A summary of "Moving Toward Opportunity for All: The Future of Universal Service Reform"

A new "consensus-driven roadmap" on the future of the Universal Service Fund argues that universal service should be understood as an ongoing responsibility, not a goal to achieve, and offers six principles for Universal Service Fund reform.

A cross-sector task force co-chaired by two former Federal Communications Commission (FCC) commissioners has released a consensus framework intended to guide Congress as it considers the future of the Universal Service Fund (USF), the roughly $8 billion-a-year system that subsidizes telecommunications service for rural areas, schools and libraries, rural health care providers, and low-income households.

The Future of Universal Service Reform Task Force, chaired by Mignon Clyburn and Rachelle Chong, "was convened to explore how the nation's universal service policies should evolve to meet the communications needs of the twenty-first century." Participants "represented a broad range of perspectives, including consumer advocates, industry representatives, education and health care stakeholders, public interest organizations, and policy experts." 

The initiative was launched through a partnership between Keep Our Communities Connected (KOCC) and the Schools, Health, and Libraries Broadband (SHLB) Coalition, with organizational leadership from InnovateEDU CEO Erin Mote and SHLB Executive Director Joseph Wender. 

The Universal Service Fund

For readers new to the topic, the report supplies a primer:

• Legal foundation. The USF was "[e]stablished by the Communications Act of 1934 to ensure baseline telephone access, and significantly expanded by the Telecommunications Act of 1996 to encompass modern digital connectivity and internet services."
• Oversight and administration. The Fund is "[g]overned by the Federal Communications Commission (FCC) and administered by the independent non-profit Universal Service Administrative Company (USAC)."
• Four core programs. The High-Cost Program (Connect America Fund) subsidizes buildout "in rural, isolated, or insular areas where market forces alone make deployment economically unviable." The Schools and Libraries Program (E-Rate) provides discounts for K-12 broadband and internal networking. The Rural Health Care Program subsidizes service "for rural clinics, public health departments, and mental health centers to facilitate telemedicine." Lifeline "[p]rovides monthly subsidies to make voice and broadband services affordable for low-income households."

The report does not describe how the USF is financed beyond noting that it rests on "mandatory industry contributions" and, seventeen pages later, that "consumers ultimately bear Universal Service Fund contributions through fees on their telecommunications bills." The mechanics:

• Where the money comes from. The USF receives no congressional appropriations. Instead, telecommunications carriers pay a percentage of their interstate and international revenue from traditional voice service and interconnected internet-based calling—long-distance and international calling, the voice and texting portion of wireless plans, and business phone lines. Broadband internet service is not assessed: the FCC classifies broadband as an "information service," which falls outside the contribution base. Neither is in-state calling, which states assess separately. The FCC sets the percentage—the contribution factor—quarterly. The contribution factor stands at 38.8 percent for the third quarter of 2026, the highest in the Fund's history (compared to 17.9 percent in the second quarter of 2016). Carriers are not required to pass the charge to customers, but many do, as the "Universal Service" line item on a phone bill. The result is a Universal Service Fund that pays almost entirely for broadband while collecting almost entirely from phone service—and from a base that shrinks as customers drop landlines and long-distance service.

One-time federal capital, "such as the deployment portion of the $42.5 billion Broadband Equity Access and Deployment (BEAD) Program," is "built to deploy physical infrastructure," the report notes, but does "not fund the long-term operational costs, network maintenance, or disaster recovery required to keep remote networks functional over time." Universal service, the report argues, "remains the nation's primary vehicle for closing the digital divide."

Destination or Continuing Responsibility?

The report presents this problem as a binary choice between a discrete, achievable goal and an ongoing commitment to a principle.

Viewed as a destination, "policymakers may focus primarily on achieving specific deployment, adoption, or affordability goals. For example, once policymakers determine that nearly all students have broadband access, the policy objective may be viewed as largely complete." 

Viewed as a continuing responsibility, policymakers "may instead focus on maintaining networks, funding mechanisms, and governance structures that can adapt to changing technologies and evolving societal needs over time. Under this approach, achieving a particular benchmark is viewed not as the end point, but as one milestone in an ongoing commitment." 

The task force's participants "generally viewed the latter perspective as more consistent with the statutory mandate and historical evolution of universal service policy."

Six Core Principles

The heart of the report is a set of six principles, each paired with a short list of steps to advance each principle.

1. Preserve universal service as an enduring national commitment

Universal service "should continue to be viewed as an ongoing national responsibility rather than a one-time deployment objective." Capital injections like BEAD do not cover "hardware replacement needed to keep networks functional over time."

To advance this principle, policymakers should: preserve the enduring national commitment; recognize that universal service "requires ongoing adaptation rather than a fixed end point"; continue evaluating universal service in light of changing technologies and societal needs; and preserve the flexibility to keep universal service relevant over time.

2. Strengthen the legal and institutional durability of universal service 

Long-term success "depends upon governance structures that are legally durable, institutionally stable, and capable of adapting." Congress "should continue to reinforce the enduring statutory framework and authority governing universal service—as recently upheld by the Supreme Court in FCC v. Consumers Research—while preserving sufficient flexibility for the FCC to implement and modernize the programs." In that 2025 decision, the Supreme Court held 6-3 that the Fund's contribution mechanism does not violate the nondelegation doctrine. The report notes that Consumers' Research has since filed a new challenge in the Fifth Circuit; that case was argued August 5, 2026.

To advance this principle, policymakers should: reinforce the long-term statutory foundation; clarify statutory principles and institutional roles "where appropriate"; preserve the FCC's flexibility to implement and modernize within the statutory framework; and maintain governance structures promoting "legal certainty, political durability, and institutional stability."

3. Ensure long-term funding stability and sustainability

Universal service "requires robust funding mechanisms that provide predictability, stability, and long-term financial sustainability." The report states that "stakeholders emphasized that the $8+ billion fund must preserve its non-appropriated structure—a dedicated funding mechanism established by Section 254 of the Communications Act that operates outside the annual appropriations process and is supported through mandatory industry contributions." A non-appropriated mechanism, it argues, "insulates vital connectivity infrastructure from the volatility of federal budget showdowns, political gridlock, and government shutdowns."

To advance this principle, policymakers should: preserve stable and predictable funding mechanisms; avoid reliance on annual appropriations for ongoing universal service support; evaluate funding reforms using "affordability, sustainability, predictability, administrative simplicity, technological neutrality, and minimizing regressivity"; and continue pursuing approaches supporting long-term planning and investment. "Minimizing regressivity" refers to who ultimately bears the cost. Contributions are assessed as a percentage of carriers' interstate and international end-user telecommunications revenues, and carriers are permitted to pass the charge through to customers as a line item on their bills. Because that charge is a flat percentage of the assessable portion of a bill rather than a function of income, it takes a larger share of income from lower-income households than from higher-income ones, including from many of the same households Lifeline exists to serve. 

4. Modernize affordability policies to promote meaningful adoption 

"Access, affordability, and adoption are the foundational objectives of universal service policy." Task force participants "generally agreed that the current Lifeline program should be modernized to better reflect today's broadband marketplace and affordability realities." The report is explicit that "participants expressed differing views regarding specific policy approaches," but that "there was broad agreement that affordability should remain a central focus."

To advance this principle, policymakers should: preserve affordability as a core objective; modernize affordability programs "to better reflect current broadband realities"; continue supporting policies that promote meaningful broadband adoption; and evaluate affordability policies "in light of evolving consumer needs and communications markets."

5. Improve program administration, accountability, and public trust 

"Effective administration, transparency, and responsible stewardship are essential to maintaining public confidence." Modernization "should improve administrative efficiency while preserving strong oversight and accountability," and should "reduce unnecessary administrative burdens, strengthen program integrity, improve transparency, and support continuous improvements."

The report highlights USAC's Open Data Portal—covering 100,000+ schools, 9,000+ clinics, and 8.1 million Lifeline households—as a foundation to build on, calling for "granular, real-time mapping dashboards that overlay USF allocations directly onto localized broadband adoption indices."

To advance this principle, policymakers should: simplify program administration "while maintaining appropriate safeguards"; strengthen oversight, transparency, and stewardship; improve performance measurement and public reporting; and modernize administrative processes "through improved data, technology, and interagency coordination."

6. Prepare universal service for future communications needs

Programs "must remain capable of dynamically responding to evolving communications technologies, escalating cybersecurity risks, network resilience requirements, and changing consumer expectations." The report points to the FCC's "$200 million Schools and Libraries Cybersecurity Pilot Program" as an example, and argues that as severe weather increasingly threatens physical connectivity, USF programs "must institutionalize rapid-response frameworks—similar to the emergency rule waivers deployed during Hurricanes Helene and Milton—in order to guarantee immediate funding flexibility for network repair and disaster recovery." Modernization should shift the framework "away from legacy, rigid technology definitions" and instead "permanently fund end-to-end network hardening, next-generation firewall protection, and gigabit-speed capabilities."

To advance this principle, policymakers should: strengthen cybersecurity and institutional resilience; preserve flexibility to respond to emerging technologies; support continuous modernization of program administration; and "[e]valuate future reforms using evidence, measurable outcomes, and ongoing assessment."

One-Time Appropriations or Permanent Funding?

The report's case for preserving the Universal Service Fund's non-appropriated structure rests largely on a single example. The $14.2 billion Affordable Connectivity Program (ACP), "[e]stablished via a one-time congressional appropriation in the 2021 Bipartisan Infrastructure Law," connected "over 23 million low-income households" before exhausting its funds. Task force participants treated the resulting cliff as "a cautionary tale": one-time appropriations are "highly effective for rapid capital injections" but "ill-suited for long-term affordability." Targeted appropriations, the report concludes, "should only be used as a supplement to, rather than a replacement for," the non-appropriated USF baseline. 

The report does not carry the example forward into its principles. Core Principle 4 commits to modernizing Lifeline without naming a mechanism or benefit level, and does not mention ACP. Proposals to establish an ACP-like program within the Fund, or to apply ACP's design lessons to Lifeline, appear only as the views of "some participants." 

Action Items for Congress and the FCC

The report sets out a governance model in which "Congress establishes the enduring mission, statutory objectives, and institutional framework for universal service, and the FCC retains sufficient flexibility to administer, implement, and modernize the programs." 

Matters identified as appropriate for congressional direction include the enduring mission and objectives of universal service; the statutory scope and purpose of the USF; the contribution methodology "and identification of new types of contributors not authorized by statute"; the overall governance structure; long-term funding architecture; the circumstances under which new programs may be established or existing programs significantly expanded; the statutory framework governing eligible services; and periodic review of statutory objectives. 

Matters identified as appropriate for continued FCC implementation and discretion include determining eligible services; program implementation and administration; administrative and application simplification; establishing and updating cybersecurity requirements; establishing and updating network resilience requirements; updating program requirements and technical standards; measuring performance and collecting data; updating broadband performance metrics; and establishing enforcement mechanisms and administrative remedies. 

Task force participants cautioned that "excessive statutory specificity, while providing certainty in some respects, may also reduce the flexibility needed to modernize programs." 

Contribution Methodology 

Participants "devoted significant discussion as to whether the Communications Act provides the FCC with sufficient authority to adopt a fundamentally new Universal Service Fund contribution methodology under existing law. The Task Force did not reach consensus, and participants expressed differing views regarding the scope of the Commission's authority." 

Nonetheless, "broader agreement found that successive administrations were unable to achieve comprehensive contribution reform through the regulatory process alone... As a result, the Task Force concludes that fundamental changes to the contribution methodology are best addressed by Congress through legislation."

Where the Task Force Reached Consensus—and Where It Didn't

The report uses graduated vocabulary. "Broad agreement" and "participants generally agreed" mark the strongest claims; "some consensus," "several participants," and "some participants" mark weaker ones. Here we highlight the broader consensus. 

Reported as broad agreement:

• Annual appropriations "would not provide the predictability needed for programs that depend upon ongoing support and multi-year planning." 
• The four programs function as "an interconnected ecosystem," and long-term success "depends on maintaining the strength and effectiveness of all four programs." 
• Affordability "remains a central component of the universal service mission," even though "participants did not converge on specific policy reforms." 
• Performance expectations "must continue to evolve with technology and consumer use so that publicly supported infrastructure does not become outdated before it is fully deployed"—with the report specifically declining to treat the FCC's current 100 Mbps download/20 Mbps upload standard as a fixed parameter.
• Cybersecurity "deserves greater attention within the universal service ecosystem," though "[p]articipants did not converge on a preferred implementation model or funding architecture." The report cites the FBI's Internet Crime Complaint Center data, noting that cybercrime losses "surpassed $2.9 billion, representing a dramatic 26% surge year-over-year," with complaint volume exceeding one million for the first time.
• Administrative effectiveness and program integrity are "complementary rather than competing objectives." 

Explicitly unresolved: the scope of FCC authority over contribution reform; specific contribution methodologies, contributor categories, and burden allocations; specific affordability mechanisms; cybersecurity implementation models; and whether outcome-based metrics such as educational and health outcomes are measurable enough to be useful, with some members supporting them and "[o]thers caution[ing] that such outcomes may be difficult to measure." 

Looking Ahead

The report identifies issues the task force flagged for further work rather than resolution: digital literacy and adoption support; device availability and affordability; cybersecurity implementation models; "[t]he operational implications of artificial intelligence and other emerging technologies"; shared services and regional support models; improved coordination across federal connectivity programs; and "[e]volving definitions of meaningful connectivity." 

The report closes on its organizing frame: "the future of universal service is not defined by choosing between stability and change. Rather, its long-term success will depend upon preserving the nation's enduring commitment to universal connectivity while ensuring that the institutions, policies, and programs supporting that commitment continue to evolve alongside changing technologies, communications markets, and the needs of the American people." 

"Moving Toward Opportunity for All: The Future of Universal Service Reform" is published by Keep Our Communities Connected and the Schools, Health and Libraries Broadband Coalition, a project of InnovateEDU. Task force co-chair Mignon Clyburn serves on the Benton Institute's board. The Benton Institute and the SHLB Coalition are both intervenors supporting the FCC in Consumers' Research v. FCC, No. 25-60535 (5th Cir.)​

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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