RECOVERY ACT

Broadband Programs 

Are Ongoing, and 

Agencies’ Efforts 

Would Benefit from 

Improved Data Quality

Report to Congressional Committees

September 2012

GAO-12-937

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-937, a report to 

congressional committees

September 2012

RECOVERY ACT

Broadband Programs Are Ongoing, and Agencies’ 

Efforts Would Benefit from Improved Data Quality

Why GAO Did This Study

Access to affordable broadband 

service is seen as vital to economic 

growth and improved quality of life, yet 

residents in many areas of the country 

lack access to or do not use 

broadband. To extend broadband 

access and adoption, the American 

Recovery and Reinvestment Act of 

2009 (Recovery Act) provided over $7 

billion to NTIA and RUS for grants or 

loans to support broadband projects. 

NTIA and RUS made all awards by 

September 30, 2010.

This report responds to mandates 

under the Recovery Act for GAO to 

examine the use of Recovery Act funds 

and report on the quarterly estimates 

of jobs funded. This report addresses 

(1) the progress of broadband projects, 

(2) their effect on expanding access to 

and adoption of broadband, and (3) 

any challenges awardees face in 

completing projects and agency 

actions to address these challenges. 

GAO analyzed program documentation 

and data and interviewed agency 

officials and BTOP and BIP awardees. 

What GAO Recommends

To ensure RUS is collecting reliable 

information regarding the effect of its 

investments in broadband, GAO 

recommends that RUS take steps to 

improve the quality of its data on the

number of fiber miles and wireless 

access points created by BIP projects. 

RUS disagreed with GAO’s 

characterization that it does not collect 

adequate data, and stated it has 

already taken steps to improve data 

quality. GAO believes that more 

reliable data will permit RUS to better 

assess the progress of the BIP 

program. 

What GAO Found

The progress of the broadband projects is difficult to measure because of data 

limitations. As projects progress, the National Telecommunications and 

Information Administration (NTIA) and the Rural Utilities Service (RUS) disburse 

awarded funds to projects on, for example, a reimbursement basis. As of July 

2012, NTIA has disbursed approximately $1.9 billion of the $3.8 billion it awarded 

for projects under the Broadband Technology Opportunities Program (BTOP), 

and as of June 2012, RUS has disbursed approximately $1 billion of the $3.3 

billion it awarded for projects under the Broadband Initiatives Program (BIP). 

These disbursements are one measure of progress, and the disbursements 

indicate that the projects in aggregate are less than half complete. However, 

disbursements sometimes lag behind actual progress for a number of reasons, 

such as contracts that provide for payment after work is completed. In addition, 

the agencies have been inconsistent in collecting non-financial data on project 

progress. While NTIA has collected data on BTOP projects, RUS did not collect 

data until recently. According to NTIA data, 76 percent of planned network miles 

are complete. According to RUS, the data it has recently collected are not 

reliable measures of fiber miles and wireless access points deployed by BIP 

projects. Without reliable information on the progress of BIP projects in 

expanding infrastructure, RUS may struggle to demonstrate the progress and 

effectiveness of the BIP program. 

Data limitations make it difficult to fully measure the effect of BTOP and BIP on 

expanding access to and adoption of broadband. NTIA’s non-financial data 

indicate that BTOP awardees have established over 57,000 new or upgraded 

network miles, with connections to over 8,000 community anchor institutions, 

such as schools, libraries, and hospitals, and nearly 34,000 new computer 

workstations for use in public computer centers, such as libraries. RUS initially 

did not collect comparable non-financial data for BIP projects, and the data it has 

are not reliable; therefore, it is not possible to fully assess the effect of BIP on 

expanding access to broadband. With respect to broadband adoption, however, 

both NTIA and RUS have faced difficulties collecting reliable data from awardees 

on subscribership for BTOP and BIP projects. Both agencies have taken steps to 

address this issue, with NTIA providing guidance to awardees and RUS 

developing a tool for staff reviews of subscribership data reported by awardees.

Both NTIA and RUS helped awardees address multiple challenges in completing 

their broadband projects. Specifically, awardees identified challenges complying 

with regulations and obtaining permits, as well as handling construction-related 

issues such as broadband fiber shortages. BTOP’s non-infrastructure projects—

which provide computers to libraries or encourage broadband adoption—faced a

different set of challenges, including staffing, contracting, and procurement. NTIA 

and RUS have taken a number of actions—including providing regular contact 

and expertise, webinars, and guidance—to help awardees address these 

challenges. In addition, RUS hired additional staff to address delays in its review 

and approval of contracts, a challenge that delayed some BIP projects. View GAO-12-937. For more information, 

contact Mark L. Goldstein at (202) 512-2834 

or goldsteinm@gao.gov.
Page i GAO-12-937 Recovery Act

Letter 1 

Background 4

The Progress of Recovery Act Broadband Projects Is Difficult to 

Measure because of Data Limitations 8

NTIA Has Expanded Access to Broadband through BTOP Projects; 

However, Data Limitations Make it Difficult to Measure the 

Effects of BTOP and BIP on Broadband Adoption 12

NTIA and RUS Have Acted to Address the Variety of Challenges 

Awardees Identified in Completing Projects 17

Conclusions 23

Recommendation for Executive Action 24

Agency Comments and Our Evaluation 24

Appendix I Scope and Methodology 26

Appendix II Analysis of Employment Data Submitted by Program Awardees 29

Appendix III Comments from the Department of Agriculture 32

Appendix IV GAO Contact and Staff Acknowledgments 40

Tables

Table 1: Summary of Recovery Act Broadband Programs, as of 

June and July 2012 5

Table 2: Deadlines for BTOP Projects 7

Table 3: Distribution of BTOP and BIP Awardees by the Percentage 

of Project Funding Disbursed, as of June and July 2012 10

Table 4: BTOP Infrastructure Expansion, as of March 31, 2012 13

Table 5: Challenges Faced by BTOP and BIP Awardees 18

Contents
Page ii GAO-12-937 Recovery Act

Figures

Figure 1: Amount of Awarded Program Funds Disbursed to Current 

BTOP and BIP Awardees, and Remaining Program Funds, 

as of June and July 2012 9

Figure 2: Example of an Accessible Workstation, with Desktop 

Magnifier. 15

Figure 3: FTEs Reported by BTOP and BIP Recipients, January 

2010 through June 2012 31

Abbreviations

BIP Broadband Initiatives Program 

BTOP Broadband Technology Opportunities Program 

CCI Comprehensive Community Infrastructure 

FCC Federal Communications Commission 

FPO Federal Program Officer 

GFR General Field Representative 

FTE full-time equivalent 

NTIA National Telecommunications and Information

 Administration 

OMB Office of Management and Budget 

PCC public computer center 

Recovery Act American Recovery and Reinvestment Act of 2009

RUS Rural Utilities Service 

SBA sustainable broadband adoption

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Page 1 GAO-12-937 Recovery Act

United States Government Accountability Office 

Washington, DC 20548

September 14, 2012

The Honorable John D. Rockefeller IV

Chairman

The Honorable Kay Bailey Hutchison

Ranking Member 

Committee on Commerce, Science, and Transportation

United States Senate

The Honorable Fred Upton

Chairman

The Honorable Henry A. Waxman

Ranking Member 

Committee on Energy and Commerce

House of Representatives

Access to affordable broadband telecommunications1

To extend access to broadband throughout the United States, as well as 

to stimulate the economy and create jobs, Congress appropriated $7.2 

billion for broadband programs under the American Recovery and 

is increasingly 

viewed as vital to long-term economic growth and improved quality of life, 

just as electricity, telephone, and the interstate highway system filled 

similar roles in previous generations. The ability to share large amounts of 

information at ever-greater speeds increases productivity, facilitates 

commerce, and drives innovation. Furthermore, broadband can improve 

citizens’ quality of life. For example, broadband technology makes it 

possible for a patient to visit a local clinic and receive medical attention 

from specialists hundreds of miles away, for a student to access 

information not available from the local library, and for a firefighter to 

download blueprints of a burning building. Broadband is particularly 

critical in rural areas, where advanced communications can reduce the 

isolation of remote communities and individuals.

 

1

The term broadband commonly refers to high speed Internet access. GAO, 

Telecommunications: Broadband Deployment Is Extensive throughout the United States, 

but It Is Difficult to Assess the Extent of Deployment Gaps in Rural Areas, GAO-06-426

(Washington, D.C.: May 5, 2006).

 
 

Page 2 GAO-12-937 Recovery Act

Reinvestment Act of 2009 (Recovery Act), enacted on February 17, 

2009.2

• $4.7 billion for the Department of Commerce’s National 

Telecommunications and Information Administration (NTIA) to create the 

Broadband Technology Opportunities Program (BTOP) to award 

competitive grants to a variety of entities for broadband infrastructure, 

public computer centers, and innovative projects to stimulate demand for 

and adoption of broadband.

This $7.2 billion included:

3

• $2.5 billion for the Department of Agriculture’s Rural Utilities Service 

(RUS) for the Broadband Initiatives Program (BIP) to provide loans, 

grants, and loan/grant combinations for broadband infrastructure projects 

primarily in rural areas.4

The agencies made all awards by September 30, 2010. As of July 2012, 

there were 225 BTOP awards comprising $3.8 billion in awarded funds.

 

5

As of June 2012, there were 263 BIP projects comprising $3.3 billion in 

awarded funds.6

 

2

Pub. L. No. 111-5, 123 Stat. 115 (2009). 

 

3

Of the $4.7 billion provided to NTIA, approximately $293 million was used to fund 56 

grants to states and territories for the purposes of gathering broadband data in order to 

develop and maintain a nationwide map on the availability of broadband service, with 

some funds to be transferred to the Federal Communications Commission for the 

development of the national broadband plan. These activities are not included in our 

review. Recovery Act, 123 Stat., 128 and div. A, title VI, 123 Stat., 512, codified at 47 

U.S.C. § 1305.

4

Recovery Act, div. A, title I, 123 Stat., 118-119.

5

Several factors contribute to the discrepancy between the funds appropriated for BTOP 

and the funds awarded. On August 10, 2010, Congress rescinded $302 million from 

BTOP, reducing the program’s funding to approximately $4.4 billion. See Pub. L. No. 111-

226, § 302, 124 Stat. 2389, 2404. NTIA also terminated one award, had one awardee not 

accept an award, and four awardees terminate their project voluntarily.

6

The amount of funds awarded by RUS exceeds its appropriation because RUS can 

award and obligate funds in excess of its budget authority through the use of loans. For 

grants, the face amount of each grant is charged against RUS budget authority. However, 

the Federal Credit Reform Act of 1990, Pub. L. No. 101-508, div. A, title XIII, § 13201(a), 

104 Stat. 1388-609, codified at 2 U.S.C. ch. 17A, subch. III, requires RUS to account for 

the budgetary impact of loans by estimating the expected net loss (or gain) of loans. This 

net amount, which is estimated by calculating the net present value of all cash flows to 

and from RUS over the lifetime of the loans, is referred to as the subsidy cost of the loans. 

RUS must charge the subsidy cost of loans to its budget authority. In addition, as of June 

2012, RUS had terminated 38 BIP awards. 
 

Page 3 GAO-12-937 Recovery Act

Nearly 2 years have passed since all BTOP and BIP Recovery Act 

awards were made; thus, this review provides an opportunity to assess 

the status of the projects. This report is part of GAO’s ongoing efforts to 

monitor Recovery Act programs and builds on our prior reports reviewing 

BTOP and BIP.

7 In particular, we examined: (1) What progress has been 

made implementing broadband projects funded by the Recovery Act? (2) 

What effect, if any, have these projects had on expanding access to and 

adoption of broadband service? (3) What challenges, if any, do grant and 

loan recipients face in completing broadband projects and what actions

have the agencies taken to help address these challenges? The 

information provided in this report and in appendix II responds to two 

recurring mandates in the Recovery Act. The first, which we respond to 

as part of this report, requires that we review bimonthly, the use of 

Recovery Act funds by recipients.8 The second, which we respond to in 

appendix II, requires us to comment and report quarterly on estimates of 

jobs funded and counted as full-time equivalents (FTE), as reported by 

recipients of Recovery Act funds.9

To address our objectives, we reviewed program data collected by NTIA 

and RUS, interviewed agency officials and program awardees, and

reviewed relevant documentation. Specifically, to determine the progress 

made implementing broadband projects, we analyzed the data collected 

by NTIA and RUS on the total funding awarded and the amount of funds 

disbursed to each project. We also reviewed NTIA’s data on the progress 

made in meeting BTOP’s program targets related to deploying 

 

 

7

GAO, Recovery Act: Broadband Program Awards and Risks to Oversight, GAO-11-371T

(Washington, D.C.: Feb. 10, 2011); Recovery Act: Further Opportunities Exist to 

Strengthen Oversight of Broadband Stimulus Programs, GAO-10-823 (Washington, D.C.: 

Aug. 4, 2010); and Recovery Act: Agencies Are Addressing Broadband Program 

Challenges, but Actions Are Needed to Improve Implementation, GAO-10-80

(Washington, D.C.: Nov. 16, 2009).

8

Recovery Act, div. A, title IX, § 901, 123 Stat.,191. Updates on GAO’s oversight of 

Recovery Act funds can be found at: http://gao.gov/recovery. As of July 20, 2012, the 

Department of the Treasury had paid out $255.2 billion in Recovery Act funds for use in 

states and localities.

9

Recovery Act, div. A, title XV, § 1512(e), 123 Stat., 287. FTE data provide insight into the 

use and impact of the Recovery Act funds, but recipient reports cover only direct jobs 

funded by the Recovery Act. These reports do not include the employment impact on 

suppliers (indirect jobs) or on the local community (induced jobs). Both data reported by 

recipients and other macroeconomic data and methods are necessary to understand the 

overall employment effects of the Recovery Act. 
 

Page 4 GAO-12-937 Recovery Act

infrastructure; RUS did not collect comparable data until recently, and 

could not assure the quality of its data. To assess the effect of the 

projects on expanding access to and adoption of broadband service, we 

analyzed the data reported by BTOP awardees on the number of network 

miles deployed (which can include miles of broadband fiber and non-fiber 

miles, such as microwave links), institutions connected, computer 

workstations installed in public computer centers, and broadband 

subscribers. We also interviewed BTOP and BIP awardees to understand 

the effects of their individual projects; we selected awardees to interview 

that varied in progress (gauged by the percentage of their total award that 

had been disbursed), and that were geographically dispersed. We also 

selected awardees who received large awards. To determine the 

challenges that grant and loan recipients face in completing projects, we 

interviewed NTIA and RUS officials, as well as BTOP and BIP awardees. 

We also reviewed BTOP awardees’ progress reports for the first quarter 

of 2012, in which awardees noted challenges or issues they were facing 

in achieving planned progress. For BIP, we reviewed a tracking 

spreadsheet maintained by RUS where agency officials note the status of 

each BIP project and, in some cases, would note issues or challenges 

facing individual projects. To determine the reliability of the data used in 

this report, we reviewed relevant documentation, including manuals, 

guidance, and forms provided to awardees reporting the data, 

descriptions of internal controls, and Inspector General reviews of the 

data from the Department of Agriculture and the Department of the 

Treasury (which manages the payment system used by BTOP recipients). 

We also interviewed agency officials about their processes for reviewing 

the data and ensuring their accuracy. We found the data generally 

reliable for our purposes and note the limitations of the data where 

appropriate. For more information on our scope and methodology, see 

appendix I.

We conducted this performance audit from November 2011 through 

September 2012 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.

In addition to being administered by different agencies, BTOP and BIP 

differ in several ways, including in methods for providing funding to 

awardees, types of awardees funded, and services funded through the 

Background
 

Page 5 GAO-12-937 Recovery Act

programs. NTIA funded a range of organizations from states and 

municipalities to non-profit and commercial organizations, whereas RUS 

made BIP loans, grants, and combinations of loans and grants primarily 

to private-sector entities, including for-profit companies and cooperatives. 

In addition to funding infrastructure projects, BTOP funded public 

computer center (PCC) projects and sustainable broadband adoption 

(SBA) projects. Also, the vast majority of BTOP’s infrastructure awards 

were investments in “middle-mile” infrastructure projects, which provide a 

link from the Internet backbone to the last mile networks of local providers 

(such as cable or phone companies) that provide broadband service to 

end users. The availability of broadband service to end users depends 

upon access to adequate middle-mile facilities, which can be costly to 

deploy in rural areas. In contrast, BIP primarily funded “last-mile” 

infrastructure projects that provide service directly to end users. Table 1 

provides more detail about the BTOP and BIP programs, including the 

current number of projects and the amount of funding they represent.

Table 1: Summary of Recovery Act Broadband Programs, as of June and July 2012

Program Project category

Number

of 

projects a

Total 

program 

funds Description

BTOP Comprehensive community 

infrastructure 

117 $3.4 billion Deploy broadband infrastructure. NTIA primarily funded 

middle-mile projects, which do not provide service to end 

users (such as households and businesses), but instead 

provide a link from the Internet backbone to the networks of 

local service providers, such as cable or phone companies. 

The projects also provide new or upgraded connections to 

community anchor institutions, such as schools, libraries, 

colleges and universities, medical and healthcare 

providers, public safety entities, and other community 

support organizations. Seven of these awards fund projects 

that intend to use the 700 MHz spectrum to deploy public 

safety broadband systems.b

 

Public computer center 65 $200 million Expand public access to broadband service and enhance 

broadband capacity at entities such as community colleges 

and public libraries. Awardees also provide classes at 

these entities, in which citizens can receive training on 

topics such as online job searching, basic computer and 

Internet skills, and certification and educational courses.

Sustainable broadband 

adoption 

43 $250 million Increase Internet use and broadband subscribership 

among individuals and businesses. Projects may include 

digital literacy training and outreach campaigns to increase 

the relevance of broadband in people’s everyday lives.
 

Page 6 GAO-12-937 Recovery Act

Program Project category

Number

of 

projects a

Total 

program 

funds Description

BIP Infrastructure and satellite 263 $3.3 billion Deploy infrastructure in rural areas, with an emphasis on 

last-mile infrastructure. A last-mile project is defined as any 

project that provides service to end users or end-users’ 

devices. Four of these awards fund satellite broadband 

projects, which offer satellite broadband connections to 

users in rural locations where terrestrial broadband 

services are not available. Twelve awards funded middlemile projects.

Source: GAO analysis of NTIA (as of July 2012) and RUS (as of June 2012) data. 

Note: Canceled projects removed from totals. 

a

We excluded certain activities funded under BTOP and BIP, such broadband mapping projects and 

funds transferred to FCC for the national broadband plan under BTOP and technical assistance 

projects funded under BIP. 

b

In February 2012, Congress enacted the Middle Class Tax Relief and Job Creation Act of 2012, Pub. 

L. No. 112-96, § 6002, 126 Stat 156, 203 (2012), codified at 47 U.S.C. § 1422, which contained 

provisions to create a nationwide interoperable public safety broadband network, with one entity 

holding the license for the 700 MHz spectrum. In light of this development, NTIA partially suspended 

the seven BTOP-funded 700 MHz public safety projects to ensure that they proceed in a manner that 

supports development of the nationwide, interoperable network. 

NTIA and RUS solicited applications to the programs and made awards in 

two rounds, with the first funding round beginning in June 2009 and 

ending in April 2010, and the second round beginning in January 2010 

and ending in September 2010. In the joint Notice of Funds Availability, 

NTIA and RUS provided that projects should be substantially complete 

within 2 years of receiving an award. The agencies disburse awarded 

funds as projects progress. To meet the substantially complete 

requirement, a project must receive two-thirds of its award 2 years after 

receiving the award.10

 

1074 Fed. Reg. 33104, 33110 (2009).

NTIA and RUS also provided that projects should 

be complete within 3 years of receiving an award. In October 2011, RUS 

modified these requirements to provide that BIP projects must commence 

within 180 days of the latter of the completion of the project’s historic 

preservation or environmental review, and be fully complete no later than 

June 30, 2015. NTIA maintained the original requirements. Since NTIA 

made several rounds of awards, the 3-year completion deadlines for the 

projects are staggered throughout 2012 and 2013. Table 2 shows the 

various deadlines, and the number of BTOP projects subject to that 

deadline. 
 

Page 7 GAO-12-937 Recovery Act

Table 2: Deadlines for BTOP Projects

Deadline

Total award value 

(in millions)

Number of BTOP projects subject to deadline

Comprehensive community 

infrastructure

Public computer 

center

Sustainable broadband 

adoption Total

November 2012 $64 2 4 2 8 

December 2012 $71 2 2 1 5 

January 2013 $533 24 11 3 38

February 2013 $212 7 3 6 16

March 2013 $110 5 0 1 6 

June 2013 $440 18 11 0 29

July 2013 $1,463 43 15 9 67

August 2013 $864 16 12 14 42

September 2013 $46 0 7 7 14

Total $3,803 117 65 43 225

Source: GAO analysis of NTIA data.

Note: Canceled projects removed from totals. April and May 2013 are not included because none of 

the BTOP projects have a deadline occurring in those months. 

NTIA and RUS must oversee BTOP and BIP projects, respectively, 

through each program’s completion. NTIA and RUS both have officials 

monitoring the overall progress of the programs and reviewing requests 

for funds. In addition to these officials, the agencies also provided staff to 

serve as the primary point-of-contact for their awardees and answer 

questions and address issues that arise for specific awardees. NTIA’s 

Federal Program Officers (FPO) provide this assistance to BTOP 

awardees; RUS’s General Field Representatives (GFR) serve the same 

role for BIP awardees. In addition, BTOP and BIP awardees face a 

variety of reporting requirements. For example, the Recovery Act requires 

fund recipients, including BTOP and BIP awardees, to submit quarterly 

reports that provide a description of their projects or activities, the 

progress of their projects, and estimates of the number of resulting jobs 
 

Page 8 GAO-12-937 Recovery Act

funded, measured on a FTE basis.

11 NTIA also requires that BTOP 

awardees submit quarterly and annual progress reports to the agency 

that provide financial data and information on the projects’ status and 

effects. RUS requires that BIP awardees submit quarterly reports that 

provide subscribership data, and according to RUS, these efforts also 

include financial statements consisting of income statements, balance 

sheets, and cash flow statements. 

NTIA and RUS both use the amount of funds disbursed to awardees as 

one method of tracking progress, and less than half of all the awarded 

funding has been disbursed to Recovery Act BTOP and BIP awardees. 

BTOP awardees appear to have made more progress than BIP 

awardees, as NTIA has disbursed half of BTOP’s funds while RUS has 

disbursed less than one-third of BIP’s funds. However, the agencies 

disburse awarded funds for projects as payment becomes due, 

sometimes only as contracts are complete. Because disbursements do 

not fully reflect the amount of work completed, NTIA has established 

other non-financial indicators of progress, such as network miles 

deployed. In contrast, RUS did not initially establish indicators to measure 

the deployment of infrastructure. 

As awardees implement their projects, they request funds from the 

agency administering their award. NTIA and RUS track how much of each 

project’s award that they have disbursed to the awardee, which serves as 

one indicator of progress. The data that NTIA and RUS collect indicate 

that the agencies have disbursed less than half of all awarded funds. Of 

the roughly $3.8 billion available for the BTOP projects, NTIA has 

disbursed approximately $1.9 billion (50 percent) to its awardees. As 

noted in figure 1, disbursements to NTIA’s infrastructure projects 

 

11Pub. L. No. 111-5, § 1512(e), 123 Stat. 115, 288. FTE data provide insight into the use 

and impact of the Recovery Act funds, but recipient reports cover only direct jobs funded 

by the Recovery Act. These reports do not include the employment impact on suppliers 

(indirect jobs) or on the local community (induced jobs). Both data reported by recipients 

and other macroeconomic data and methods are necessary to understand the overall 

employment effects of the Recovery Act. OMB defines FTEs as the total number of hours 

worked and funded by Recovery Act dollars within the reporting quarter divided by the 

quarterly hours in a full-time schedule. OMB Memorandum, M-10-08, Updated Guidance 

on the American Recovery and Reinvestment Act – Data Quality, Non-Reporting 

Recipients, and Reporting of Job Estimates (Dec. 18, 2009). 

The Progress of 

Recovery Act 

Broadband Projects Is 

Difficult to Measure

because of Data 

Limitations

Amount of Funding 

Disbursed as an Indicator 

of Progress
 

Page 9 GAO-12-937 Recovery Act

comprise $1.6 billion of BTOP’s disbursed funds, while disbursements to 

public computer center and sustainable broadband adoption projects total 

$290 million. Of the roughly $3.3 billion available for the BIP projects, 

RUS has disbursed approximately $1 billion (30 percent) to its awardees. 

Figure 1: Amount of Awarded Program Funds Disbursed to Current BTOP and BIP 

Awardees, and Remaining Program Funds, as of June and July 2012

Note: Canceled projects removed from totals. 

 

Our analysis of the disbursements indicates that BTOP awardees have 

made more progress than BIP awardees. Sixty-eight percent of BTOP 

awardees have received more than half of their awarded funds, versus 24 

percent of BIP awardees. The fact that the BTOP program includes noninfrastructure projects, such as public computer center and sustainable 

broadband adoption projects, may partially explain this disparity; NTIA 

officials noted that since most of these non-infrastructure projects are not 

required to undergo an environmental assessment, they tend to progress 

more quickly than the infrastructure projects. See table 3. 
 

Page 10 GAO-12-937 Recovery Act

Table 3: Distribution of BTOP and BIP Awardees by the Percentage of Project Funding Disbursed, as of June and July 2012

Percent of project funding disbursed

BTOP BIP

No. of 

awardees

Percentage of 

awardees

No. of 

awardees

Percentage of 

awardees

0% 2 1% 15 6%

Greater than 0% to 25% 15 7% 132 50%

Greater than 25% to 50% 55 24% 52 20%

Greater than 50% to 75% 89 40% 27 10%

Greater than 75% to less than 100% 59 26% 30 11%

100% 5 2% 7 3%

Total 225 100% 263 100%

Source: GAO analysis of NTIA (as of July 2012) and RUS (as of June 2012) data. 

Note: Canceled projects removed from totals. 

Of the BTOP projects that have reached the 2-year target to be 

substantially complete, more than half have received two-thirds of their 

total award. As previously mentioned, NTIA provided that BTOP projects 

should receive two-thirds of their total award within 2 years of receiving 

the award. There are 102 projects that started before August 2010 and 

thus have reached the two-thirds benchmark in terms of project time 

elapsed. Of these 102 projects, 61 have received two-thirds of their 

awarded funds as of July 2012. NTIA officials told us that in cases where

a project does not meet the two-thirds complete threshold, NTIA program 

officers follow up to determine whether the project is delayed, or whether 

disbursements are not reflecting the amount of work completed, as 

mentioned above. In these cases, program officers will conduct a handson review, which helps NTIA determine whether the project needs a 

performance improvement plan with specific actionable recommendations 

to get the project back on track. 

While disbursements are one measure of progress, officials from NTIA 

and RUS told us that disbursements do not fully reflect the amount of 

work completed. NTIA and RUS disburse awarded funds for projects as 

payment becomes due, sometimes only as contracts are completed. Thus 

disbursements do not fully reflect the amount of work completed at any 

point in time. NTIA officials noted that in some cases, awardees have 

entered into contracts that are structured so that the awardee does not 

pay the contractor until the bulk of construction is complete. For example, 

one awardee we interviewed noted that although the project was 95 

percent complete, it had only received 65 percent of the project’s funding, 

giving the incorrect impression that the project was behind schedule. In 
 

Page 11 GAO-12-937 Recovery Act

our review of BTOP awardees’ first quarter 2012 reports to NTIA, we 

found that some recipients cited this issue when reporting their financial 

progress in the quarterly reports. Others noted that cost savings made 

their disbursements appear as if the project were behind schedule, but 

that was not the case. In other words, a project that is on schedule but 

incurring costs below the levels anticipated in its original plan could 

appear to be behind schedule, since its disbursements will be lower than 

expected.

NTIA established other non-financial performance measures that show 

that awardees have made progress in implementing their projects. 

Specifically, NTIA established performance metrics for measuring BTOP’s 

progress against key performance indicators, such as the number of 

network miles deployed and leased, community anchor institutions 

connected, new workstations in public computer centers, and new 

broadband subscribers. NTIA established the baselines for these key 

performance indicators by aggregating the information awardees provided 

in their applications to the program, and provided program targets to the 

Office of Management and Budget (OMB).12

In contrast, RUS did not establish non-financial performance metrics for 

measuring BIP’s progress in deploying infrastructure, such as miles 

deployed.

NTIA tracks progress against 

these indicators and reports that as many as 76 percent of network miles

are complete and more than 97 percent of new workstations are 

complete. These results, when compared with the amount of funds 

disbursed, are consistent with NTIA’s statements that in some cases, 

disbursement of funds lags behind progress of projects.

13

 

12NTIA adjusted the projected benefits estimated in BTOP recipients’ initial applications. 

NTIA revised projections to reflect changes in the projects that occurred after awards were 

made, such as rerouting of planned broadband networks because of environmental issues 

or changes in partners. Total miles were reduced from 127,072 to 75,000, community 

anchor institutions connected were reduced from 29,557 to 15,000, new workstations 

were reduced from 35,334 to 35,000, and subscribers were reduced from 785,862 to 

500,000. NTIA officials told us they raised three of the projections to 110,000 miles, 

18,000 community anchor institutions, and 37,500 workstations.

RUS officials told us that because of RUS’s traditional role as 

a loan administrator, it tends to focus on ensuring that the funding is 

13RUS is collecting data on subscribers to show the effect of BIP on broadband adoption, 

which we discuss later in this report. However, we do not consider this a measure by 

which one can evaluate the progress of a project toward completion. 

Non-Financial Indicators 

of Progress
 

Page 12 GAO-12-937 Recovery Act

disbursed, the project is built, and the agency is repaid, instead of 

tracking project outcome information. In addition, the Recovery Act did 

not require RUS to collect performance metrics from awardees. 

Nevertheless, the Recovery Act sought to provide an unprecedented level 

of transparency with respect to how funds were being spent and program 

outcomes were being achieved, and we have noted the importance of 

collecting complete, accurate, and consistent data to document program 

performance. In June 2012, RUS officials told us that they began tracking 

the number of fiber miles and wireless access points deployed by BIP 

projects; however, they could not ensure the quality of the data at that 

time. Without reliable information on the progress of BIP projects in 

expanding infrastructure and moving toward completion of projects, RUS 

may not be able to demonstrate the progress and effectiveness of the BIP 

program.

NTIA collects data on network miles deployed, community anchor 

institutions connected, and workstations added at public computer 

centers, which helps illustrate that BTOP expanded broadband 

infrastructure and provided increased access to the public. As previously 

mentioned, RUS did not begin collecting this type of information until this 

year and cannot assure the quality of the data; thus, BIP’s contribution to 

these goals is less clear. Both NTIA and RUS face challenges in ensuring 

the quality of subscribership data, and therefore, it is difficult to measure 

the effect of BTOP and BIP on broadband adoption. 

As previously mentioned, the current goal of BTOP’s Comprehensive 

Community Infrastructure (CCI) projects is to deploy or upgrade 75,000 

miles of broadband infrastructure and provide broadband access to 

15,000 community anchor institutions, such as schools, libraries, health 

care providers, and public safety entities. As of March 31, 2012, BTOP’s 

117 infrastructure projects reported that they have established over 

57,000 new or upgraded network miles, with connections to over 8,000

community anchor institutions. See table 4. 

NTIA Has Expanded 

Access to Broadband 

through BTOP 

Projects; However, 

Data Limitations 

Make it Difficult to 

Measure the Effects 

of BTOP and BIP on 

Broadband Adoption

BTOP Expanded

Infrastructure and 

Provided Access at Public 

Computer Centers
 

Page 13 GAO-12-937 Recovery Act

Table 4: BTOP Infrastructure Expansion, as of March 31, 2012 

Miles

Network Miles Installed 14,192

Network Miles Leased 27,207

Existing Miles Upgraded 13,327

Existing Miles Leased 2,523

Total 57,249

Community Anchor Institutions

Institutions with New Access 2,420

Institutions with Improved Access 5,952

Total 8,372

Source: GAO analysis of NTIA data.

As shown in table 4, BTOP projects report several different types of miles 

of broadband infrastructure:

• “Network miles installed” includes newly constructed miles, such as new 

aerial or buried fiber, built using BTOP funds. 

• “Network miles leased” includes new network capacity acquired via lease 

using BTOP funds. 

• “Existing network miles upgraded” refers to existing capacity that was 

upgraded using BTOP funds. 

• “Existing network miles leased” refers to capacity that was acquired from 

a third-party prior to BTOP and that is being used or improved using 

BTOP funds. 

In our discussions with BTOP awardees, they explained how their 

individual projects expanded broadband access in their communities. For 

example, one awardee who received BTOP and BIP funds explained that 

the majority of the areas served by its projects did not have broadband 

service, with one community lacking basic telephone service. The 

awardee added that as broadband expands in the area, the local 

economy has benefited as tourism-oriented businesses are better able to 

provide Web sites and online reservation systems. Another awardee 

noted that its project serves some areas that previously had broadband 

service; however, the choice of service provider was limited, and the 

broadband options were generally expensive and slow. This awardee 

reported that its BTOP-funded infrastructure improved broadband speed 

for community anchor institutions, including schools, community colleges, 

and health care providers, from 1 gigabyte per second to 10 gigabytes 

per second.
 

Page 14 GAO-12-937 Recovery Act

Interviewees also reported that the public computer center (PCC) 

program expanded access to broadband in their communities. BTOP’s 65 

PCC projects have deployed new workstations (computers) at multiple 

locations, such as community colleges and public libraries, throughout a 

city or state. For example, the New Jersey State Library reported that its 

PCC project has deployed 845 computers to 124 public libraries, and 128 

laptops that community colleges use to provide workforce development 

courses to the public. Some public computer centers also received 

upgraded broadband connections and wireless routers. Officials from the 

State Library of Louisiana noted that residents will use wireless hot spots 

in the library to access the Internet from their own devices, adding that 

one woman brings her children to the library parking lot after hours so that 

they can access the signal and work on their homework when the library 

is closed. In addition, PCC projects have installed workstations designed 

to be accessible by users with visual impairments. The workstation in 

figure 2 includes software that reads aloud what is on the computer 

screen, screen magnification software, and a desktop magnifier that 

enlarges materials placed under it. As of March 2012, PCC awardees 

reported that they provided nearly 34,000 new workstations for public 

use. 
 

Page 15 GAO-12-937 Recovery Act

Figure 2: Example of an Accessible Workstation, with Desktop Magnifier.

PCC projects have also provided classes on a variety of topics, including 

English as a second language, digital literacy, and job training. Officials 

from the New Jersey State Library project noted that while they initially 

targeted people with limited or no computer skills and provided basic 

computer training, they encountered unexpectedly high demand and 

expanded course offerings to reach recent college graduates, those with 

managerial experience, as well as offering additional resources for small 

businesses and entrepreneurs. We visited classes in Louisiana and 

Washington, D.C., and observed participants learning software programs. 

The State Library of Louisiana noted in its first quarter 2012 report that its 

various training programs had over 19,000 participants. During our visit, 

we observed a training class, and participants stated that they had driven 

several hours to attend some classes, and wanted to attend more. For 

more information see, the sidebar titled “Example of PCC Project: State 

Library of Louisiana.” 
 

Page 16 GAO-12-937 Recovery Act

NTIA and RUS have faced difficulties in ensuring that awardees provide 

reliable data regarding broadband subscribership for their BTOP and BIP 

projects, which makes it challenging to fully and accurately determine the 

effects of the programs on broadband adoption. NTIA’s sustainable 

broadband adoption (SBA) projects were established to stimulate demand 

for broadband Internet access, and applicants were required to describe 

how they would calculate subscribership for their projects. For example, 

the SBA project Computers for Youth/Los Angeles Unified School District 

Broadband Engagement Program provides 4-hour workshops in highpoverty Los Angeles schools, during which it provides hands-on, bilingual 

training to sixth-grade students and their families on using broadband for 

educational purposes. The participants receive a free computer preloaded with educational software as well as access to toll-free bilingual 

help-desk support, and Computers for Youth conducts a survey before 

and after the workshop to determine whether the families subscribed to 

broadband service after attending the workshop. Computers for Youth 

stated in its first quarter 2012 report that over 30,000 participants 

(students and their parents) had attended a family-learning workshop 

during the course of its program and that nearly 5,000 households had 

newly subscribed to broadband. Program officials noted that by 

highlighting the relevance of broadband to children’s education and 

offering free computers and technical support, they were able to generate 

broadband subscribers despite the lack of discounted broadband service.

Although current data reflect an increase in subscribers as a result of 

BTOP projects, they may not be accurate. As of March 31, 2012, SBA 

projects reported that they generated over 334,000 broadband 

subscribers. However, NTIA officials told us that many recipients have 

faced difficulties in measuring broadband subscribers related to the 

project and have revised their counting methods. Thus, NTIA officials 

noted that the total subscribers reported to date may not represent the 

true number of new subscribers. In our review of awardees’ first quarter 

2012 reports, we found that 13 of 43 SBA projects reported difficulties 

with collecting subscriber data. For example, some awardees reported 

that they thought they would be able to obtain subscribership data from 

Internet service providers to determine the effect of their projects, but 

later found that Internet service providers were unwilling to provide 

subscribership data. NTIA has provided training on this issue, and 

facilitated sessions in which projects share best practices for measuring 

subscribership. Program officials told us NTIA is also working with 

individual projects to help them find ways to address the challenges 

involved in collecting subscribership data. 

Measurement and Data 

Limitations Make It 

Difficult to Assess the 

Programs’ Effects on 

Broadband Adoption 
 

Page 17 GAO-12-937 Recovery Act

Similarly, RUS data on the effects of BIP projects on broadband adoption 

may not be accurate. RUS established a goal for BIP projects to provide 

new or improved broadband service to 359,450 subscribers, and in 2010, 

RUS stated that it exceeded this goal because it estimates that BIP 

projects will provide new or improved service to 847,239 subscribers. 

However, this total does not reflect actual program outcomes, because it 

is based on the estimates of applicants prior to the execution of their 

funded projects. RUS requires recipients to report quarterly on the 

number of households, businesses, educational providers, libraries, 

health care providers, and public safety providers receiving new or 

improved broadband service. However, when we reviewed the data, we 

noted discrepancies. When we asked RUS about these discrepancies in 

the subscribership data, RUS officials noted that the data are inaccurate 

and that RUS has implemented quality checks to improve the information. 

Specifically, RUS developed a spreadsheet tool that RUS staff use to

review the subscriber data submitted by individual projects, note whether 

the data appear to be correct, and report how any problems with the data 

were resolved. In its comments on a draft version of this report, RUS 

noted that its field staff provides extensive contact and guidance to 

awardees.

BTOP and BIP awardees identified multiple challenges in completing 

projects, including compliance with regulations and construction related 

challenges. Additionally, BIP awardees identified some additional 

challenges related to RUS’s processes and requirements, and noninfrastructure projects participating in BTOP face challenges related to 

staffing and deploying the projects. In some cases, these challenges have 

contributed to the lack of progress discussed above. NTIA and RUS have 

taken a number of actions to help awardees address these challenges,

including providing awardees with regular contact, expertise, webinars, 

and guidance. 

While BTOP and BIP awardees have identified some of the same 

challenges they have faced, they also identified some different challenges 

because the programs are administered by different agencies and fund 

different services. Table 5 lists the challenges we identified facing BTOP 

and BIP awardees based on our interviews and content analysis of NTIA 

and RUS documents.

NTIA and RUS Have 

Acted to Address the 

Variety of Challenges 

Awardees Identified 

in Completing 

Projects 

Challenges 
 

Page 18 GAO-12-937 Recovery Act

Table 5: Challenges Faced by BTOP and BIP Awardees

Challenges BTOP BIP

Environmental review and compliance X X 

Prevailing wage requirements X X 

Permitting, right of way, and make-ready work X X 

Weather and terrain X X 

Broadband fiber availability X X 

Approval of contracts and plans by RUS X 

Compliance with RUS reporting requirements X 

Proposed changes to the Federal Communications Commission’s 

Universal Service Fund

X 

Staffing or expertise Xa

Contracting, procurement, and financing Xa

Technical issues Xa

Outreach and program participation Xa

Source: GAO analysis of interviews and NTIA and RUS documents.

a

NTIA and RUS officials and awardees all identified challenges associated 

with environmental compliance, as BTOP and BIP awardees were 

required to comply with the National Environmental Policy Act

These challenges were identified as pertaining to BTOP PCC and SBA projects. 

14 and the 

National Historic Preservation Act.15 This involved working with state and 

federal agencies to address any environmental or historic preservation 

issues related to the project before construction could commence. 

According to our analysis of BTOP awardees’ first quarter 2012 reports to 

NTIA, 44 of 114 infrastructure awardees reported challenges associated 

with the environmental assessment and historic preservation review.16

 

14Pub. L. No. 91-190, 83 Stat. 852 (1970), as amended, codified at 42 U.S.C. ch. 55. 

Likewise, RUS officials told us that the environmental assessment 

process took significantly longer than anticipated and stated that one 

cause of this was a backlog within the state offices that conduct the 

15Pub. L. No. 89-665 (1966), as amended, codified at 16 U.S.C. ch. 1A, subch. II. 

16As mentioned previously, BTOP awardees are required to submit reports on a quarterly 

basis that among other things, discuss projects’ progress made during the preceding 3 

months and discuss challenges as to why projects may not have met their targets. These 

reports only include the challenges awardees reported during this period. Awardees may 

have experienced these or other challenges in prior quarters. 
 

Page 19 GAO-12-937 Recovery Act

assessments because of the large volume of Recovery Act work. The 

initial environmental assessment process was also the most common 

challenge cited by RUS’s GFRs, who told us that these assessments took 

longer than anticipated and negatively affected all awardees’ schedules. 

Officials from NTIA and RUS both noted delays associated with the 

environmental assessment process, and NTIA officials noted that these 

delays have been up to 6 months for BTOP projects.

BTOP and BIP awardees reported facing other delays in beginning 

project construction, such as: 

• Prevailing wage requirements. The Recovery Act requires that all 

laborers and mechanics employed by contractors and subcontractors on 

projects funded directly by or assisted in whole or in part by and through 

the federal government under the Recovery Act be paid at prevailing 

wage rates.17 NTIA and RUS officials and an awardee told us that in 

many cases identifying the prevailing wage for activities such as fiber 

deployment was difficult because that type of work had often not been 

done in that area and the prevailing wage had not yet been determined 

by the Department of Labor.

• Permitting, right-of-way agreements, and make-ready work. Awardees 

must apply for and receive permits and right of way agreements before 

beginning construction. NTIA officials and awardees told us that for some 

projects, obtaining these agreements from all the relevant stakeholders 

took longer than anticipated and put the projects behind schedule. For 

example, these agreements may have to be obtained from state and 

local governments, tribal governments, federal entities (such as the 

Bureau of Land Management), private landowners, and railroads. One 

awardee we spoke with experienced delays of up to 9 months in the 

installation of equipment and fiber because of the amount of time it took 

to receive right of way permits from railroad companies. In addition, 

make-ready work, which includes the tasks associated with preparing 

utility poles for the installation of equipment and fiber, must be complete 

before any construction occurs, and this need has posed challenges to

maintaining project timelines. For example, one BTOP awardee indicated 

in its first quarter 2012 report to NTIA that “keeping make-ready 

completion ahead of construction crew availability remains the major 

challenge for the project.” 

 

17Recovery Act, div. A, title XVI, § 1606, 123 Stat. 303. 
 

Page 20 GAO-12-937 Recovery Act

• Weather, terrain, and broadband fiber availability. Weather-related 

challenges and difficult terrain can cause delays in construction. 

Awardees reported delays for, among other things, a major tornado that 

caused damage to a service area and equipment, hurricanes, snowfall, 

and flooding. Difficult terrain can also cause delays. One awardee told us

that its project unexpectedly called for boring through solid granite under 

a river, which required additional tools and time. NTIA and RUS officials

told us that BTOP and BIP projects were also delayed due to fiber 

shortages caused by the 2011 tsunami in Japan and increased worldwide 

demand for fiber. For example, one BTOP infrastructure awardee noted

in its first quarter 2012 report to NTIA that it was “experiencing delays in 

the delivery of the fiber...[and that] while we received a few shipments 

during this quarter it was much less than promised.” 

RUS officials also noted some challenges specific to the BIP program, 

such as:

• Approval of contracts and plans. RUS officials told us that to ensure 

quality construction is completed, they require that awardees gain 

approval of contracts before the construction begins or materials are 

purchased. RUS officials said that on average, it takes the agency 1 and 

a half months to 2 months to approve a contract. However, some RUS 

GFRs and awardees said that RUS did not approve BIP contracts in a 

timely fashion in some instances, which resulted in project delays. In 

particular, some GFRs said that RUS took 6 to 12 months to approve a 

contract. RUS officials noted that there could be a number of reasons 

why contracts had not been approved, including that the contracts were 

not correct when they were submitted for approval.

• Compliance with reporting requirements. RUS officials told us some 

awardees that received a loan or loan/grant combination have 

experienced challenges complying with RUS reporting requirements. The 

officials explained that awardees who had not previously borrowed from 

RUS are more likely to experience difficulties complying with reporting 

requirements than those awardees with a history of borrowing from RUS.

• Proposed changes to the Federal Communications Commission’s (FCC) 

Universal Service Fund. Some RUS officials were concerned about how 

reforms to FCC’s Universal Service Fund, which provides

telecommunications funding to some BIP awardees, could potentially 

affect projects’ income streams. FCC’s reforms include changes to the 
 

Page 21 GAO-12-937 Recovery Act

distribution and use of Universal Service Fund payments to make the 

funds available to support both telephone service and broadband 

deployment.18 As a result of the reforms, rural telecommunications 

carriers could receive reduced universal service support payments. In 

August 2011, RUS provided data to FCC on how these changes could 

potentially affect the income stream of RUS borrowers and grant 

awardees. Subsequently, in its 2011 Order and Further Notice of 

Proposed Rulemaking on this issue, FCC stated that the reforms it 

adopted were more modest than the estimates used by RUS to 

determine the potential impact of the reforms, and that RUS did not 

consider the potential for borrowers to adopt operational efficiencies that 

would offset reductions in universal service support.19

NTIA officials and awardees also identified challenges that apply to noninfrastructure BTOP projects, such as: 

• Staffing or expertise. PCC and SBA projects faced staffing and expertise 

challenges, such as high staff turnover, or the need for additional staff to 

handle tasks such as providing technical support for computers or 

manning computer labs. Our analysis of BTOP awardees’ first quarter 

2012 reports to NTIA indicate that 7 of 43 SBA projects and 22 of 64 

PCC projects reported challenges with either a lack of staff or lack of staff 

expertise.

• Contracting, procurement, and financing. Contracting and procurement 

issues also commonly caused delays at the beginning of PCC and SBA 

projects, according to NTIA officials. These projects can be run by state 

or local entities, and four of the Federal Program Officers (FPOs) we 

spoke with told us that the projects they oversee were delayed by the 

need to comply with state or local contracting or procurement 

requirements. For example, FPOs told us that one project was delayed 

by 4 to 5 months because the state legislature needed to approve the 

spending of BTOP funding, and another project run by a large city was 

delayed by more than a year because of its internal contracting process.

 

18We previously reported on the need for FCC to reform the Universal Service Fund. 

GAO, Telecommunications: FCC Has Reformed the High-Cost Program, but Oversight 

and Management Could be Improved, GAO-12-738 (Washington, D.C.: July 25, 2012).

19In the Matter of Connect America Fund, 26 FCC Rcd. 17663 (2011), as corrected, 27 

FCC Rcd. 4040 (2012).
 

Page 22 GAO-12-937 Recovery Act

• Technical issues. Issues related to equipment, software, and Internet 

service, have also been challenging to SBA and PCC projects. Our 

analysis of BTOP awardees’ first quarter 2012 reports to NTIA indicate 

that 8 of 43 SBA projects and 16 of 64 PCC projects noted challenges 

with the technical aspects of the projects. For example, one awardee 

reported that software conflicts caused system crashes for the 

workstations deployed for seniors and adults with disabilities.

• Outreach and program participation. Some awardees reported outreach 

and participation challenges, such as difficulty in participant retention. For 

example, one awardee reported that most of the participants were senior 

citizens and were easily discouraged when they felt that they could not 

retain new skills after each class or training session. Overall, according to 

our analysis of BTOP awardees’ first quarter 2012 reports to NTIA, 13 of 

43 SBA projects and 10 of 64 PCC projects reported challenges related 

to outreach or participation.

NTIA and RUS provided resources and took action to help awardees 

address their challenges. Both agencies have provided awardees with 

regular contact and support. For example, NTIA officials told us that they 

have regularly scheduled calls between awardees and FPOs to 

encourage dialog and early resolution of problems. The officials also 

noted they have encouraged awardees to come to the agency for help, 

especially in complex situations where federal influence can help resolve 

challenges. For example, NTIA officials stated that they worked with FCC 

and state public utility commissions to ensure that they prioritized their 

review of BTOP projects’ requests for permits. Likewise, RUS officials told 

us that GFRs and other agency staff have provided regularly scheduled 

contact to determine project status and challenges early on so they can 

begin addressing them. Both FPOs and GFRs told us that they worked to 

identify options for dealing with fiber shortages and provided that 

information to awardees. 

Both NTIA and RUS developed webinars and training sessions to inform 

awardees and provide them with updated information. NTIA has provided 

guidance to awardees through webinars and conference calls and has 

held several webinars on topics including pole attachment issues, 

computer recycling and refurbishing, and numerous other topics. Some 

awardees told us the webinars and conference calls were both useful and 

timely. RUS also developed and held webinars focused on assisting grant 

and loan recipients with the contract process; which according to officials, 

could increase the likelihood that the contracts are approved more 

Agencies’ Actions to 

Address Challenges
 

Page 23 GAO-12-937 Recovery Act

expeditiously so that awardees can be reimbursed in a more timely 

fashion. NTIA also has a monitoring process to identify projects with 

schedule, performance, or other challenges, and as needed provides 

such projects with performance improvement plans and corrective action 

plans. In its comments on a draft version of this report, RUS noted that it 

has implemented a detailed review process to identify issues with BIP 

awards and is constantly providing guidance and assistance to the 

awardees to overcome issues with the performance of the award.

In addition to providing the general resources and actions described 

above, NTIA and RUS took the following actions to address some of the 

specific challenges described earlier in this report:

• NTIA took steps to facilitate the sharing of information and best practices 

among projects by identifying projects that had already successfully 

addressed a particular issue and asking them to share their experiences 

with similar projects. For example, a significant number of infrastructure 

projects were experiencing similar make-ready challenges, and NTIA 

organized and moderated a discussion where awardees discussed 

problems and solutions. 

• NTIA also created different groups for PCC and SBA projects to share 

information on a range of issues that were challenging awardees related 

to K-12 education, seniors, tribes, municipalities, and healthcare. 

• RUS proposed contract modifications to streamline and simplify the 

timeline for construction and hired 8 additional engineers and loan and 

grant technicians and allowed some GFRs overseeing larger projects to 

approve routine contracts to help address the contract approval backlog 

described above. 

BTOP and BIP, as established by the Recovery Act, are intended to 

promote the availability and use of broadband Internet access throughout 

the country, as well as create jobs and stimulate economic development. 

The ability to measure the progress of BTOP and BIP projects and their 

effects on expanding access to and use of broadband Internet access is 

an important component of program management and oversight, and 

could inform future federal programs. NTIA and RUS track the amount of 

funds disbursed to projects as one measure of progress. However, 

disbursements do not fully reflect the amount of progress made. Thus, 

data on non-financial measures of progress, such as the amount of 

infrastructure deployed, can provide insights into the progress of 

Conclusions
 

Page 24 GAO-12-937 Recovery Act

broadband projects. While NTIA established performance measures and 

collected data on non-financial measures of progress, RUS did not initially 

collect comparable data, and once it did begin collecting these data, it 

could not ensure their quality. Collecting accurate data would enable RUS 

to better demonstrate BIP projects’ progress toward completion, and 

outcomes for the BIP program. We also identified challenges that NTIA 

and RUS both faced in ensuring the accuracy of projects’ subscribership 

data. Because both agencies have taken steps to improve the quality of 

the subscribership data reported by awardees, we are not making a 

recommendation to address this issue in this report.

To ensure RUS is collecting reliable information regarding the effect of 

investments in broadband, we recommend that the Secretary of 

Agriculture direct RUS to take steps to improve the quality of its data on 

the number of fiber miles and wireless access points created by BIP 

projects. 

We provided a draft of this report to the Secretary of Commerce and the 

Secretary of Agriculture for review and comment. The Department of 

Commerce provided technical comments that we incorporated into the 

report as appropriate. The Department of Agriculture provided written 

comments on a draft of this report, which appear in appendix III. The 

department disagreed with our characterization that RUS does not collect 

adequate data to measure the progress of BIP and noted that RUS 

collects financial data as well as contract-level data with information on 

planned construction for each project. The department also noted that 

RUS collects data on the number of subscribers, which it implies is a 

relevant measure of performance for the BIP program. We agree that 

RUS collects financial data, but as we note in the report, financial data do

not fully reflect the progress of the program. Thus, non-financial data, 

such as fiber miles and wireless access points deployed, provide an 

additional indicator of BIP’s progress. As we note in the report, RUS’s 

data for these measures, as well as the number of subscribers, are 

unreliable, which hinders RUS’s ability to assess the progress of BIP.

Although the department neither agreed or disagreed with our 

recommendation that RUS should improve the quality of its data on the 

number of fiber miles and wireless access points created by BIP projects, 

the department stated that RUS has already taken steps to improve the 

quality of its data. If RUS takes action and can demonstrate that the data 

are reliable, we will close the recommendation as implemented.

Recommendation for 

Executive Action

Agency Comments

and Our Evaluation
 

Page 25 GAO-12-937 Recovery Act

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Agriculture, and the Secretary of 

Commerce. 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 major contributions to 

this report are listed in appendix IV. 

Mark L. Goldstein

Director, Physical Infrastructure 
Appendix I: Scope and Methodology

Page 26 GAO-12-937 Recovery Act

This appendix provides information on the methodologies that we used to 

assess (1) the progress made in implementing broadband projects funded 

by the American Recovery and Reinvestment Act of 2009 (Recovery 

Act),1 (2) the effect of the projects on expanding access to and adoption

of broadband service, and (3) the challenges that grant and loan 

recipients face in completing broadband projects, and the actions that 

agencies are taking to help address these challenges. 

To determine the progress made in implementing the projects funded by 

the Recovery Act, we obtained data that allowed us to calculate the 

amount of funds awarded and the amount of funds disbursed to projects 

participating in the Broadband Technology Opportunities Program 

(BTOP) administered by the National Telecommunications and 

Information Administration (NTIA), and the Broadband Initiatives Program 

(BIP) administered by the Rural Utilities Service (RUS). In addition, we 

obtained data from NTIA on the status of BTOP in meeting the targets for 

the key performance indicators established by NTIA: miles deployed or 

leased, community anchor institutions connected, workstations installed in 

public computer centers, and new broadband subscribers. To determine 

the reliability of these data, we reviewed relevant documentation, 

including manuals, guidance and forms provided to awardees reporting 

the data, descriptions of internal controls, and Inspector General reviews 

of the data from the Department of Agriculture and the Department of the 

Treasury (which manages the payment system used by BTOP recipients); 

and we interviewed agency officials about their processes for reviewing 

the data and ensuring their accuracy. We found the data generally 

reliable for our purposes of reporting the amount of funds disbursed to 

BTOP and BIP awardees, and the amount of progress made toward 

meeting NTIA’s targets for BTOP, although we did note and report on 

limitations with NTIA’s subscribership data. 

To assess the effect of the projects on expanding access to and adoption 

of broadband service, we reviewed data collected by NTIA and RUS, 

such as the aforementioned data on the progress of BTOP projects in 

deploying miles, connecting community anchor institutions, installing 

workstations in public computer centers, and creating new broadband 

 

1

Pub. L. No. 111-5, 123 Stat. 115 (2009).

Appendix I: Scope and Methodology

Progress of Programs

Effect of Programs
Appendix I: Scope and Methodology

Page 27 GAO-12-937 Recovery Act

subscribers. Our efforts to determine the reliability of BTOP’s program 

data are discussed above. We reviewed the data that RUS collects from 

BIP awardees on the number of subscribers accessing BIP-funded 

service, but based on conversations with RUS officials, determined the 

data were not reliable for our purposes. We also interviewed BTOP and 

BIP awardees to understand the effects of their individual projects. We 

used the following criteria to select awardees to interview: projects that 

had received two-thirds of their award (thereby meeting NTIA’s 

“substantially complete” requirement), large award size, and geographic 

dispersion. 

To determine the challenges that grant and loan recipients face in 

completing projects, we interviewed NTIA and RUS officials, including 

NTIA’s Federal Program Officers (FPO) and RUS’s General Field 

Representatives (GFR), who serve as a point-of-contact for the 

awardees. We also interviewed the BTOP and BIP awardees mentioned 

in the previous paragraph, as well as some awardees that had not 

received two-thirds of their award. For BTOP, we reviewed awardees’ 

progress reports for the first quarter of 2012,2 which covered the time 

period from January 1, 2012, to March 31, 2012. In these quarterly 

reports, awardees must report on their progress toward meeting 

milestones (progress is based on expenditures), and describe the reason 

for any variance from their baseline plan or subsequent written updates 

provided to their program officer. Awardees must also describe any 

challenges or issues faced in the past quarter in achieving planned 

progress, and any areas where assistance from NTIA is needed. We 

created content categories for the challenges reported by the awardees 

and for whether they requested assistance from NTIA. Two analysts 

independently coded each response into one of the categories; any 

discrepancies in the coding of the two analysts were discussed and 

addressed by the analysts. For BIP, we reviewed a tracking spreadsheet 

maintained by RUS, in which the GFRs provide the status of each BIP 

project and in some cases, note issues or challenges facing individual 

projects. 

 

2

NTIA requires that BTOP awardees submit quarterly and annual progress reports.

Challenges 
Appendix I: Scope and Methodology

Page 28 GAO-12-937 Recovery Act

To determine the actions NTIA and RUS are taking to address challenges 

facing BTOP and BIP awardees, we interviewed NTIA and RUS officials, 

including FPOs and GFRs. We also reviewed documentation of guidance, 

training, webinars, and workshops provided by the agencies. We asked 

the BTOP and BIP awardees we interviewed about their experiences with 

NTIA and RUS, including whether the awardees had faced challenges 

and the awardees’ perceptions of NTIA and RUS guidance and 

resources.

We conducted this performance audit from November 2011 through 

September 2012 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.

Agency Actions to Address 

Challenges
Appendix II: Analysis of Employment Data 

Submitted by Program Awardees

Page 29 GAO-12-937 Recovery Act

This appendix responds to a recurring GAO mandate in the American 

Recovery and Reinvestment Act (Recovery Act) requiring us to comment 

and report quarterly on estimates of jobs funded and counted as full-time 

equivalents (FTE) as reported by recipients of Recovery Act funds.1 To 

assess the quality of FTE reporting by awardees participating in the

National Telecommunications and Information Administration’s (NTIA)

Broadband Technology Opportunities Program (BTOP) and the Rural 

Utilities Service’s (RUS) Broadband Initiatives Program (BIP), we 

examined recipient-reported data publicly available at Recovery.gov as of 

August 1, 2012, for these two programs over the 10 quarters in which 

they reported FTE data.

2

Our assessment of the FTE reporting included interviewing NTIA and 

RUS program officials familiar with awardees’ recipient reporting and a 

review of the FTE figures and other recipient reported data. Our matches 

showed a high degree of agreement between the agencies’ assessments 

of FTE positions reported and our analyses of information recipients 

provided on their quarterly reports. Based on our analyses and interviews 

with agency officials, we determined that the recipient-reported data 

appeared to be sufficiently reliable for the purpose 

 While Recovery Act recipients’ reporting of 

FTEs began in September 2009, the first quarter that FTE data were 

submitted for the BTOP and BIP programs was the first quarter of 2010 

for BTOP and the second quarter of 2010 for BIP.

 

1

Pub. L. No. 111-5, § 1512(e), 123 Stat. 115, 288 (2009). FTE data provide insight into the 

use and impact of the Recovery Act funds, but recipient reports cover only direct jobs 

funded by the Recovery Act. These reports do not include the employment impact on 

suppliers (indirect jobs) or on the local community (induced jobs). Both data reported by 

recipients and other macroeconomic data and methods are necessary to understand the 

overall employment effects of the Recovery Act. 

2

In addition to conducting our analyses of recipient report data for BIP and BTOP 

programs under the Recovery Act, we continued, as in prior rounds, to perform edit 

checks and analyses on all prime recipient reports to assess data logic and consistency 

and identify unusual or atypical data.

Appendix II: Analysis of Employment Data 

Submitted by Program Awardees 
Appendix II: Analysis of Employment Data 

Submitted by Program Awardees

Page 30 GAO-12-937 Recovery Act

of providing summary, descriptive information about FTEs and other 

information submitted on grantees’ recipient reports.3

The FTE data reported by BTOP and BIP recipients showed an overall 

rise in the level of employment activity among the projects. As shown in 

figure 3, the number of FTEs reported by both programs steadily 

increased from quarter to quarter in 2010 and 2011 with BTOP continuing 

to show an increase in the second quarter of 2012 while BIP showed a 

decrease during the first quarter of 2012, and an increase from that in the 

second quarter of 2012.

 

3

We did notice, however, in our review of BIP’s FTE data that some recipients did not 

report their FTEs in accord with RUS guidance. Recipients that received awards that were 

a combination of loans and grants were to report FTEs separately for each component of 

the award. RUS officials stated that they instructed the recipients that funds should be 

drawn down proportionally from the loan and grant, and to divide FTEs along that same 

proportion. Thus, if the award is 50 percent loan and 50 percent grant, then FTEs for the 

entire project were to be divided evenly between the grant and the loan reports for the 

reporting quarter. We observed that there were recipients who received combination 

awards with different, unequal grant and loan award amounts, but reported FTEs equally 

split between the loan quarterly report and the grant quarterly report. The apportioning of 

the FTEs did not match the apportioning of the loan and grant amounts. RUS officials 

stated that without following up with the individual recipients, they could not determine the 

reason for this.
Appendix II: Analysis of Employment Data 

Submitted by Program Awardees

Page 31 GAO-12-937 Recovery Act

Figure 3: FTEs Reported by BTOP and BIP Recipients, January 2010 through June 2012 

Notes: FTE values are shown for each individual quarter and are not cumulative. 

Technical assistance awards for BIP are not included in the totals. 

Recipients reported that BTOP-funded FTEs increased from about 20 

FTEs in the first quarter of 2010 to a peak quarter of about 4,500 FTEs in 

the second quarter of 2012. BIP recipients reported an increase from 86 

FTEs in the second quarter of 2010 to about 4,500 in the second quarter 

of 2012, with a peak of over 4,700 FTEs in the fourth quarter of 2011. 
Appendix III: Comments from the Department 

of Agriculture

Page 32 GAO-12-937 Recovery Act

Appendix III: Comments from the 

Department of Agriculture 

Note: GAO comments 

supplementing those 

in the report text 

appear at the end of 

this appendix. Page 

numbers in the draft 

report may differ from 

those in this report. 
Appendix III: Comments from the Department 

of Agriculture

Page 33 GAO-12-937 Recovery Act
Appendix III: Comments from the Department 

of Agriculture

Page 34 GAO-12-937 Recovery Act

x.

See comment 1.
Appendix III: Comments from the Department 

of Agriculture

Page 35 GAO-12-937 Recovery Act

See comment 2. 

See comment 2. 

See comment 3.

See comment 2. 

See comment 4.

See comment 2.
Appendix III: Comments from the Department 

of Agriculture

Page 36 GAO-12-937 Recovery Act

See comment 1.

See comment 3.

See comment 5.

See comment 6.

See comment 6.
Appendix III: Comments from the Department 

of Agriculture

Page 37 GAO-12-937 Recovery Act
Appendix III: Comments from the 

Department of Agriculture

Page 38 GAO-12-937 Recovery Act

The following are GAO’s comments on the Department of Agriculture’s 

letter dated September 4, 2012.

1. We do not imply that RUS does not or should have the same data as 

NTIA. Rather, we note that the agencies have financial and nonfinancial measures of progress. Both NTIA and RUS have reliable 

financial measures of progress. However, as we note, the financial 

data do not fully reflect the amount of work completed. Therefore, 

non-financial data provide additional insight into the progress of the 

programs toward completion. In its letter, RUS says that the number 

of fiber miles is not as relevant as the number of subscribers. But, 

since RUS began tracking fiber miles and wireless access points 

deployed, we assume the agency considers these important 

measures of progress. Yet, at the time of our review, RUS officials 

told us that they could not ensure the quality of the data. We agree 

that the number of subscribers is an important performance measure 

for the programs; however, unlike fiber miles and wireless access 

points deployed, the number of subscribers is not an indicator of the 

progress of a project toward completion. Rather, it is an outcomebased performance measure for a completed project, as the number 

of subscribers depends in part on the deployment of fiber miles and 

wireless access points. Further, as we discuss in the report, RUS 

officials told us that its subscriber data are inaccurate. Therefore, at 

an aggregate, program level, RUS does not have accurate nonfinancial data to measure the progress of BIP.

2. We acknowledge that RUS tracks the progress of individual BIP 

projects through its review and approval of contracts. RUS noted that 

it uses the information provided in contracts to monitor the 

construction of fiber facilities and the installation of access points on a 

project-by-project basis. RUS also noted that as a lender, there was 

no need to track these measures at an aggregate level. However, 

considering the number of BIP projects, the provision of grants in 

addition to loans, and the emphasis on transparency and quickly 

deploying Recovery Act-funded projects, aggregated information 

provides a holistic view of the progress of BIP. In addition, if the 

underlying project-level data are reliable, it is unclear why the 

aggregate level information would be unreliable, as RUS officials told 

us during our review.

3. We included additional information on RUS’s efforts in the body of our 

report.

GAO Comments
Appendix III: Comments from the 

Department of Agriculture

Page 39 GAO-12-937 Recovery Act

4. We revised our report to note that the quarterly reports also include 

awardees’ financial statements. 

5. We revised our report to identify the additional steps that RUS has 

taken to help awardees address their challenges, including 

implementing a detailed review process and providing guidance and 

assistance to awardees.

6. At the time of our review, RUS officials told us that they could not 

ensure the quality of the data on the number of fiber miles and 

wireless access points deployed. RUS officials attributed the problems 

with data quality to the short collection period, as they had begun 

collecting these data in June 2012. If RUS takes action and can 

demonstrate that the data are reliable, we will close the 

recommendation as implemented.
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 40 GAO-12-937 Recovery Act

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

In addition to the contact named above, Michael Clements (Assistant 

Director), Tom Beall, Crystal Huggins, Bert Japikse, Aaron Kaminsky, 

Carol Patey, Amy Rosewarne, Beverly Ross, and Jon Stehle made key 

contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(543296)
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