TELECOMMUNICATIONS

Additional Coordination 

and Performance 

Measurement Needed for 

High-Speed Internet 

Access Programs on Tribal 

Lands

Report to Congressional Requesters

January 2016

GAO-16-222

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-222, a report to 

congressional requesters

January 2016

TELECOMMUNICATIONS

Additional Coordination and Performance 

Measurement Needed for High-Speed Internet Access 

Programs on Tribal Lands

Why GAO Did This Study

High-speed Internet service is viewed 

as a critical component of the nation’s 

infrastructure and an economic driver,

particularly to remote tribal 

communities. However, in 2015, FCC

reported that the lack of service in 

tribal areas presents impediments. 

GAO was asked to review the status of 

high-speed Internet on tribal lands. The 

report examines (1) perspectives of 

tribes and providers on high-speed 

Internet access and barriers to 

increasing this access; (2) the level of 

interrelation and coordination between 

federal programs that promote highspeed Internet access on tribal lands; 

and (3) existing data and performance 

measures related to high-speed 

Internet on tribal lands. GAO visited or 

interviewed officials from a nongeneralizable sample of 21 tribal 

entities and 6 service providers

selected to provide diversity in size, 

location, and poverty levels. GAO also

reviewed FCC and USDA fiscal year 

2010 through 2014 program data, 

funding, and materials and interviewed 

federal officials. 

What GAO Recommends

GAO recommends that FCC (1) 

develop joint training and outreach with 

USDA; (2) develop performance goals 

and measures for tribal areas for

improving broadband availability to 

households; (3) develop performance 

goals and measures for improving 

broadband availability to tribal schools 

and libraries; and (4) improve the 

reliability of FCC data related to 

institutions that receive E-rate funding 

by defining “tribal” on the program 

application. FCC agreed with the

recommendations.

What GAO Found

Although all 21 tribes GAO interviewed have some access to high-speed 

Internet, tribes and providers GAO interviewed cited barriers to increasing 

access. For example, high poverty rates and the high costs of connecting remote 

tribal villages to core Internet networks—called middle-mile infrastructure—limit

high-speed Internet availability and adoption on tribal lands (see fig.). About half 

of the tribes GAO interviewed also said that the lack of sufficient administrative 

and technical expertise among tribal members limits their efforts to increase highspeed Internet access.

Types of Middle-Mile Internet Service Delivery Infrastructure

The Federal Communications Commission’s (FCC) Universal Service Fund

subsidy programs and the U.S. Department of Agriculture’s (USDA) Rural 

Utilities Service grant programs are interrelated in that they seek to increase 

high-speed Internet access in underserved areas, including tribal lands. GAO’s 

previous work on overlap, duplication, and fragmentation has shown that 

interagency coordination on interrelated programs can help ensure efficient use 

of resources and effective programs. However, FCC and USDA do not 

coordinate to develop joint outreach and training. This could result in an 

inefficient use of federal resources and missed opportunities for resource 

leveraging between FCC and USDA. 

FCC has placed special emphasis on improving Internet access on tribal lands 

following the issuance of the National Broadband Plan, which called for greater 

efforts to make broadband available on tribal lands. However, FCC has not 

developed performance goals and measures for improving high-speed Internet 

availability to households on tribal lands. Without these goals and measures FCC 

cannot assess the impact of its efforts. The National Broadband Map includes 

data on Internet availability on tribal lands that could allow FCC to establish 

baseline measures for Internet availability on tribal lands. Further, FCC also lacks 

performance goals and measures for tribal institutions—such as schools and

libraries. Specifically, FCC’s E-rate program provides funds to ensure that 

schools and libraries have affordable access to modern broadband technologies, 

but FCC has not set any performance goals for the program’s impact on tribal 

institutions. Nor has FCC defined “tribal” on the E-rate application. Without such 

information, it will be difficult to accurately track progress in making broadband 

available in tribal institutions.

View GAO-16-222. For more information, 

contact Mark Goldstein at (202) 512-6670 or 

goldsteinm@gao.gov.
Page i GAO-16-222 Telecommunications

Letter 1

Background 4

Selected Tribes and Providers Identified Opportunities and 

Barriers Related to Increasing High-Speed Internet Access 8

Interrelated Federal Programs Promoting High-Speed Internet 

Access on Tribal Lands Are Not Always Well Coordinated 16

Federal Government is Gathering Data, but FCC Lacks 

Performance Goals and Measures for the Internet on Tribal 

Lands 22

Conclusions 29

Recommendations for Executive Action 30

Agency Comments 31

Appendix I Objectives, Scope, and Methodology 34

Appendix II List of Tribes, Alaska Native Entities, Internet Service Providers, and 

Other Groups GAO Interviewed 37

Appendix III Comments from the Federal Communications Commission 38

Appendix IV GAO Contact and Staff Acknowledgments 41

Figures

Figure 1: Map of Tribal Lands in the United States, According to 

the 2010 Census 5

Figure 2: Types of Middle-Mile Internet Service Delivery 

Infrastructure 10

Figure 3: A Building in Beaver, Alaska Serviced with a Satellite 

Internet Connection 11

Figure 4: 2013 Poverty Rates among Tribes GAO Interviewed 13

Figure 5: Picture of High-Speed Internet-Enabled Telemedicine 

Cart from the Village of Nenana, AK 18

Figure 6: Wireless Microwave Internet Tower in Oscarville, Alaska 20

Figure 7: Example of National Broadband Map Website 

Information About Tribal Lands 24

Contents
Page ii GAO-16-222 Telecommunications

Abbreviations

ACS American Community Survey

CAF Connect America Fund

DSL Digital Subscriber Line

FCC Federal Communications Commission

Mbps Megabits Per Second 

NTIA National Telecommunications and Information Administration 

OTSA Oklahoma Tribal Statistical Areas 

RUS Rural Utilities Service

USDA U.S. Department of Agriculture’s 

USF Universal Service Fund 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-222 Telecommunications

441 G St. N.W.

Washington, DC 20548

January 29, 2016

Congressional Requesters

Increasingly, high-speed Internet service is viewed as a critical 

component of the nation’s physical infrastructure and a driver of economic 

growth. High-speed Internet access provides a number of social and 

economic benefits including essential communications service for ecommerce, telemedicine, online courses, and other educational tools. The 

Internet is particularly useful to tribal communities—which are generally 

located in remote, rural locations—as access to it offers new opportunities 

for growth, productivity, and innovation. However, in 2012, the Federal 

Communications Commission’s (FCC) Office of Native Affairs and Policy 

reported that the lack of service in rural and tribal lands presents 

impediments to efforts of tribal nations to build their internal structures for 

self-governance, economic opportunity, education, public safety, and 

cultural preservation. 

The communications infrastructure that supports Internet access is, by 

and large, built and operated by private industry. However, from fiscal 

years 2010 to 2014, the federal government provided over $33 billion in 

assistance to telecommunications service providers and municipalities to 

build or improve networks in order to further the national goal of universal 

high-speed Internet access. The federal government has provided this 

funding through the FCC’s Universal Service Fund (USF) and the U.S. 

Department of Agriculture’s (USDA) Rural Utilities Service (RUS). 

In January 2015, FCC reported that Americans living in rural areas and 

on tribal lands disproportionately lack access to high-speed Internet. 

FCC’s data indicate that, as of December 2013, high-speed Internet was 

available to 37 percent of households on tribal lands—compared to 47 

percent of U.S. households in rural areas and 92 percent of U.S. 

households in urban areas. You asked us to review the availability of 

high-speed Internet access on tribal lands. This report examines (1) 

perspectives of selected tribes and providers on the importance of highspeed Internet access for tribes and any barriers to increasing this access 

on tribal lands; (2) the level of interrelation and coordination between 

federal programs at FCC and USDA that promote high-speed Internet 

access on tribal lands; and (3) existing data and FCC performance goals 

and measures related to access to high-speed Internet service on tribal 

lands and for tribal institutions.

Letter
Page 2 GAO-16-222 Telecommunications

To determine perspectives of selected tribes and providers on the 

importance of high-speed Internet access and any barriers to increasing 

this access on tribal lands, we reviewed relevant literature and

interviewed officials from 18 tribal governments in the continental United 

States, 3 Alaska Native regions, and 6 service providers operating on 

tribal lands. For the three Alaska Native regions, we visited villages within 

each region and spoke with officials from the Regional Corporation, 

regional nonprofit, Village Corporation, tribal government, and city 

government. To identify tribes to interview, we reviewed the types and 

amounts of assistance provided by FCC and USDA between fiscal years 

2010 and 2014 and Bureau of the Census (Census) 2013 data regarding 

population and poverty rates. We selected tribes to have a range of 

population, poverty rates, and locations, both remote and closer to urban 

areas. For reporting purposes, we developed the following series of 

indefinite quantifiers to describe the tribal responses from the 21 tribal 

entities we interviewed.

• 5 of the 21 is described as “a few”;

• 5 to 9 is described as “some”;

• 10 to 12 is described as “about half”;

• 13 to 16 is described as “many”; and 

• 17 or more is described as “most”. 

We selected service providers to interview using initial tribal interviews 

and FCC data for fiscal years 2010 through 2014 to identify providers that 

serve tribal lands and receive federal subsidies or loans to do so. These 

interviews are not generalizable to all tribes or all service providers. 

Furthermore, we identified and interviewed industry stakeholders such as 

research groups and telecommunications associations on their views 

regarding the barriers to increasing high-speed Internet access to 

broadband on tribal lands. 

To determine the level of interrelation and coordination between federal 

programs at FCC and USDA that promote high-speed Internet access on 

tribal lands, we reviewed FCC and USDA program funding and guidance 

materials for fiscal year 2010 through 2014, interviewed FCC and USDA 

officials, and interviewed tribal officials from the selected 21 tribal 

governments or Alaska Native regions and six service providers operating 

on tribal lands. These interviews are not generalizable to all tribes or all 

service providers. We evaluated USF and RUS program coordination 
Page 3 GAO-16-222 Telecommunications

based on criteria for implementing interrelated programs developed in 

previous GAO work on fragmentation, overlap, duplication, and 

interagency coordination within the federal government.1

 

To determine what data and FCC performance goals and measures, if 

any, exist related to access to high-speed Internet service on tribal lands 

and to tribal institutions, we analyzed fiscal year 2010 through 2014 data 

from USF programs providing assistance, reviewed applications and the 

guidance materials for those programs, and the agencies’ performance 

reports. We also reviewed Census’ American Community Survey 5-year 

data on population, poverty rates, and telecommunication access; and 

interviewed FCC and Census officials. We determined that FCC and 

Census data were sufficiently reliable for our purposes by interviewing 

FCC and Census officials on their data collection and validation efforts. 

Finally, we reviewed performance goals and measures for USF programs 

according to criteria established in the Government Performance and 

Results Act of 1993, as amended2 and in federal standards for internal 

control.

3 Appendix I contains a more detailed discussion of our objectives, 

scope, and methodology. Appendix II provides a list of the Native 

American Tribes, including Alaska Native Villages; Internet service 

providers; and other organizations we interviewed.

We conducted this performance audit from February 2015 to January 

2016 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.

 1 GAO, Fragmentation, Overlap, and Duplication: An Evaluation and Management Guide, 

GAO-15-49SP, (Washington, D.C.: April 14, 2015). GAO, Managing for Results: Barriers 

to Interagency Coordination, GAO/GGD-00-106, (Washington, D.C.: March 29, 2000). 

GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022, (Washington, D.C.: September 27, 2012). 

2 Pub. L. No. 103-62, 107 Stat. 285 (Aug. 3, 1993) as amended by GPRA Modernization 

Act of 2010, Pub. L. No. 111-352 (2010).

3 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1999).
Page 4 GAO-16-222 Telecommunications

According to 2013 Census estimates, more than 640,000 American 

Indians and Alaska Natives reside on tribal lands.4 The federal 

government has recognized many American Indian tribes and Alaska 

Native Villages as distinct, independent political communities with 

inherent sovereignty. Tribal lands vary in size, demographics, and 

location. The smallest are less than one square mile, and the largest, the 

Navajo Nation, is more than 24,000 square miles. Most tribal lands are in 

remote, rural locations, but some are located near urban areas. There 

are more than 300 Indian tribes in the continental United States and more 

than 200 Alaska Native Villages that are federally recognized. The tribal 

government has the option of forming entities that manage tribal affairs 

including schools, housing, health, and economic enterprises. 

Additionally, the Alaska Native Claims Settlement Act of 1971 directed the 

establishment of 12 regional corporations representing geographic 

regions of the entire state to, among other things, resolve long-standing 

aboriginal land claims and foster economic development in Alaska.5

 

These corporations distribute land and monetary benefits to Alaska 

Natives to provide a fair and just settlement of aboriginal land claims in 

Alaska. The regional corporations have corresponding nonprofit 

organizations that provide social services to the villages. Figure 1 shows 

tribal lands in the United States according to the 2010 Census, and the 

Alaska Native regions.

 4 For this report, GAO has defined tribal lands as lands that include any federally 

recognized Indian tribe’s reservation, off-reservation trust lands, pueblo, or colony, and 

Alaska Native regions established pursuant to the Alaska Native Claims Settlement Act, 

Pub. L. No. 92-203, 85 Stat. 688 (1971) (codified as amended at 43 U.S.C. §§ 1601 et 

seq.). Tribal lands do not include Oklahoma Tribal Statistical Areas (OTSA), and the 

population figure of 640,000 does not include the 401,000 Native Americans living on 

OTSAs.

5 In addition, a thirteenth corporation was established later for nonresident Alaska Natives. 

See 43 U.S.C. § 1606.

Background
Page 5 GAO-16-222 Telecommunications

Figure 1: Map of Tribal Lands in the United States, According to the 2010 Census

a

For this report, GAO has defined tribal lands as lands that include any federally recognized Indian 

tribe’s reservation, off-reservation trust lands, pueblo, or colony, and Alaska Native regions 

established pursuant to the Alaska Native Claims Settlement Act, Pub. L. No. 92-203, 85 Stat. 688 

(1971) (codified as amended at 43 U.S.C. §§ 1601 et seq.). Tribal lands do not include Oklahoma 

Tribal Statistical Areas (OTSA).

Native Americans are among the most economically distressed groups in 

the United States. According to the Census’ 2014 American Community 

Survey (ACS), about 28.3 percent of Native Americans live in households 

with incomes below the federal poverty level—compared to 15.5 percent 

for the U.S. population as a whole. In addition, ACS data shows that 

residents of tribal lands often lack basic infrastructure, such as water and 

sewer systems, and telecommunications services. We reported in 2006 

that tribal officials and government agencies said that conditions on tribal 

lands have made successful economic development more difficult than in 

other parts of the country because the high cost and small markets 

associated with investment on tribal lands deter business investment. We 
Page 6 GAO-16-222 Telecommunications

found that this was particularly true for businesses such as Internet 

providers that must build out infrastructure to serve tribal lands.6

 

Customers generally subscribe to Internet through a fixed or mobile 

device. In-home fixed Internet plans are often sold as a monthly 

subscription by cable television or telephone companies. Consumers can 

connect a variety of devices to in-home fixed networks through a wired or 

wireless connection. Service is provided via different types of technology. 

Service from cable television companies is generally provided through the 

same coaxial cables that deliver television programming. Service from 

telephone companies is generally provided through traditional copper 

telephone lines—commonly referred to as digital subscriber line (DSL) 

service—or fiber-optic lines, which convert electrical signals carrying data 

into light and send the light through glass fibers. In areas where none of 

these wired connections exist, some carriers offer fixed wireless devices 

for home use. Advances in technology, such as the use of fiber optics and 

new wireless technologies have allowed providers to offer increasingly 

faster high-speed Internet that supports new services and applications 

such as streaming video. Only these faster speeds attained through fiber 

and other new technologies are considered high-speed Internet. In 2010, 

FCC stated that every household and business in America should have 

access to affordable advanced telecommunication service with a speed of 

at least 4 Mbps download and at least 1 Mbps upload and that this target 

should be re-set every four years. In January 2015, FCC adopted a 

speed benchmark at download speeds of at least 25 Mbps and upload 

speeds of at least 3 Mbps.7

 Generally, only cable or fiber can deliver this 

level of broadband service to consumers’ homes.

 6 GAO, Telecommunications: Challenges to Assessing and Improving 

Telecommunications for Native Americans on Tribal Lands, GAO-06-189 (Washington, 

D.C.: January 11, 2006).

7 In 2010, the National Broadband Plan stated that every household and business in 

America should have access to affordable broadband service with a speed of at least 4 

Mpbs download and at least 1 Mpbs upload. In January 2015, FCC adopted a speed 

benchmark at download speeds of at least 25 Mbps and upload speeds of at least 3 

Mbps. Inquiry Concerning the Deployment of Advanced Telecommunication Capability to 

All Americans in a Reasonable and Timely Fashion, and Possible Steps to Accelerate 

Such Deployment Pursuant to Section 706 of the Telecommunications Act of 1996, as 

Amended by the Broadband Data Improvement Act, GN Docket No. 14-126, 2015 

Broadband Progress Report and Notice of Inquiry on Immediate Action to Accelerate 

Deployment, 30 FCC Rcd 1375, paras. 3 and 45 (2015 Broadband Progress Report).
Page 7 GAO-16-222 Telecommunications

Mobile service is provided through cell tower coverage with data 

transmitted over the radio spectrum.8

 Traditionally, mobile service 

providers sold access to the Internet as an option to mobile telephone 

service plans. A number of devices may connect to mobile high-speed 

networks, such as smart phones, tablets, and mobile devices that enable 

laptops to connect to a wireless service. 

The federal government has recognized the difficulties of providing 

services on tribal lands, and has maintained several ongoing programs to 

increase Internet availability and access in unserved areas. The USDA’s 

Rural Utilities Service (RUS) and FCC are responsible for several 

programs designed to improve the nation’s telecommunications 

infrastructure. RUS’s programs focus on rural telecommunications 

development, while FCC’s programs under the Universal Service Fund 

(USF) focus on providing support for areas where the cost of providing 

services is high, as well as for low-income consumers, schools, libraries, 

and rural health care facilities. All of these programs, which are 

discussed in more detail later in this report, seek to expand high-speed 

Internet access and can benefit tribal lands and their populations.

The American Recovery and Reinvestment Act of 2009 (Recovery Act)9

authorized other, one-time federal programs such as the Broadband 

Initiatives Program10 and the Broadband Technologies Opportunities 

Program11 to expand high-speed Internet access in unserved areas, 

including on tribal lands. The Recovery Act also directed FCC to develop 

a national broadband plan to ensure every American had access to highspeed Internet service. In March 2010, FCC issued the National 

Broadband Plan that included a centralized vision for achieving 

 8 The radio spectrum is the radio frequency (RF) portion of the electromagnetic spectrum. 

In the United States, regulatory responsibility for the radio spectrum is divided between 

the Federal Communications Commission (FCC), which administers spectrum for nonfederal use and the National Telecommunications and Information Administration (NTIA), 

which administers spectrum for federal use.

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

10 USDA’s RUS awarded over $3.2 billion for 320 projects under the Broadband Initiatives 

Program, primarily for projects expected to provide broadband service directly to end 

users in rural areas, including community facilities such as schools, libraries and hospitals.

11 The Recovery Act provided $4.7 billion to establish the Broadband Technology 

Opportunities Program through which the National Telecommunications and Information 

Administration awarded competitive grants to a variety of entities for broadband 

infrastructure, public computer centers, and to increase broadband access and adoption.
Page 8 GAO-16-222 Telecommunications

affordability and maximizing use of high-speed Internet to advance 

community development, health care delivery, education, job creation, 

and other national purposes.12 With regard to tribal lands, the Plan 

recommended that the Commission increase its commitment to 

government-to-government consultation with tribal leaders and consider 

increasing tribal representation in telecommunications planning. In July 

2010, FCC announced the creation of the Office of Native Affairs and 

Policy. The office was tasked to promote the deployment and adoption of 

communication services and technologies throughout tribal lands and 

native communities, by, among other things, ensuring the recommended 

consultation with tribal governments and native organizations. Officials 

from the Office of Native Affairs and Policy said that the office has helped 

to facilitate, draft, analyze, and advise on policy issues affecting Native 

communities as part of FCC’s decision-making process.

Tribal officials we interviewed said they place a high priority on 

institutional and personal Internet access because of the numerous 

benefits, including the following.

• Economic Development: Officials from most tribes said high-speed 

Internet is essential for economic development such as finding 

employment or establishing online businesses. FCC also found that 

community access to Internet services is critical in facilitating job 

placement, career advancement, and other uses that help to stimulate 

economic activity. For example, a resident of an Alaska Native Village 

operates a tour company and stated that the booking, communication, 

 12 FCC, Connecting America: The National Broadband Plan (Washington, D.C.: 2010).

Selected Tribes and 

Providers Identified 

Opportunities and 

Barriers Related to 

Increasing HighSpeed Internet 

Access

Selected Tribes Identified 

the Importance of Internet 

to Their Communities and 

All Selected Tribes Had 

Some Internet Service
Page 9 GAO-16-222 Telecommunications

and advertising of the business are completely reliant on a satellite 

Internet connection. However, the unreliable Internet service quality 

made booking customers and working with online tourism companies 

challenging. 

• Education: Officials from many tribes stated that high-speed Internet 

access at schools supports educational success. For example, access 

can allow students to conduct online testing or to watch online 

lectures, according to officials from two tribes we interviewed. In 

addition, officials from some tribes said that students who had access 

at school, but not at home were disadvantaged compared to their 

peers who had access at home.

• Health: About half of the tribes said that high-speed Internet access to 

support telemedicine was important to the tribe, particularly in rural or 

remote areas.

Officials from all of the tribes we interviewed also said that Internet 

service existed on at least some of their lands at varying connection 

speeds, ranging from less than 1 Mbps to over 25 Mbps. Some of the 

tribes we interviewed had at least some fiber optic high-speed Internet 

connections while the others had slower copper lines, only mobile 

service, or only satellite service. Moreover, while many of the tribal lands 

where we held interviews had some level of mobile Internet service, only 

a few tribal lands had 4G mobile high-speed Internet services and a few 

others had no mobile service. Further, officials from about half of the 

tribes we interviewed described important limitations to their Internet 

services, including higher than usual costs, small data allocations, slow 

download speeds, and unreliable connections. For example, officials from 

the Quileute tribe said that connection problems caused by heavily 

congested networks forced them to upload the required reports to federal 

grant websites after regular business hours. 
Page 10 GAO-16-222 Telecommunications

The interrelated barriers of rugged terrain and rural location characteristic 

of many tribal lands, as well as tribal members’ limited ability to pay for 

high-speed Internet service were tribes’ and private providers’ most 

commonly cited impediments to improvements in high-speed Internet 

service. FCC’s Office of Native Affairs and Policy reported in 2012 that 

rural, remote, and rugged terrain increase the cost of installing, 

maintaining, and upgrading Internet infrastructure.13 It also reported that

affordability of these services among tribal members is affected by often 

endemic levels of poverty, as discussed later in this report. Internet 

providers said that these barriers can deter private investment in 

infrastructure needed to connect remote towns and villages to a service 

provider’s core network—known as the middle mile. Middle-mile 

infrastructure may include burying fiber optic or copper cables, stringing 

cable on existing poles, or erecting towers for wireless microwave links, 

which relay wireless Internet connections from tower to tower through 

radio spectrum. Figure 2, below, illustrates some of the options for 

middle-mile Internet service delivery deployment infrastructure.

Figure 2: Types of Middle-Mile Internet Service Delivery Infrastructure

 13 FCC Office of Native Affairs and Policy, 2012 Annual Report, (Washington, D.C.: 2012).

Selected Tribes and 

Providers Said that 

Rugged and Remote 

Terrain are Barriers for 

Increasing Internet Access 

on Tribal Lands 
Page 11 GAO-16-222 Telecommunications

Many tribal officials and all six providers we interviewed listed rugged 

terrain and the rural location of many tribal lands as challenges to 

deploying this infrastructure to tribal lands. Tribal lands located far from 

urban areas may not have middle-mile infrastructure necessary for highspeed Internet deployment to their lands. More specifically, interviewees 

discussed the remoteness or distance from existing high-speed Internet 

networks in urban and suburban centers; the vastness of reservation 

lands; low population density; rugged terrain characteristics such as hills, 

forests, mesas, and rocks; and, in some places, a lack of basic services 

such as roads, addresses, and commercial power. Figure 3 from the 

remote village of Beaver, Alaska, which is not connected to a road 

network and is only accessible by plane, illustrates some of these 

characteristics. The building shown is connected only via satellite, 

because there is no fixed or wireless Internet service in Beaver. 

Residents of Beaver told us that satellite Internet is a poor substitute for 

land-based middle-mile infrastructure because it is slower, less reliable, 

includes restrictive caps on data usage, and suffers from regular blackout 

periods.

Figure 3: A Building in Beaver, Alaska Serviced with a Satellite Internet Connection
Page 12 GAO-16-222 Telecommunications

The terrain and lack of basic services tend to increase the cost of building 

and maintaining the middle-mile infrastructure, compared to costs in 

urban settings. For example, the Lac du Flambeau and Menominee tribes 

in Wisconsin live on reservations with dense, tall forests, and microwave 

towers must be tall enough—sometimes as high as 250 feet—in order to 

transmit the high-speed Internet signal above the tree canopy, according 

to tribal officials. Additionally, Alaska’s permafrost and seasonal thaw 

makes it difficult to lay fiber optic cables, according to service provider 

officials. Finally, one provider in the Southwest United States said it has

only been able to deploy limited service on the Navajo Nation land 

because it spans more than 24,000 square miles, and many of the remote 

areas are not served by commercial power. 

The limited financial resources available to tribal households were also 

cited by tribal officials and providers we interviewed as a barrier to highspeed Internet access. Of the 21 tribes we interviewed, many reported 

poverty and affordability as drivers of low subscribership to existing 

Internet services or as a barrier to broadening the availability of services. 

Poverty rates among the tribes we interviewed varied, but many were well 

above the 2014 national average of 15.5 percent, as is common for tribal 

lands. Figure 4 below shows the poverty rates for the 21 tribes we 

interviewed. 

Selected Tribes and 

Providers Said that 

Poverty Constrains 

Internet Adoption on Tribal 

Lands
Page 13 GAO-16-222 Telecommunications

Figure 4: 2013 Poverty Rates among Tribes GAO Interviewed

Note: Because no poverty rate data exist for the Bad River Band of Lake Superior Tribe of Chippewa 

Indians, they were omitted from this chart.

For example, the Menominee reservation and Pueblo of Laguna each 

have poverty rates of 35-36 percent according to Census’ 2013 American 

Community Survey, which collects demographic, social, economic and 

housing data. For the Rosebud Sioux, the poverty rate is 47 percent. 

Officials from the Menominee tribe said tribal households still cannot 

afford Internet service. For the Pueblo of Laguna, tribal officials reported 

that residents often choose mobile Internet options because they cannot 

afford separate phone and Internet service. Officials from the 

Confederated Tribes of Salish and Kootenai said that when tribal 

households can afford Internet, they can afford only the slowest download 

speeds available. 

Some tribes we interviewed said they are served by a single provider, and 

officials from five of those tribes reported their provider charging what 

they described as high prices for limited service. In Bethel, Napaskiak, 

and Oscarville, Alaska, residents reported that while they had Internet 

access through a regional service provider, this provider’s services had 

low data allocations that subscribers routinely exceeded and paid 
Page 14 GAO-16-222 Telecommunications

penalties as a result. Moreover, officials from Bethel said that applicants 

for tribal housing assistance with outstanding debt of more than five 

percent of their income from unpaid mobile Internet bills were ineligible for 

this assistance. Also according to these officials, when an Internet 

customer had an outstanding bill, the local provider would shut off their 

phone. The customer had to pay back this outstanding balance before 

they could get their phone turned back on and qualify for housing 

assistance. In the housing application round for Bethel that occurred just 

before our June 2015 visit, 13 of 38 applicants were rejected due to their 

delinquent Internet bills, according to data provided by the tribe. Tribal 

officials said that this was typical, and that it can take up to a year to pay 

off these bills due to the limited income opportunities in the region. 

Two of the providers we interviewed discussed non-payment among tribal 

households as a disincentive to Internet service provision. One provider 

said that the customers it serves on tribal lands had non-payment rates 

double that of other customer groups, and that these rates often follow 

seasonal employment patterns. Officials from another Internet provider 

said that high poverty had led tribal customers’ accounts to fall into 

delinquency and be subsequently disconnected from service. According 

to some of the tribes we interviewed, limited finances led many tribal 

households to opt out of purchasing service or not being able to keep up 

payments for service they did purchase. 

About half of the tribes we interviewed told us that a lack of tribal 

members with sufficient bureaucratic and technical expertise is a barrier 

to increasing high-speed Internet access on tribal lands. Tribal officials 

said that tribal members do not always have the bureaucratic expertise 

required to apply for federal funds, which can lead to mistakes or the 

need to hire consultants. Officials of the Ute tribe, for example, described 

submitting application paperwork for federal funding several times before 

being accepted because of multiple federal officials asking for different 

edits. Some tribes reported spending resources on outside consultants to 

handle the application process. For example, the Mississippi Choctaw 

told us they hired a full-time grant writer to manage their E-rate 

application when they had difficulty applying for E-rate on their own.14 

The consultant confirmed that there is a steep learning curve to the 

process and not all tribes would have the money or time to have a 

 14 FCC’s Universal Service Program for Schools and Libraries, commonly known as the Erate program, helps schools and libraries to obtain affordable broadband.

About Half of Tribes 

Reported That They Lack 

the Capacity to Apply for 

Federal funds or Design 

High-Speed Internet 

Networks
Page 15 GAO-16-222 Telecommunications

member overcome the learning curve while fulfilling other tribal 

responsibilities. Further, according to officials, Unalakleet’s regional 

school district contracts out the E-rate application process to a consultant 

for $22,000 annually. The district receives about $5 million in E-rate 

funding annually to subsidize its schools’ high-speed Internet connection. 

Additionally, Lac du Flambeau officials said they spent funds on lawyers, 

consultants, and engineers who they had hired to assist them in applying 

for federal funding.

Lack of technical expertise also affects tribes’ ability to interact with 

private-sector Internet providers. For the seven tribes we interviewed that 

either had a tribally owned provider or were in the process of establishing 

one, three of them said that the lack of expertise in the tribe was a 

challenge to establishing a tribally-owned telecommunications provider for 

high-speed Internet deployment. In addition, Salish and Kootenai officials 

recounted a meeting with several providers as part of a federal assistance 

application requirement. The officials said that none of the tribal officials 

understood the providers’ plans and as a result were not able to represent 

the tribe’s best interests. Further, officials from the Pueblo of Laguna 

highlighted that they will need ongoing investment in employee training to 

ensure that their knowledge keeps pace with technological developments 

and infrastructure upgrades. 

The National Broadband Plan recognized the challenges of administrative 

and technical capacity and recommended that FCC and Congress 

support technical training and capacity development on tribal lands, such 

as by considering additional funding for tribal leaders to participate in 

FCC training at no cost. In the early 2000s, FCC held a number of Indian 

Telecommunications Initiatives Regional Workshops and Roundtables. In 

fiscal year 2012, the Office of Native Affairs and Policy consulted with 

about 200 tribal nations, many during six separate one- to three-day 

telecommunications training and consultation sessions on tribal lands. 

These included the Native Learning Labs, where attendees could, for 

example, learn about data the FCC has available on spectrum licensing

and USF programs, among other things. Recently, the Office held seven 

training workshops in fiscal year 2014 and fiscal year 2015, and plans to 

offer more in fiscal year 2016. The goal of this new series of sessions is 

to provide tribal officials with information about funding opportunities and 

policy changes with respect to high-speed Internet, USF programs, and 

spectrum issues.
Page 16 GAO-16-222 Telecommunications

FCC and USDA implement mutually supportive interrelated high-speed 

Internet access programs that offer assistance to tribes and the providers 

that serve tribal lands. FCC’s and USDA’s programs have similar goals to 

increase access to Internet on tribal lands and they both offer funding to 

either tribal entities or service providers to achieve this goal of increased 

access. Further, both FCC and USDA programs have eligibility 

requirements based on the need of an area as well as deployment 

requirements. Tribes sometimes qualify for benefits from more than one 

of these programs, either directly or through private-sector Internet 

providers. Tribal officials we interviewed said that both FCC’s and 

USDA’s programs were important for the expansion of high-speed 

Internet service on their lands.

The FCC has programs that provide subsidies or discounts to improve 

telecommunications services, including services on tribal lands. These 

programs have a longstanding goal of making communications services 

available “so far as possible to all the people of the United States.” The 

Telecommunications Act of 1996 extended the scope of federal universal 

service to support and make advanced telecommunications services 

available to eligible public and nonprofit elementary and secondary 

schools, libraries, and nonprofit rural health care providers at discounted 

rates. Today, the goals of these programs include increasing access to 

Internet service for all consumers at reasonable and affordable rates. 

Three universal service programs subsidize telecommunications carriers 

Interrelated Federal 

Programs Promoting 

High-Speed Internet 

Access on Tribal 

Lands Are Not Always 

Well Coordinated

FCC and USDA HighSpeed Internet Programs 

are Interrelated
Page 17 GAO-16-222 Telecommunications

that provide high-speed Internet and other telecommunications services 

to areas that include tribal lands:15 

• The Connect America Fund (CAF)—formerly the High Cost 

Program—was established to extend high-speed Internet service to 

those areas that lack service, while preserving voice service. CAF 

provides subsidies to Internet providers to supplement their operating 

costs for providing high-speed Internet in unserved or high-cost areas. 

In total, the High Cost and Connect America Fund distributed about 

$20 billion in subsidies to providers between 2010 and 2014, portions 

of which went to providers that serve tribal lands.16 

• The USF Schools and Library Support Program, also known as Erate, provides discounts to eligible schools and libraries on 

telecommunications services, Internet access, and internal 

connections. In total, the E-rate program provided about $13 billion in 

discounts to schools and libraries between 2010 and 2014, portions of 

which went to schools and libraries on tribal lands.

• The Healthcare Connect Fund provides assistance to ensure eligible 

rural health care providers have access to high-speed Internet 

services and supports the formation of regional health care provider 

networks. Although the Healthcare Connect Fund does not 

specifically target tribal institutions, assistance may be provided to a 

service provider (or group of providers) that serve tribal lands. The 

Healthcare Connect Fund started in 2014 and provided about $52 

million to healthcare facilities in fiscal year 2014, a portion of which 

went to tribal lands. For example, tribal officials said that the 

Healthcare Connect Fund helped fund telemedicine carts that access 

high-speed Internet connections to send patient data including 

pictures and X-rays to regional hospitals to reduce costs, (see figure 

5). 

 15 The Lifeline and Link-Up Program provides subsidies to low-income customers so that 

telecommunications service is more affordable. In the Lifeline Modernization Order and 

FNPRM, adopted in June 2015, the FCC sought comment on expanding Lifeline to 

support broadband.

16 Due to a lack of specific data, we were unable to determine the portion that went to 

tribal lands from each of the USF programs.
Page 18 GAO-16-222 Telecommunications

Figure 5: Picture of High-Speed Internet-Enabled Telemedicine Cart from the Village 

of Nenana, AK

In addition to general programs that include tribal beneficiaries, FCC has 

also implemented efforts designed specifically to address concerns of 

Tribal and Native Communities. For example, in 2000 FCC began its 

Tribal Lands Bidding Credit Program to provide incentives to wireless 

providers to deploy wireless services on tribal lands. FCC is authorized 

to auction radiofrequency spectrum to be used for wireless services in the 

United States. Under the Tribal Lands Bidding Credit program, FCC 

grants bidding credits to a winning bidder in a spectrum auction if the 

bidder deploys facilities and provides telecommunications services to 

qualifying tribal lands.17 In total, the program has awarded credits to 53 

 17 The agreement under the program includes constructing and operating a wireless 

system that offers service to at least 75 percent of the tribal land area covered by the 

credit within 3 years of the grant of the license. Tribal lands with telephone subscribership 

below 85 percent are eligible for the program.
Page 19 GAO-16-222 Telecommunications

licensees that have pledged to deploy facilities and provide 

telecommunications services on 13 tribal lands.

More recently, in 2012 when FCC made reforms to universal service, it 

created the Mobility Fund under the Connect America Fund. Phase I of 

the Mobility Fund, which began in fiscal year 2012, provided $300 million 

of one-time support to extend the availability of wireless voice and highspeed Internet networks in areas where they were not available, including 

tribal lands. It also established a separate, one-time Tribal Mobility fund, 

which awarded $50 million in fiscal year 2014. Phase II of the Mobility 

fund will have a budget of $500 million, of which $100 million is 

designated as support for tribal lands. FCC has not set a date for the 

awarding of these funds.

According to some tribes and five of the six service providers we 

interviewed, FCC’s USF subsidies have helped expand high-speed 

Internet throughout tribal lands for tribal institutions, such as schools, 

libraries, and clinics. Further, building out the Internet service delivery 

infrastructure for schools and clinics with USF support allows service 

providers to begin offering household access in remote areas as well, 

according to two providers we interviewed. For example, one service 

provider said that Internet service would not exist in the majority of Alaska 

without USF’s E-rate and Healthcare Connect Fund programs. FCC’s 

programs made Internet service possible in the remote villages of 

Napaskiak and Oscarville, Alaska. These villages were only accessible by 

boat or plane and did not have roads or running water, but they did have 

Internet. According to officials, the best connections in both villages were 

in the USF supported schools and clinics, and officials from the regional 

school district serving the two villages said students rely on the highspeed Internet networks and the schools hope to use e-books since flying 

textbooks to rural Alaska is expensive. Figure 6 depicts the microwave 

tower in Oscarville, Alaska, which completes the middle-mile wireless 

signal that it conveys to the school, clinic, and households in the village.
Page 20 GAO-16-222 Telecommunications

Figure 6: Wireless Microwave Internet Tower in Oscarville, Alaska

RUS programs also provide support to improve rural telecommunications 

infrastructure—including high-speed Internet—through grants, loans, and 

loan guarantees. RUS programs seek to extend high-speed Internet 

access in rural communities, where it is least likely to be commercially 

available, but where it can improve the quality of life, education, 

healthcare, and community development. Eligible participants in RUS 

programs can include federally recognized tribes. Assistance from RUS 

can be used to build out new or improve existing telecommunication 

infrastructure in rural areas, which include many of the tribal lands, 

through two programs: 

• The Distance Learning and Telemedicine program provides grants to 

rural communities to acquire technologies that use the Internet to link 

educational and medical professionals with people living in rural 

areas. In total, the Distance Learning and Telemedicine program 

provided about $128 million in grants and loans between 2010 and 

2014, almost $3 million of which went to tribal lands.

• The Community Connect Program provides grants to rural 

communities to provide high-speed Internet service to unserved 

areas. In total, the Community Connect Program provided about $53 
Page 21 GAO-16-222 Telecommunications

million in grants between 2010 and 2014, almost $3 million of which 

went to tribal lands.

Officials from some tribes, three of which operate tribally owned service 

providers, said that USDA RUS grant and loan programs or RUS stimulus 

funding efforts through the Recovery Act were important in the expansion 

of Internet throughout tribal lands for tribal institutions. In addition, officials 

from one Internet provider in Alaska said that RUS funding was important 

for allowing them to build high-speed Internet infrastructure in rural areas, 

including Native Villages. 

FCC’s and USDA’s programs that promote high-speed Internet access in 

tribal lands are interrelated in that they all seek to increase this access in 

areas that include tribal lands. For example, FCC’s Health Care Connect 

and USDA’s Distance Learning and Telemedicine programs both seek to 

assist clinics connect to the Internet, including those on tribal lands. 

These programs are not always well coordinated. Our body of work has 

shown that interagency coordination can help agencies with interrelated 

programs ensure efficient use of resources and effective programs.18 

Agencies can enhance and sustain their coordinated efforts by engaging 

in key practices, such as establishing compatible policies and procedures 

through official agreements.19 Agencies can also develop means to 

operate across agency boundaries, including leveraging resources across 

agencies for joint activities such as training and outreach.20 

One area lacking coordination between FCC and USDA is their outreach 

and technical assistance efforts when planning visits to tribes or 

conference attendance. Synchronizing these activities could be a 

resource-saving mechanism. However, both FCC and USDA 

independently conduct outreach and training efforts for related programs 

promoting Internet access. For example, FCC was authorized to spend 

up to $300,000 on tribal consultation and training in fiscal year 2015. 

While FCC officials said they invite USDA officials to FCC training 

workshops and are sometimes invited to USDA training workshops, they 

 18 GAO, Managing for Results: Barriers to Interagency Coordination, GAO/GGD-00-106, 

(Washington, D.C.: March 29, 2000).

19 GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022, (Washington, D.C.: September 27, 2012).

20 GAO, Fragmentation, Overlap, and Duplication: An Evaluation and Management Guide, 

GAO-15-49SP, (Washington, D.C.: April 14, 2015).

Outreach and Training 

Efforts for Interrelated 

Programs Are Not Always 

Well Coordinated
Page 22 GAO-16-222 Telecommunications

said that they do not coordinate to develop joint outreach or training 

events. This could result in an inefficient use of limited federal resources 

and missed opportunities for resource leveraging between the two 

agencies and cost-savings to the tribes attending training events. For 

example, while USDA held a training event in Washington State in fiscal 

year 2015, FCC hosted a training event in Oregon the same year. The 

two agencies could have planned a joint training event in the Pacific 

Northwest Region and each contributed towards the costs of the event 

while reducing the cost burdens for tribes, who would not have had to 

travel twice or choose between the two training events given limited 

budgets. Officials from one tribe said that multiple federal programs 

offering similar grants were confusing and that a federal one-stop-shop 

for outreach and training would help them better target the right programs 

for their situation. Officials from a different tribe said that the tribe benefits 

from FCC programs but not USDA programs, in part, because tribal 

officials did not have a strong understanding of the USDA programs that 

might benefit their community’s Internet access. Better coordination on 

conferences, as feasible, could help FCC and USDA reach a broader 

audience and increase the value of their outreach to tribes.

In 2006, we found that the rate of Internet access on tribal lands was 

unknown because no federal survey had been designed to capture this 

information. We recommended that additional data be identified to help 

assess progress towards providing access to telecommunications, 

including high-speed Internet, for Native Americans living on tribal 

lands.21 Since then, the federal government has started collecting data 

on Internet availability and access on tribal lands.

 21 GAO-06-189.

Federal Government 

is Gathering Data, but 

FCC Lacks 

Performance Goals 

and Measures for the 

Internet on Tribal 

Lands

The Federal Government 

is Gathering Data on 

Internet Availability and 

Adoption in Households 

on Tribal Lands
Page 23 GAO-16-222 Telecommunications

The National Telecommunications and Information Administration (NTIA) 

and FCC have collected data on high-speed and broadband Internet 

availability nationwide, including on tribal lands. Specifically, in 2011, 

NTIA, in cooperation with the FCC and the states began publishing the 

National Broadband Map, an interactive website that allows users to view 

information on high-speed Internet availability across the United States, 

including tribal lands. The website provides several types of maps 

including the availability of high-speed Internet based on the type of 

technology (DSL, copper, fiber, or wireless); maximum advertised upload 

and download speeds; the number of service providers; and provider 

service areas. In addition, the website allows users to analyze data by 

specific speeds, availability, or geographic location, as well as other 

characteristics and supporting data. The data to support the National 

Broadband Map is collected from service providers, including those 

offering service to federally recognized Indian tribes, including Alaska 

Native Villages. From 2010 through June 2014, the service providers 

submitted data to the states, which then submitted the data to NTIA. NTIA 

then passed the data to the FCC to be processed and incorporated. 

Currently, service providers submit the broadband deployment data 

directly to FCC. The website provides data on Internet availability on 

approximately 318 federal Indian reservations and associated trust lands, 

including upload and download speeds for both wireline and wireless 

service; technology for Internet delivery; and the number of Internet 

service providers. Figure 7 below shows selected National Broadband 

Map website information for the Quinault Indian Nation in Washington 

State.

Data on Internet Availability in 

Households on Tribal Lands
Page 24 GAO-16-222 Telecommunications

Figure 7: Example of National Broadband Map Website Information About Tribal 

Lands 

We did not examine the reliability of the National Broadband Map data, 

but we asked federal officials, service providers, and tribes about its 

accuracy. While the National Broadband Map provides information about 

high-speed Internet availability, according to NTIA officials, the map is 

based on Census blocks.22 If a service provider reported any availability 

of high-speed Internet in a Census block, the entire block was counted as 

 22 Census blocks are the basis for all geographic boundaries for which the Census Bureau 

tabulates data. Census blocks are statistical areas bounded by visible features such as 

roads, streams, and railroad tracks, and by nonvisible boundaries such as property lines, 

city, township, school district, county limits, and short line-of-sight extensions of roads.
Page 25 GAO-16-222 Telecommunications

served. This could create misrepresentations of service in rural areas, 

which generally constitute large Census blocks. Because much of tribal 

land is rural, the reported broadband service is shown to be greater than 

actual service available on tribal lands, according to NTIA officials. 

Further some tribal officials said that some areas were inaccurate. For 

example, the map showed the Lac du Flambeau reservation as covered, 

because two providers reported that they provide Internet service on the 

reservation. According to tribal officials, the National Broadband Map 

exaggerated the level of service on their reservation making them unable 

to compete for some USF and RUS programs. Tribal officials said that 

they canvassed the area and documented coverage problems in an 

unsuccessful effort to correct the map. However, five of the six providers 

we interviewed said that the reliability of the National Broadband Map has 

improved over time. One provider indicated that in rural areas, it is more 

difficult to get accurate data because in some cases addresses are not 

used, making it difficult to link service to a census block. However, in the 

future, this provider indicated that they planned to utilize GPS information 

to provide more accurate data.

In 2008, Congress passed the Broadband Data Improvement Act,23

which required the Bureau of the Census to collect information from 

residential households, including those on tribal lands, on Internet 

adoption, as to whether a computer is owned or used at the residence, if 

the household subscribes to Internet service, and if so, whether that 

service is dial-up or a high-speed connection.

Census began collecting the required data on Internet adoption beginning 

with the 2013 American Community Survey (ACS). The survey collects 

information on demographic, social, economic and housing 

characteristics. The ACS is distributed to approximately 295,000 

addresses across the country each month (over 3.5 million per year). 

According to Census officials, five years of ACS data must be collected to 

provide data for areas with smaller populations; the first data release with 

five years’ worth of computer and internet use data will be the 2013-2017 

5-year ACS, which will be released in late 2018. Census officials said 

that this data will provide an estimate for Internet adoption nationwide, 

including the first estimates for hard to reach populations such as Native 

Americans. 

 23 Pub. L. No. 110-385, 122 Stat. 4096 (2008).

Data on Internet Adoption by 

Households on Tribal Lands
Page 26 GAO-16-222 Telecommunications

FCC has made an important distinction between Internet availability and 

Internet adoption. Availability relates to the presence of Internet Service in 

an area, and adoption relates to people in the area subscribing to the 

Internet service. FCC’s strategic plan for fiscal years 2015-2018 includes 

a strategic goal related to Internet availability and ensuring that “all 

Americans can take advantage of the service...without artificial 

impediments.” This goal has a strategic objective to “maximize the 

availability of broadband Internet to all—including low income Americans, 

those in rural areas and tribal lands, and individuals with disabilities.” As 

we reported in June 2015, this represented a change from the previous 

strategic plan, which included a strategic objective to “maximize” 

broadband adoption with a related performance goal to “support and 

facilitate” broadband adoption. Noting that the change in the strategic 

plan from adoption to availability made it unclear as to which was the 

priority, we recommended that FCC revise its strategic plan to more 

clearly state if addressing adoption is a major function of the Commission 

and, if so, specify what outcomes they intend to achieve.24 In response, 

FCC commented that broadband adoption remains a significant focus. 

However, as of December 2015, FCC has not identified the performance 

goals and measures it intends to achieve for broadband availability or

adoption.

Agency performance measurement is the ongoing monitoring and 

reporting of program accomplishments, particularly towards preestablished goals. Performance measurement allows organizations to 

track progress in achieving their goals and provides information to identify 

gaps in program performance and plan any needed improvements. The 

GPRA Modernization Act of 2010 requires annual performance plans to 

include performance measures to show the progress the agency is 

making in achieving its goals. Further, we have identified best practices in 

articulating goals that include (among others): 

• Showing baseline and trend data for past performance and

 24 GAO, Broadband: Intended Outcomes and Effectiveness of Efforts to Address Adoption 

Barriers Are Unclear, GAO-15-473, (Washington, D.C.: June 2, 2015).

FCC Has Not Established 

Performance Goals and 

Measures for Internet 

Availability to or Adoption 

in Households on Tribal 

Lands
Page 27 GAO-16-222 Telecommunications

• Identifying projected target levels for performance for multi-year 

goals.25

The National Broadband Map is the most detailed source of Internet 

availability on tribal lands and the reliability of the data is improving. 

Providers are updating information and incorporating GPS information to 

correct inaccuracies, and FCC has a formal process for the public to 

report complaints. Map data are widely used by FCC currently to describe 

the availability of broadband nationwide. For example, FCC uses data 

gathered for the National Broadband Map in its annual Broadband 

Progress report provided to Congress as required by the

Telecommunications Act of 1996.26 Data supporting the National 

Broadband Map could be used, for example, to establish a baseline of 

high-speed Internet availability nationwide and on tribal lands. Making 

high-speed Internet, including broadband Internet, available to all 

Americans is FCC’s stated goal, but FCC has not set goals to 

demonstrate or measure progress toward achieving it. While the National 

Broadband Map does have some weaknesses, it provides the best 

current tool for setting goals and measuring progress toward increasing 

the availability of high-speed Internet on tribal lands. 

Although Census is gathering baseline information on household internet 

adoption, and the National Broadband Map provides data on high-speed 

Internet availability across the country, FCC lacks information to measure 

the outcomes of its E-rate program at tribal schools and libraries. FCC’s 

E-rate program provides assistance to schools, school districts, and 

libraries to obtain telecommunications technology, including high-speed 

Internet. E-rate does not specifically target tribal schools and libraries, 

although some are eligible and receive benefits. Since 2010, E-rate has 

committed more than $13 billion in service provider customer fees to 

schools and libraries, and according to data provided by FCC, and at 

least $1 billion of that amount supports tribal institutions.

 25 GAO, Agency Performance Plans: Examples of Practices that Can Improve Usefulness 

to Decisionmakers, GAO/GGD/AIMD-99-69, (Washington, D.C.: Feb. 1999). While the 

Government Performance and Results Act is applicable to the department or agency level, 

performance goals and measures are important management tools applicable to all levels 

of an agency, including the program, project, or activity level, consistent with leading 

practices and internal controls related to performance monitoring.

26 Pub. L. No. 104-104, § 706, 110 Stat. 56, 153 (1996).

Data Collected Does Not 

Allow FCC to Measure the 

Outcomes of its E-rate 

Program for Tribal 

Institutions
Page 28 GAO-16-222 Telecommunications

FCC’s strategic plan sets forth an objective for the E-rate program to 

ensure that all schools and libraries have affordable access to modern 

broadband technologies. Communicating what an agency intends to 

achieve and its programs for doing so are fundamental aims of 

performance management. Under the GPRA Modernization Act of 2010, 

an agency is expected to communicate the outcomes of its efforts. 

Specifically the act requires the agency to have outcome oriented goals 

for major functions and operations and an annual performance plan 

consistent with that strategic plan with measurable, quantifiable 

performance goals. Similarly, Federal Internal Control Standards state 

that operational and financial data are needed to determine whether or 

not an agency is meeting its strategic and annual performance goals.27 

However, FCC has not set any quantifiable goals and performance 

measures for its E-rate efforts to extend high-speed Internet in schools 

and libraries nationwide, or more specific performance measures for the 

same institutions on tribal lands.

FCC has noted the additional difficulties that tribal entities have in 

securing high-speed Internet on their lands, and directed efforts to 

address these difficulties in the E-rate Modernization Orders in 2014. 

According to federal internal control standards, management should 

ensure there are adequate means of obtaining information from external 

stakeholders that may have a significant impact on the agency meeting its 

goals. FCC collects information on E-rate recipients nationwide through 

questions on its application for E-rate assistance, including the type of 

organization requesting funding and the types of institutions served, such 

as public, private, tribal, or Head Start, among others. Several different 

types of institutions on tribal lands can qualify for E-rate funding, including 

schools operated by the tribe or Bureau of Indian Education, private 

schools operating on a reservation, as well as public school districts that

serve the reservation.28 FCC’s E-rate application provides for applicants 

to self-identify whether recipients of service on the application are tribal, 

but in this instance, provides no definition of "tribal." We found that not all 

schools and libraries on tribal lands identify themselves as such during 

the application process. FCC provided us with information on E-rate 

 27 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1999).

28 The Indian Self-Determination and Education Assistance Act of 1975 (ISDEA), Pub. L. 

No. 93-638 (1975), as amended, directs the U.S. Department of the Interior, at the request 

of a tribe, to contract with Indian tribes or tribal organizations to carry out the services and 

programs the federal government provides to Indians.
Page 29 GAO-16-222 Telecommunications

recipients between 2010 and 2014 that self-identified as tribal, and the 

amounts committed to those recipients. These data may understate the 

amount of funds supporting schools on tribal lands. Specifically, we 

identified more than 60 additional school districts, private schools, and 

public libraries on the lands of the 21 tribes we studied that received Erate assistance but were not included in FCC’s information on tribal 

recipients. FCC officials stated that they do not provide a definition 

because the increased formality might give applicants the incorrect 

impression that being a “tribal” institution has an effect on funding 

decisions. However, because FCC does not provide a definition for tribal 

in its E-rate application, it is unclear what level of tribal involvement or 

participation in an institution would cause it to be considered “tribal” on an 

application. For example, applicants may be unsure if a public school 

district, a private school, or public library that serves the general public on 

a reservation should indicate it is a tribal recipient on an application even 

if most students or patrons are tribal members. Further, according to FCC 

officials, it would be appropriate for such institutions to identify as tribal. 

Consequently, FCC does not have accurate information on the number of 

federally recognized tribes or Alaska Native Villages receiving E-rate 

support, or the amount being provided to them. Without more precise 

information and direction from FCC, the extent to which E-rate assistance 

is provided to tribal institutions cannot be reliably determined, nor can 

FCC rely on the information to develop quantifiable goals and 

performance measures for improving high-speed Internet access in tribal 

schools or libraries. It is important to understand how these programs 

affect tribal institutions because FCC has made improving high-speed 

Internet access in tribal institutions a priority following the National 

Broadband Plan, with the establishment of the Office of Native Affairs and 

Policy in 2010, and its current Strategic Plan.

Access to Internet on tribal lands varies but challenges to access and 

adoption remain. The high costs of infrastructure buildout on tribal lands, 

which tend to be remote and rugged terrain, work in tandem with tribal 

member poverty to create a barrier to high-speed Internet expansion on 

tribal lands. In addition, about half of the tribes we interviewed told us that 

the lack of tribal members with sufficient bureaucratic and technical 

expertise is a barrier to increasing high-speed access on tribal lands. 

FCC’s USF subsidy program and USDA’s RUS grant and loan programs 

seek to increase high-speed Internet access in underserved areas, 

including tribal lands, by assisting in building infrastructure and 

purchasing equipment as well as by paying for the ongoing operation of 

this infrastructure and equipment. While these programs have been 

important to improving high-speed Internet access on tribal lands, their 

efforts to further increase high-speed Internet on tribal lands could be 

Conclusions
Page 30 GAO-16-222 Telecommunications

limited by a lack of interagency coordination on training and outreach. 

Officials from one tribe said that multiple federal programs offering similar 

grants were confusing and officials from another tribe said that they 

accessed FCC programs but lacked a strong understanding of the USDA 

programs designed to increase Internet access. Through better 

coordination where feasible on joint training efforts to build tribal 

administrative and technical capacity, FCC and USDA could better 

ensure that their programs are efficient and remain mutually supportive 

and accessible to tribal governments. 

Despite the importance of FCC and USDA programs for expanding highspeed Internet on tribal lands, FCC has not established performance 

goals and measures related to improving Internet availability. However, 

data on broadband availability is readily available through the National 

Broadband Map to measure progress on efforts to improve broadband 

availability. Further, FCC’s subsidy programs also seek to increase highspeed Internet access on tribal lands, but the E-rate program lacks 

reliable data specific to institutions on tribal lands as well as goals and 

performance measures to track the outcomes of efforts on tribal lands. 

Not defining “tribal” in the E-rate application makes it difficult to measure 

the program’s impact on tribal lands as not all E-rate recipients serving 

these areas self-identify as tribal. Gathering such data is important for 

FCC because The National Broadband Plan has placed a special 

emphasis on improving access on tribal lands, and internal control 

standards call for management to be provided with data to determine 

whether or not it is meeting goals. Without such information, it will be 

difficult for FCC to determine the extent to which FCC is achieving its 

goals. 

To help improve and measure the availability and adoption of high-speed 

Internet on tribal lands, we recommend that the Chairman of the Federal 

Communications Commission take the following four actions:

• Develop joint outreach and training efforts with USDA whenever 

feasible to help improve Internet availability and adoption on tribal 

lands; 

• Develop performance goals and measures using, for example, data 

supporting the National Broadband Map, to track progress on 

achieving its strategic objective of making broadband Internet 

available to households on tribal lands;

• Improve the reliability of FCC data related institutions that receive ERate funding by defining “tribal” on the program application; and

Recommendations for 

Executive Action
Page 31 GAO-16-222 Telecommunications

• Develop performance goals and measures to track progress on 

achieving its strategic objective of ensuring that all tribal schools and 

libraries have affordable access to modern broadband technologies.

We provided copies of the draft report to the Federal Communications 

Commission, the U.S. Department of Agriculture, The U.S. Department of 

the Interior, and the U.S. Department of Commerce for comment prior to 

finalizing the report. We received technical comments that we 

incorporated as appropriate. We received written comments from FCC, 

which are reproduced in appendix III. FCC concurred with our 

recommendations and noted that it has efforts under way to address 

them. Regarding our recommendation for greater coordination on training 

and outreach, FCC summarized the areas in which it coordinates with 

USDA and said that it will continue to work with USDA to ensure more 

strategic and routine coordination. Regarding our recommendation to 

develop performance goals and measures for making broadband Internet 

available to households on tribal lands, FCC summarized its efforts to 

track broadband deployment on tribal lands. Regarding our 

recommendation to improve data reliability by defining “tribal” on the Erate funding application, FCC said that it plans to include guidance for Erate applicants to self-report as tribal if they serve tribal populations 

beginning in fiscal year 2017. Regarding our recommendation to develop 

performance goals and measures to track tribal schools and libraries 

access to broadband, FCC said that its goal is to provide all schools and 

libraries with broadband Internet, including tribal schools and libraries and 

that its efforts will substantially improve the accessibility of modern 

broadband technologies for tribal schools and libraries. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 5 days from the 

report date. At that time, we will send copies to FCC, USDA, and other 

interested parties. In addition, the report is available at no charge on 

GAO’s website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-6670 or Goldsteinm@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

Agency Comments
Page 32 GAO-16-222 Telecommunications

the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix III.

Mark Goldstein

Director, Physical Infrastructure Issues
Page 33 GAO-16-222 Telecommunications

List of Requesters

The Honorable Frank Pallone, Jr.

Ranking Member

Committee on Energy and Commerce

House of Representatives

The Honorable Anna G. Eshoo

Ranking Member

Subcommittee on Communications and Technology

Committee on Energy and Commerce

House of Representatives

The Honorable Ben Ray Luján

House of Representatives

The Honorable Don Young

House of Representatives

The Honorable Tom Cole

House of Representatives

The Honorable Derek Kilmer

House of Representatives

The Honorable Suzan DelBene

House of Representatives

The Honorable Jared Huffman

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 34 GAO-16-222 Telecommunications

You asked us to review the availability of broadband access on tribal 

lands. This report examines (1) perspectives of selected tribes and 

providers on the importance of Internet access for tribes and any barriers 

to increasing access to Internet on tribal lands; (2) the level of 

interrelation and coordination between federal programs at FCC and 

USDA that promote high-speed Internet access on tribal lands; and (3) 

existing data and FCC performance goals and measures related to 

access to Internet service on tribal lands and for tribal institutions.

To determine perspectives of selected tribes and providers on the 

importance of high-speed Internet and any barriers to increasing access 

to high-speed Internet on tribal lands, we reviewed relevant literature and 

interviewed officials from 18 tribal governments in the continental United 

States and 3 Alaska Native regions. For the three Alaska Native regions 

we interviewed, we visited villages within the region and spoke with 

officials from the Regional Corporation, regional nonprofit, Village 

Corporation, tribal government, and city government. Five of the 21 total 

tribes we interviewed operate their own Internet providers and two were 

considering forming a tribally-owned provider. We selected tribes to 

interview using FCC and USDA data from fiscal years 2010 through 2014 

and Bureau of the Census (Census) 2013 demographic data such as 

population and poverty rates. We selected tribes to include a range of 

population, poverty rates and locations. We used the same semistructured interview questions for all tribes. While we used the same 

questions, tribal officials may not have answered them in the same way. 

Additionally, we interviewed officials from six service providers operating 

on tribal lands. We selected service providers to interview using FCC 

High Cost Support data for fiscal years 2010 through 2014 and initial 

tribal interviews to identify providers that serve tribal lands and receive 

federal subsidies to do so. Furthermore, we identified and interviewed 

industry stakeholders such as research groups and telecommunications 

associations on their views regarding the barrier to increasing access to 

broadband on tribal lands. These stakeholders were selected based on 

their exposure to issues on tribal lands such as representing tribally 

owned service providers. These interviews are not generalizable to all 

tribes, all service providers or all industry stakeholders. 

To analyze the information we collected on barriers and potential 

solutions in our interviews, we identified themes and trends based on a 

literature review of recent FCC and research organization publications 

and preliminary interviews and developed a set of codes. After agreeing 

on the coding strategy and rules for the appropriate use of each code, 

one reviewer coded each carrier, tribal, and stakeholder interview using 

the agreed codes. Another team member then reviewed the coding for 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 35 GAO-16-222 Telecommunications

reasonable adherence to the strategy and rules. We then tallied coded 

responses and analyzed the themes identified through our interviews to 

determine the most prevalent challenges and solutions identified by our 

interviewees. For reporting purposes, we developed a series of indefinite 

quantifiers to describe the tribal responses from the 21 total tribal entities 

we interviewed that agreed with statements made in the report. Less 

than 5 of the 21 is “a few”, 5 to 9 is “some”, 10 to 12 is “about half”, 13 to 

16 is “many”, and 17 or more is “most”.

To determine the level of interrelation and coordination between federal 

programs at FCC and USDA that promote high-speed Internet access on 

tribal lands, we reviewed FCC and USDA program guidance materials 

and program funding for fiscal years 2010 through 2014, interviewed FCC 

and USDA officials, and interviewed tribal officials from the selected 21 

tribal governments or Alaska Native regions and 6 service providers 

about the federal government programs in which they participated. We 

evaluated USF and RUS program coordination based on criteria 

developed in previous GAO work.

1 First, we identified programs to 

examine. We selected FCC’s Universal Service Fund (USF) and USDA’s 

Rural Utilities Service (RUS) due to the high number of programs and the 

substantial appropriations amounts involved. Second, we gathered 

background information on these programs and identified relationships

among the programs. Third, we identified areas of coordination and 

possible gaps in coordination. Finally, we communicated these options to 

FCC and USDA officials to determine the feasibility of our proposed 

recommendations. 

To determine what data and FCC performance goals and measures exist 

related to access to high-speed Internet service on tribal lands and for 

tribal institutions, we analyzed fiscal year 2010 through fiscal year 2014 

USF data from FCC for tribal grantees or use on tribal lands; reviewed 

USF program applications and guidance materials; reviewed Bureau of 

Census five year data on telecommunication access from the American 

Community Survey; and interviewed FCC and Census officials. We 

determined that FCC and Census data were sufficiently reliable for our 

purposes by interviewing FCC and Census officials on their data 

 1 GAO, Fragmentation, Overlap, and Duplication: An Evaluation and Management Guide, 

GAO-15-49SP, (Washington, D.C.: April 14, 2015); GAO, Managing for Results: Barriers 

to Interagency Coordination, GAO/GGD-00-106, (Washington, D.C.: March 29, 2000); 

and. GAO, Managing for Results: Key Considerations for Implementing Interagency 

Collaborative Mechanisms, GAO-12-1022, (Washington, D.C.: September 27, 2012).
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-16-222 Telecommunications

collection and validation efforts. Finally, we reviewed performance goals 

and measures for USF programs according to criteria established in the 

Government Performance and Results Act of 1993, as amended2 and in 

federal standards for internal control.

3

We conducted this performance audit from February 2015 to January 

2016 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.

 2 Pub. L. No. 103-62, 107 Stat. 285 (Aug. 3, 1993) as amended by GPRA Modernization 

Act of 2010, Pub. L. No. 111-352 (2010).

3 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: Nov. 1999).
Appendix II: List of Tribes, Alaska Native 

Entities, Internet Service Providers, and Other 

Groups GAO Interviewed

Page 37 GAO-16-222 Telecommunications

Tribe or Alaska Native Village State

Alaska Native region of Bering Strait: Native Village of Unalakleet AK

Alaska Native region of Calista: Orutsararmiut Traditional Native Council, Native Village of Napaskiak, and 

Oscarville Traditional Village

AK

Alaska Native region of Doyon: Nenana Native Association and Beaver Village AK

Assiniboine and Sioux Tribes of the Fort Peck Indian Reservation MT

Bad River Band of Lake Superior Tribe of Chippewa Indians WI

Confederated Salish and Kootenai Tribes of the Flathead Reservation MT

Confederated Tribes of the Warm Springs Reservation OR

Hoh Indian Tribe WA

Lac du Flambeau Band of Lake Superior Chippewa Indians WI

Menominee Indian Tribe of Wisconsin WI

Mississippi Band of Choctaw Indians MS

Navajo Nation AZ, NM, and UT

Oneida Tribe of Indians of Wisconsin WI

The Osage Nation OK

Pueblo of Laguna NM

Quileute Tribe of the Quileute Reservation WA

Quinault Indian Nation WA

Rosebud Sioux Tribe SD

San Carlos Apache Tribe of the San Carlos Reservation AZ

Standing Rock Sioux Tribe of North and South Dakota ND and SD

Ute Indian Tribe of the Uintah and Ouray Reservation UT

Internet Service Providers

ACS Communications

AT&T

Century Link

Frontier

GCI Inc.

Verizon

Other Groups

National Tribal Telecommunications Association

National Congress of American Indians

NTCA – The Rural Broadband Association

Arizona State University, American Indian Policy Institute and School of Public Affairs

Office of Rural Business and Intergovernmental Affairs, Office of Governor, Alaska

Source: GAO. | GAO-16-222

Appendix II: List of Tribes, Alaska Native 

Entities, Internet Service Providers, and 

Other Groups GAO Interviewed
Appendix III: Comments from the Federal 

Communications Commission

Page 38 GAO-16-222 Telecommunications

Appendix III: Comments from the Federal 

Communications Commission
Appendix III: Comments from the Federal 

Communications Commission

Page 39 GAO-16-222 Telecommunications
Appendix III: Comments from the Federal 

Communications Commission

Page 40 GAO-16-222 Telecommunications
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 41 GAO-16-222 Telecommunications

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

In addition to the contact named above, Keith Cunningham, Assistant 

Director; Christopher Jones; Sarah Jones; Jeffery Malcolm; Josh 

Ormond; Cheryl Peterson; Carl Ramirez; Cynthia Saunders; Michelle 

Weathers; and Sarah Williamson made key contributions to this report.

Appendix IV: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(543356)
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