals and assuring the proper and effective use of federal funds  to help avoid improper payments. Our work has identified weaknesses in  grants oversight and accountability issues that span the government  including undisbursed grant award balances, single audit submissions  that are late, and significant levels of improper payments in grant  programs. Key grants management challenges related to internal controls  and oversight that we have identified include:

Timeliness of grant closeouts. Federal grant-making agencies must  close out grants when the grantee’s period of performance has ended  in order to ensure that grantees have met all financial requirements  and provide final reports as required. Closing out grants also allows  agencies to identify and redirect unused funds to other projects and  priorities as authorized or to return unspent balances to the Treasury.  These accounts, and, in some cases, the undisbursed balances  associated with them, persisted as an issue for agencies, as we  reported in 2008, 2012, and 2016. In January 2016, the Grants  Oversight and New Efficiency Act (GONE Act) was signed into law.

The act, passed in part in response to our work, required government- wide reporting of undisbursed balances in expired grant accounts.

The GONE Act requires that agencies report on the grants for which  the grantee’s period of performance had expired for more than 2  years, including those with undisbursed balances and with zero dollar  balances remaining in the accounts. In the fall of 2017, many  agencies included in their annual Agency Financial Reports an  appendix providing information required by the GONE Act. For  example, the Department of Health and Human Services (HHS)  reported almost $2 billion in undisbursed funds remaining in 16,603  grant accounts that were two years or more past their periods of  performance and 6,512 grant accounts that had no funds remaining in  them. HHS grant officials told us that they intend to close as many of  these grant accounts as possible during this fiscal year.

Timely submission of single audits. As we have previously  reported, one key way that federal agencies oversee nonfederal  grantees is through an audit of their expenditures of federal awards,  referred to as a single audit. The single audit is an audit of the award  recipient’s expenditure of federal awards and of its financial  statements. A single audit can identify deficiencies in the award  recipient’s compliance with the provisions of laws, regulations,  contracts, or grant agreements and in its financial management and  internal control systems. Correcting such deficiencies can help  reasonably assure the effective use of federal funds and reduce  federal improper payments. In 2017, we reported that of the five  departments we reviewed—the Departments of Agriculture,  Education, HHS, Housing and Urban Development, and  Transportation—some of the departments’ subagencies did not  effectively design policies and procedures to reasonably assure the  timely submission of single audit reports by award recipients. In this  report, we made 21 recommendations to these departments. Some  action has been taken to date in response to these recommendations.

Avoiding improper payments of federal grants. As we have  previously reported, improper payments—payments that should not  have been made or that were made in an incorrect amount—have  consistently been a government-wide issue. Since fiscal year 2003— when certain agencies were required by statute to begin reporting  estimated improper payments for certain programs and activities— cumulative improper payment estimates have totaled about $1.4  trillion. Our reviews of Medicaid, a joint federal-state health care  program and significant source of federal grant funding to state  governments, have shown that the program is particularly vulnerable  to improper payments, given its size, diversity, and complexity. For  example, Medicaid accounted for more than 26 percent ($36.7 billion)  of the nearly $141 billion government-wide improper payment  estimate in fiscal year 2017. We have also reported that federal  spending for Medicaid is expected to significantly increase, so it is  especially critical that appropriate measures be taken to reduce  improper payments in this program.

Opportunities to Effectively Advance Current Grants Management Initiatives

Recent and proposed legislative- and executive-sponsored initiatives  aimed at grants management reform, present opportunities to improve the  efficiency, effectiveness, and transparency of federal grants. Our work on  the design and implementation of merit-based grant award selection and  initiatives to manage for results across the federal government has  highlighted a number of key features necessary to effectively implement  such crosscutting initiatives. Those features include:

Establishing implementation goals and tracking progress. Our  work highlighted the importance of establishing an implementation  schedule and tracking progress toward priorities to help pinpoint  performance shortfalls and suggest midcourse corrections, including  any needed adjustments to future priorities and milestones.

Identifying and agreeing on leadership roles and responsibilities.  Our work has shown that when interagency councils clarify who will  do what, identify how to organize their joint and individual efforts, and  articulate steps for decision making, they enhance their ability to work  together and achieve results.

Developing an effective communication strategy. We reported on  the importance of two-way communication that allows for feedback  from relevant stakeholders. For example, our work showed that  grantees felt that a lack of opportunities to provide timely feedback  resulted in poor implementation and prioritization of streamlining  initiatives and limited grantees’ use and understanding of new  functionality of electronic systems.

In addition, given the number and diversity of grantor agencies and  grantmaking programs, we believe it is important that any grant reform  initiative integrate with other government-wide reform efforts on related  issues. One such reform initiative is the PMA, which lays out a long-term  vision for modernizing the federal government and improving the ability of  agencies to achieve results. The PMA identified a set of CAP goals to  target areas where multiple agencies must collaborate to effect change  and report progress in a manner the public can easily track. According  to the PMA, one of the goals included in the agenda—the Results- Oriented Accountability for Grants CAP goal—is intended to maximize the  value of grant funding by applying a risk-based data-driven framework  that balances compliance requirements with demonstrating successful  results for taxpayers. The PMA further states that this CAP goal seeks to  standardize grant reporting data and improve data collection in ways that  will increase efficiency, promote evaluation, and reduce reporting burden.  Effectively advancing results-oriented accountability for grants will require  that implementation of this CAP goal moves forward in tandem with  related efforts to implement the DATA Act and advance the use of  evidence to inform grant policy, highlighted below:

DATA Act implementation. As our work has shown, the DATA Act  will continue to be a critical driver of grants management change and  reform. When fully implemented, the act will improve the  accountability and transparency of federal spending data by (1)  establishing government-wide financial data standards so that data  are comparable across agencies and (2) holding federal agencies  more accountable for the quality of the information disclosed. Such  increased transparency provides opportunities for improving the  efficiency and effectiveness of federal spending; increasing the  accessibility of data to benefit the public and the business community;  and improving oversight to prevent and detect fraud, waste, and  abuse of federal funds. As efforts to implement the DATA Act move  forward, we will continue to monitor implementation efforts and  coordinate our efforts with agency inspectors general.

Evidence-based policy. To better integrate evidence and rigorous  evaluation in budget, management, operational, and policy decisions,  OMB has encouraged federal agencies to expand or improve the use  of grant program designs that focus federal dollars on effective  practices while encouraging innovation in service delivery. For  example, OMB’s efforts to foster a culture of evidence-based policy  resulted in several federal agencies’ implementation of tiered  evidence grant programs. Under this approach, agencies establish  tiers of grant funding based on the level of evidence of effectiveness  provided for a grantee’s service model. Agencies award smaller  amounts to promising service models with a smaller evidence base,  while providing larger amounts to those with more supporting  evidence. In our 2016 report, we recommended that OMB establish a  formal means for federal agencies to collaborate on tiered evidence  grants. In response, in 2017, OMB launched the Tiered Evidence  Grants Working Group to collaborate and share lessons learned, for  example, on the use and dissemination of evaluation results.

These efforts should complement each other. A lack of integration could  result in duplication of effort or run the risk of working at cross-purposes.  For example, the integration of the Results-Oriented Accountability for  Grants CAP goal with ongoing DATA Act implementation and efforts to  advance evidence-based approaches to federal grant funding and  administration presents a complex governance challenge.

In conclusion, designing and implementing grants management policies  that strike an appropriate balance between ensuring accountability for the  proper use of federal funds without increasing the complexity and cost of  grants administration for agencies and grantees is a longstanding  governance challenge. As the initiatives above demonstrate, meeting this  challenge and successfully implementing grants management reforms will  require intragovernmental coordination at the federal level,  intergovernmental collaboration with state and local governments and  other partners, and ongoing integration to ensure that grants  management reforms and related DATA Act and evidence-based policy  implementation efforts are complementary and do not exist in separate  silos.

We look forward to continuing our ongoing work to review implementation  of the CAP goals, the DATA Act, and the infusion of evidence-based  policy in federal grant programs. We also look forward to working with this  and other committees as we assist Congress in identifying additional  opportunities to advance grants management reform through reviews of  individual grant programs and crosscutting analysis of grant  implementation and grants management reform efforts.

Chairman Palmer, Ranking Member Raskin, and members of the  Subcommittee, this concludes my prepared remarks. I look forward to  answering any questions you may have.

For questions about this statement, please contact me at (202) 512-6806  or sagerm@gao.gov. Contact points for our Offices of Congressional  Relations and Public Affairs may be found on the last page of this  statement. Individuals making key contributions to this testimony were  Brenda Rabinowitz and Tom James, Assistant Directors, Alexandra  Edwards, Julie Miller, Andrew J. Stephens, and Walter Vance.

The Nation’s Fiscal Health: Action Is Needed to Address the Federal  Government’s Fiscal Future. GAO-18-299SP. Washington, D.C.: June 21,  2018.

Improper Payments: Actions and Guidance Could Help Address Issues  and Inconsistencies in Estimation Processes. GAO-18-377. Washington,  D.C.: May 31, 2018.  2018 Annual Report: Additional Opportunities to Reduce Fragmentation,  Overlap, and Duplication and Achieve Other Financial Benefits.  GAO-18-371SP. Washington, D.C.: Apr. 26, 2018.

DATA Act: OMB, Treasury, and Agencies Need to Improve Completeness  and Accuracy of Spending Data and Disclose Limitations. GAO-18-138.  Washington, D.C.: Nov. 8, 2017.

Managing for Results: Further Progress Made in Implementing the GPRA  Modernization Act, but Additional Actions Needed to Address Pressing  Governance Challenges. GAO-17-775 Washington, D.C.: Sept. 29, 2017.

Single Audits: Improvements Needed in Selected Agencies’ Oversight of  Federal Awards. GAO-17-159. Washington, D.C.: Feb. 16, 2017.

High-Risk Series: Progress on Many High-Risk Areas, While Substantial  Efforts Needed on Others. GAO-17-317. Washington, D.C.: Feb. 15,  2017.

Grants Management: Selected Agencies Should Clarify Merit-Based  Award Criteria and Provide Guidance for Reviewing Potentially  Duplicative Awards. GAO-17-113. Washington, D.C.: Jan. 12, 2017.

Tiered Evidence Grants: Opportunities Exist to Share Lessons from Early  Implementation and Inform Future Federal Efforts. GAO-16-818.  Washington, D.C.: Sept. 21, 2016.

Federal Research Grants: Opportunities Remain for Agencies to  Streamline Administrative Requirements. GAO-16-573. Washington,  D.C.: June 22, 2016.

Managing for Results: OMB Improved Implementation of Cross-Agency  Priority Goals, But Could Be More Transparent about Measuring  Progress. GAO-16-509. Washington, D.C.: May 20, 2016.

DATA Act: Section 5 Pilot Design Issues Need to Be Addressed to Meet  Goal of Reducing Recipient Reporting Burden. GAO-16-438. Washington,  D.C.: Apr. 19, 2016.

Grants Management: Actions Needed to Address Persistent Grant  Closeout Timeliness and Undisbursed Balance Issues. GAO-16-362.  Washington, D.C.: Apr. 14, 2016.

Federal Data Transparency: Effective Implementation of the DATA Act  Would Help Address Government-wide Management Challenges and  Improve Oversight. GAO-15-241T. Washington, D.C.: Dec. 3, 2014.

Managing for Results: Implementation Approaches Used to Enhance  Collaboration in Interagency Groups. GAO-14-220. Washington, D.C.:  Feb, 14, 2014.

Recovery Act: Grant Implementation Experiences Offer Lessons for  Accountability and Transparency. GAO-14-219. Washington, D.C.: Jan.  24, 2014.

Grant Workforce: Agency Training Practices Should Inform Future  Government-wide Efforts. GAO-13-591. Washington, D.C.: June 28,  2013).

Grants Management: Oversight of Selected States’ Disbursement of  Federal Funds Addresses Timeliness and Administrative Allowances.  GAO-13-392. Washington, D.C.: Apr. 16, 2013.

Grants Management: Improved Planning, Coordination, and  Communication Needed to Strengthen Reform Efforts. GAO-13-383.  Washington, D.C.: May 23, 2013.

Grants to State and Local Governments: An Overview of Federal Funding  Levels and Selected Challenges. GAO-12-1016. Washington, D.C.: Sept.  25, 2012.

Grants Management: Action Needed to Improve the Timeliness of Grant  Closeouts by Federal Agencies. GAO-12-360. Washington, D.C.: Apr. 16,  2012.

Grants Management: Attention Needed to Address Undisbursed  Balances in Expired Grant Accounts. GAO-08-432. Washington, D.C:  Aug. 29, 2008.

Grants Management: Grantees’ Concerns with Efforts to Streamline and  Simplify Processes. GAO-06-566. Washington, D.C.: July 28, 2006.

Grants Management: Additional Actions Needed to Streamline and  Simplify Processes. GAO-05-335. Washington, D.C.: Apr. 18, 2005.

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Federal grants to state and local governments totaled over $674 billion in FY 2017. The number of grant programs across federal agencies has increased in recent years, as has the level of funding, which has led to a more complex federal grant management process.

We testified about a number of grants management suggestions we have made in recent years, including:

Streamlining grant requirements so that they aren't duplicative or unnecessarily burdensome

Encouraging greater collaboration among grant participants to ensure effective grant implementation

Increasing the completeness and quality of publicly available data on federal grant spending