GAO 

United States Government Accountability Office

Report to Congressional Committees

RECOVERY ACT

Agencies Are 

Addressing Broadband 

Program Challenges, 

but Actions Are 

Needed to Improve 

Implementation 

November 2009 

GAO-10-80 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

November 2009

RECOVERY ACT

Agencies Are Addressing Broadband Program 

Challenges, but Actions Are Needed to Improve 

Highlights of GAO-10-80, a report to Implementation 

congressional committees 

Access to broadband service is 

seen as vital to economic, social, 

and educational development, yet 

many areas of the country lack 

access to, or their residents do not 

use, broadband. To expand 

broadband deployment and 

adoption, the American Recovery 

and Reinvestment Act (Recovery 

Act) provided $7.2 billion to the 

Department of Commerce’s 

National Telecommunications and 

Information Administration (NTIA) 

and the Department of 

Agriculture’s Rural Utilities Service 

(RUS) for grants or loans to a 

variety of program applicants. The 

agencies must award all funds by 

September 30, 2010. 

This report addresses the 

challenges NTIA and RUS face; 

steps taken to address challenges; 

and remaining risks in (1) 

evaluating applications and 

awarding funds and (2) overseeing 

funded projects. GAO reviewed 

relevant laws and program 

documents and interviewed agency 

officials and industry stakeholders. 

What GAO Recommends

The Secretaries of Commerce and 

Agriculture should ensure 

sufficient time to review 

applications in the second funding 

round, develop contingency plans 

for oversight beyond fiscal year 

2010, and develop program 

performance measures. The 

Secretary of Commerce should also 

set annual audit requirements for 

commercial grantees. NTIA and 

RUS agreed with GAO’s 

recommendations. 

Application evaluation and awards. NTIA and RUS face scheduling, staffing, 

and data challenges in evaluating applications and awarding funds. NTIA, through 

its new Broadband Technology Opportunities Program, and RUS, through its new 

Broadband Initiatives Program, must review more applications and award far 

more funds than the agencies formerly handled through their legacy 

telecommunications grant or loan programs, including NTIA’s largest legacy grant 

program, Public Safety Interoperable Communications (see fig.). NTIA and RUS 

initially proposed distributing these funds in three rounds, but recently adopted 

two rounds. To meet these challenges, the agencies have established a two-step 

application evaluation process that uses contractors or unpaid, independent 

experts for application reviews and plan to publish information on applicants’ 

proposed service areas to help ensure the eligibility of proposed projects. While 

these steps address some challenges, the upcoming deadline for awarding funds 

may pose risks to the thoroughness of the application evaluation process. In 

particular, the agencies may lack time to apply lessons learned from the first 

funding round and to thoroughly evaluate applications for the remaining rounds. 

Oversight of funded projects. NTIA and RUS will oversee a significant number 

of projects, including projects with large budgets and diverse purposes and 

locations. In doing so, the agencies face the challenge of monitoring these 

projects with far fewer staff per project than were available for their legacy grant 

and loan programs. To address this challenge, NTIA and RUS have hired 

contractors to assist with oversight activities and plan to require funding 

recipients to complete quarterly reports and, in some cases, obtain annual audits. 

Despite these steps, several risks remain, including a lack of funding for oversight 

beyond fiscal year 2010 and a lack of updated performance goals to ensure 

accountability for NTIA and RUS. In addition, NTIA has yet to define annual audit 

requirements for commercial entities funded under the Broadband Technology 

Opportunities Program. 

Recovery Act Broadband Programs Are Larger Than Legacy Programs

0 1,000 2,000 3,000 4,000 5,000

RUS legacy grant and loan

programs (FY 2002-2009)

RUS Broadband Initiatives

Program (FY 2009-2010)

NTIA other legacy grant

programs (FY 1994-2009)

NTIA Public Safety Interoperable

Communications Program (FY 2007)

NTIA Broadband Technology

Opportunities Program (FY 2009-2010)

NTIA and RUS programs

Source: GAO analysis of NTIA and RUS data.

Appropriations for Recovery Act broadband programs and average annual

appropriations for legacy programs (in million of dollars)

13

4,700

23

2,500

1,000

Legacy programs

Recovery Act programs

Note: Because RUS provides loans, in addition to grants, the award amount can exceed the appropriation. 

View GAO-10-80 or key components.

For more information, contact Mark L. 

Goldstein at (202) 512-2834 or 

goldsteinm@gao.gov. 
Page i GAO-10-80 

Contents 

Letter 1

Background 3 

NTIA and RUS Have Taken Steps to Address Challenges, Including 

Scheduling and Staffing, Associated With Evaluating 

Applications and Awarding Funds; However, Some Risks 

Remain 9 

NTIA and RUS Face Staffing Challenges in Overseeing Funded 

Projects, and Despite Steps Taken, Several Risks to Project 

Oversight Remain 18 

Conclusions 27 

Recommendations for Executive Action 29 

Agency Comments and Our Evaluation 30 

Appendix I Stakeholder Organizations or Individuals 

Interviewed 32 

Appendix II Comments from the Department of Agriculture 33 

Appendix III Comments from the Department of Commerce 40 

Appendix IV GAO Contact and Staff Acknowledgments 41 

Tables 

Table 1: Summary of Broadband Program Provisions in the 

Recovery Act 5 

Table 2: Estimated NTIA and RUS Full-Time-Equivalent Staff for 

Grant and Loan Programs 21 

Table 3: Annual Audit Requirements for BTOP and BIP Funding 

Recipients 25 

 Recovery Act 
Figures 

Figure 1: Recovery Act Broadband Program Milestones 8 

Figure 2: Average Annual Appropriations for NTIA 

Telecommunications and RUS Broadband Programs 10 

Figure 3: Average Annual Applications—NTIA 

Telecommunications and RUS Broadband Programs 12 

Abbreviations 

BIP Broadband Initiatives Program 

BTOP Broadband Technology Opportunities Program 

DHS Department of Homeland Security 

DOC Department of Commerce 

FCC Federal Communications Commission 

GPRA Government Performance and Results Act of 1993 

kbps kilobits per second 

NOFA Notice of Funds Availability 

NTIA National Telecommunications and Information Administration 

OMB Office of Management and Budget 

PSIC Public Safety Interoperability Communications 

RUS Rural Utilities Service 

USDA Department of Agriculture 

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

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

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necessary if you wish to reproduce this material separately. 

Page ii GAO-10-80 Recovery Act
Page 1 GAO-10-80 

 

United States Government Accountability Office

Washington, DC 20548 

 

November 16, 2009 

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 Henry A. Waxman 

Chairman 

The Honorable Joe Barton 

Ranking Member 

Committee on Energy and Commerce 

House of Representatives 

Increasingly, access to affordable broadband telecommunications1

 is 

viewed as critical to economic, educational, and social development. For 

example, broadband technology makes it possible for patients to visit local 

clinics and receive medical attention from specialists hundreds of miles 

away; allows students to access information not available from their local 

libraries; and gives school systems a means of using one teacher to 

provide advanced courses to students in multiple schools. According to 

the Federal Communications Commission (FCC), broadband technology is 

a key driver of economic growth. The ability to share large amounts of 

information at ever-greater speeds increases productivity, facilitates 

commerce, and drives innovation. Broadband is particularly critical in 

rural areas, where advanced communications can reduce the distances 

that isolate remote communities. Yet millions of Americans do not have 

access to, or do not use, broadband. 

1

The Federal Communications Commission (FCC) defined “broadband” as referring to 

advanced communications systems capable of providing high-speed transmission of 

services such as data, voice, and video over the Internet and other networks. However, for 

purposes of providing funding, the Department of Commerce and the Department of 

Agriculture define broadband as two-way data transmission with advertised speed of at 

least 768 kilobits per second (kbps) downstream and at least 200 kbps upstream from end 

users. 

 Recovery Act
 

Enacted on February 17, 2009, the American Recovery and Reinvestment 

Act2

 (Recovery Act) appropriated $7.2 billion3 to extend access to 

broadband throughout the United States. Of the $7.2 billion, $4.7 billion 

was appropriated for the Department of Commerce’s (DOC) National 

Telecommunications and Information Administration (NTIA) and $2.5 

billion for the Department of Agriculture’s (USDA) Rural Utilities Service 

(RUS). Specifically, the Recovery Act authorized NTIA, in consultation 

with FCC, to create the Broadband Technology Opportunities Program 

(BTOP) to manage competitive grants to a variety of entities for 

broadband infrastructure, public computer centers, and innovative 

projects to stimulate demand for, and adoption of, broadband. Of the $4.7 

billion, up to $350 million was available pursuant to the Broadband Data 

Improvement Act and for the purpose of developing and maintaining a 

nationwide map featuring the availability of broadband service, with some 

funds available for transfer to FCC for the development of a national 

broadband plan to help ensure that all people in the United States have 

access to broadband.4

 Similarly, RUS established the Broadband Initiatives 

Program (BIP) to make loans and to award grants and loan-grant 

combinations for broadband infrastructure projects in rural areas. 

This report is part of GAO’s ongoing efforts to monitor Recovery Act 

programs. In addition, it builds on prior reports by GAO and the Inspectors 

General of USDA, DOC, and FCC that found that broadband programs 

pose certain challenges—including difficulties in identifying broadband 

coverage, targeting rural areas, and completing projects—and may present 

risks of waste, fraud and abuse. Accordingly, this report addresses two 

questions: (1) what are the challenges and risks, if any, NTIA and RUS face 

in evaluating applications and awarding funds and the steps they have they 

taken to address identified risks, and (2) what are the challenges and risks, 

if any, the agencies face in overseeing funded projects and the steps they 

have taken to address identified risks? 

 

2

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

3

While this amount is substantial, it is small relative to the amount private industry invests. 

According to a major telecommunications association, broadband service providers invest 

approximately $60 billion a year in broadband. 

4

On July 8, 2009, NTIA published a Notice of Funds Availability (NOFA) and solicitation of 

applications to announce the availability of funds for the State Broadband Data and 

Development Grant Program pursuant to the authority provided in the American Recovery 

and Reinvestment Act of 2009, P. L. 111-5, 123 Stat. 115 (2009), and the Broadband Data 

Improvement Act, Title I, P. L. 110-385, 122 Stat. 4096 (2008). 74 Fed. Reg. 32545 (2009). 

Page 2 GAO-10-80 Recovery Act
 

To address these questions, we reviewed NTIA, RUS, and FCC program 

documentation. We also interviewed relevant staff from the three agencies 

regarding their agencies’ efforts to implement the broadband provisions of 

the Recovery Act. We reviewed relevant laws and regulations; guidance 

from the Office of Management and Budget (OMB), DOC, the Department 

Justice, and the Domestic Working Group, an intergovernmental audit 

community of 19 federal and state agencies; and prior GAO reports. We 

compared the agencies’ efforts to relevant laws, regulations, and guidance 

to identify strengths and weaknesses in their efforts. To determine what 

reporting and audit requirements will apply to recipients of NTIA and RUS 

funding, we reviewed the Single Audit Act,5

 agency regulations and 

documents, and OMB guidance, and interviewed agency officials. We 

reviewed these audit requirements to determine which requirements 

would apply to the different types of applicants, including commercial (for 

profit) applicants, nonprofit organizations, and state or local governments; 

we did not evaluate which audit requirements would be most effective for 

providing oversight of awarded funds. In addition, we did not evaluate 

how NTIA or RUS have reviewed and analyzed submitted audit reports in 

the past to determine the effectiveness of their review of these audit 

reports. Finally, we interviewed 15 stakeholders representing a range of 

interests, including associations representing wireline, wireless, cable, and 

satellite service providers; consumer advocates; telecommunications 

policy researchers; and state telecommunications regulators to obtain 

their views on the potential challenges and risks facing the agencies. See 

appendix I for a list of the stakeholders we interviewed. 

We conducted our work from April through November 2009 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. 

Both NTIA’s BTOP and RUS’s BIP programs focus primarily on broadband 

infrastructure deployment, but the programs have some differences based 

on provisions in the Recovery Act (see table 1). BTOP funds are intended 

Background 

 

5

31 U.S.C. ch. 75. 

Page 3 GAO-10-80 Recovery Act
 

to expand broadband access to unserved and underserved areas.6 BTOP 

funds can also be awarded to projects that promote broadband demand 

and adoption and provide equipment, training, and access for higher 

education, job creation, public safety and health, and other facilities that 

serve vulnerable populations. BIP focuses on rural areas7

 and its funds can 

be used solely for broadband infrastructure deployment. The agencies also 

have different project eligibility requirements. For example, the Recovery 

Act requires that BTOP applicants demonstrate that a project would not 

have been implemented during the grant period without federal grant 

assistance; the Recovery Act does not include a similar requirement for 

RUS broadband applicants.8

 

6

As defined in the NOFA, an “unserved” area is a proposed funded service area composed 

of one or more contiguous census blocks, where at least 90 percent of the households in 

the area lack access to facilities-based, terrestrial broadband service, either fixed or 

mobile, at advertised speeds of at least 768 kbps downstream and at least 200 kbps 

upstream. An “underserved” area is a proposed funded service area of one or more 

contiguous census blocks that meet at least one of the following criteria: (1) no more than 

50 percent of the households have access to facilities-based, terrestrial broadband service 

with advertised speeds of greater than 768 kbps downstream and at least 200 kbps 

upstream; (2) no fixed or mobile broadband service provider advertises service speeds of 

at least three megabits per second downstream in the proposed funded service area; or (3) 

the rate of broadband subscribership does not exceed 40 percent of the households in the 

proposed service area. 74 Fed. Reg. 33104, 33109 (2009). 

7

As defined in the NOFA, a rural area is any area, as confirmed by the latest decennial 

census of the Bureau of the Census, which is not located within (1) a city, town, or 

incorporated area that has a population of greater than 20,000 inhabitants or (2) an 

urbanized area contiguous and adjacent to a city or town that has a population of more 

than 50,000 inhabitants. 74 Fed. Reg. 33104, 33109 (2009). 

8

Pub. L. No. 111-5, div B, tit. VI, § 6001(e)(3). 

Page 4 GAO-10-80 Recovery Act
 

Table 1: Summary of Broadband Program Provisions in the Recovery Act 

Agencies 

Requirement NTIA BTOP RUS BIP 

Purpose Infrastructure: Provide access to consumers residing in 

unserved areas and improved access to consumers 

residing in underserved areas. 

Access and education: Provide broadband access, 

education, awareness, training, equipment, and support 

to schools, libraries, health care providers, job-creating 

strategic facilities, and other organizations serving 

vulnerable populations. 

Public safety: Provide improved access to, and use of, 

broadband service by public safety agencies. 

Sustainable adoption: Stimulate the demand for 

broadband, economic growth, and job creation. 

Infrastructure: Make funding available for grants, 

loans, and loan-grant combinations for broadband 

infrastructure in rural areas without sufficient access to 

high-speed broadband service to facilitate rural 

economic development. 

Funding $4.7 billion total funding with the following provisions: 

• not less than $4.35 billion for competitive broadband 

grants, including not less than $200 million for public 

computer centers, and not less than $250 million for 

sustainable broadband adoption programs; 

• $10 million for DOC Inspector General; 

• up to $350 million may be expended pursuant to the 

Broadband Data Improvement Act for the 

development and maintenance of a comprehensive, 

searchable, nationwide broadband inventory map; 

and 

• some of the funding may be transferred to FCC for 

development of a national broadband plan or other 

related purposed with appropriate notification to 

Congress. 

$2.5 billion for the cost of broadband grants, loans, 

and loan guarantees.a

Project eligibility Awardees must demonstrate that 

• the project conforms with statutory purposes; 

• the project would not have been implemented but for 

federal grant assistance; 

• the project budget is reasonable; and 

• the federal share will not exceed 80 percent of the 

total budget, except if the Secretary of Commerce 

grants a waiver for financial assistance.b

At least 75 percent of the area to be served by a 

project shall be in a rural area without sufficient 

access to high-speed broadband service to facilitate 

rural economic development as determined by the 

Secretary of Agriculture. 

Page 5 GAO-10-80 Recovery Act
 

 Agencies 

Requirement NTIA BTOP RUS BIP 

Priority for 

awarding funds 

The Assistant Secretary of Commerce for 

Communications and Information shall to the extent 

practical: 

(1) award at least 1 grant in each state; 

(2) consider whether an application to deploy 

infrastructure will, for the greatest population of users 

(a) increase affordability and subscribership; 

(b) provide the greatest broadband speed possible; 

(c) enhance service for health care, education, or 

children; and 

(d) not result in unjust enrichment through funding 

from another federal program; and 

(3) consider whether the applicant is a socially and 

economically disadvantaged small business. 

Priority shall be given to project applications that: 

(1) deliver end users a choice of more than one 

service provider; 

(2) provide service to the highest proportion of rural 

residents that do not have access to broadband 

service; 

(3) include current or former RUS telecommunications 

borrowers; 

(4) demonstrate that all project elements will be fully 

funded; 

(5) can commence and be completed; and 

(6) demonstrate that no area of a funded project may 

receive funding to provide broadband service under 

BTOP. 

Source: GAO analysis of Recovery Act broadband provisions. 

a

Although the Recovery Act included loan guarantees, RUS indicated that it would not offer loan 

guarantees. 

b

Awardees will be required to provide matching funds of at least 20 percent toward the total eligible 

project costs. State and local government applicants must demonstrate that they will appropriate 

funds required to meet the 20 percent match requirement. 

To implement the Recovery Act, NTIA and RUS will fund several types of 

projects. The agencies will fund last-mile and middle-mile network 

infrastructure projects to extend broadband service in unserved or 

underserved areas. According to NTIA and RUS, last-mile projects are 

those infrastructure projects whose predominant purpose is to provide 

broadband service to end users or end-user devices. Middle-mile projects 

mostly do not provide broadband service to end users or end-user devices, 

but instead provide relatively fast, large-capacity connections between 

backbone facilities—long-distance, high-speed transmission paths for 

transporting massive quantities of data—and last-mile projects. NTIA is 

also funding public computer centers and sustainable adoption projects. 

Both NTIA and RUS have experience with similar broadband grant or loan 

programs. Before receiving Recovery Act funding, NTIA implemented the 

Technology Opportunities Program; this program promoted the innovative 

use of information and communication technologies, primarily in 

underserved population segments, to promote public benefits. 

Additionally, NTIA implemented other, nonbroadband programs, such as 

the Public Safety Interoperability Communications (PSIC) program, which 

provides funding to public safety organizations; the digital television 

transition coupon program; and the Public Telecommunications Facilities 

Page 6 GAO-10-80 Recovery Act
 

Program, which provides funding to public broadcasters. RUS has prior 

and ongoing experience with several broadband-specific programs—

including the Rural Broadband Access Loan and Loan Guarantee 

(Broadband Access Loan) Program which funds the construction, 

improvement, and acquisition of facilities and equipment for broadband 

service in eligible rural communities, and the Community Connect 

broadband grant program, which funds broadband on a “communityoriented connectivity” basis to currently unserved rural areas for the 

purpose of fostering economic growth and delivering enhanced health 

care, education, and public safety services. 

To implement the broadband provisions in the Recovery Act, NTIA and 

RUS coordinated their efforts and developed program milestones (see 

fig. 1). OMB tasked agencies implementing Recovery Act programs to 

engage in aggressive outreach with potential applicants. NTIA and RUS, 

with FCC coordination, held a series of public meetings in March 2009, 

explaining the overall goals of the new broadband programs. NTIA and 

RUS also sought public comments from interested stakeholders on various 

challenges that the agencies would face in implementing the broadband 

programs through these meetings and by issuing a Request for 

Information. NTIA and RUS received over 1,500 comments. FCC, in a 

consultative role, provided support in developing technical definitions and 

participated in the first kick-off meeting. On July 1, 2009, Vice President 

Joe Biden, Secretary of Commerce Gary Locke, and Secretary of 

Agriculture Tom Vilsack announced the release of the first joint Notice of 

Funds Availability (NOFA) detailing the requirements, rules, and 

procedures for applying for BTOP grants and BIP grants, loans, and loangrant combinations.9

 Subsequently, the agencies held 10 joint 

informational workshops throughout the country for potential applicants 

to explain the programs, the application process, and the evaluation and 

compliance procedures, and to answer stakeholder questions. NTIA and 

RUS coordinated and developed a single online intake system whereby 

applicants could apply for either BTOP or BIP funding. NTIA and RUS 

initially indicated that they would award Recovery Act broadband program 

funds in three jointly-conducted rounds and initially expected to issue the 

NOFA for a second funding round before the end of calendar year 2009 

and for a third round in 2010. In a draft version of this report, we 

recommended that the agencies combine the second and third funding 

rounds. Subsequently, on November 10, 2009, the agencies announced that 

 

9

74 Fed. Reg. 33104 (2009). 

Page 7 GAO-10-80 Recovery Act
 

they would award the remaining program funds in one round, instead of 

two.10 Both BTOP and BIP projects must be substantially complete within 

2 years and fully complete no later than 3 years following the date of 

issuance of their award. 

date of 

Figure 1: Recovery Act Broadband Program Milestones 

2009

2010

2011

Source: GAO analysis of NTIA and RUS data.

Date Schedule

2009

2010

2011

Initial selections made (target date), agencies request documentation to verify application information.

Deadline for submitting documentation for further review. Due diligence review begins.

Begin awarding first round funds (target date)

Second RFI and NOFA published (target dates)

Finish awarding first round funds (target date)

February 17:

March 10: 

March 12: 

April 13: 

June 12: 

June 30: 

July 1: 

July 31: 

July 31: 

August 3:

August 14: 

August 20: 

August 24: 

September 14: 

September 15: 

October 15 (or 30

days after applicant

notified of selection): 

November 7:

October-December: 

December 31: 

All BTOP and BIP funds must be awarded. 

NTIA publishes national broadband map (statutory deadline)

March 1: NTIA broadband mapping data due (target date)

April-June: Third RFI and NOFA released (target dates)

September 30:

February 17:

Recovery Act signed 

Public outreach: RUS, NTIA, and FCC hold first of 7 joint meetings

First request for information (RFI) published, public comment period begins

Public comment period closes

RUS contractor selection (target date)

NTIA contractor selection (target date)

First notice of funds availability (NOFA) published by RUS and NTIA 

Electronic application system opens

RUS contractor selected (actual date)

NTIA contractor selected (actual date)

Deadline for application submission, initial review begins (target date) 

Extended deadline for all applications in progress by August 14 deadline

Extended deadline for all attachments for applications filed by August 20 

S

1

2

3

Program set-up activities

1st funding round activities

2nd funding round activities

3rd funding round activities

S

S

S

S

S

S

S

S

1

1

1

1

1

1

1

1

1

1

2

3

Initial proposed service areas published for public comment (target date).

 

10NTIA press release, NTIA and RUS Streamline Programs to Bring Broadband, Jobs to 

More Americans: Plan to Consolidate Final Two Funding Rounds, Seek Comment on 

Program Enhancements (Nov. 10, 2009). 

Page 8 GAO-10-80 Recovery Act
 

NTIA and RUS Have 

Taken Steps to 

Address Challenges, 

Including Scheduling 

and Staffing, 

Associated With 

Evaluating 

Applications and 

Awarding Funds; 

However, Some Risks 

Remain 

NTIA and RUS face scheduling, staffing, and data challenges in evaluating 

applications and awarding funds. The agencies have taken steps to meet 

these challenges, including the adoption of a two-step evaluation process, 

utilization of nongovernmental personnel, and publication of information 

on the applicant’s proposed service area. While these steps address some 

challenges, the agencies’ remaining schedule may pose risks to the review 

of applications. In particular, the agencies may lack the needed time to 

apply lessons learned from the first funding round and may face a 

compressed schedule to review new applications, thereby increasing the 

risk of awarding funds to projects that may not be sustainable or do not 

meet the priorities of the Recovery Act. 

NTIA and RUS Face 

Scheduling, Staffing, and 

Data Challenges in the 

Evaluation of Applications 

and Awarding of Funds 

Scheduling challenges. Under the provisions of the Recovery Act, NTIA 

and RUS must award all funds by September 30, 2010. Thus, the agencies 

have 18 months to establish their respective programs, solicit and evaluate 

applications, and award funds. While in some instances a compressed 

schedule does not pose a challenge, two factors increase the challenges 

associated with the 18-month schedule. First, while RUS has existing 

broadband programs, albeit on a much smaller scale than BIP, NTIA must 

establish the BTOP program from scratch. Second, the agencies face an 

unprecedented volume of funds and anticipated number of applications 

compared to their previous experiences. 

The volume of funds to be awarded exceeds previous broadband-related 

programs implemented by NTIA and RUS. While NTIA and RUS have prior 

experience in administering grant or loan programs, these programs had 

less budgetary authority than the programs in the Recovery Act (see fig. 2). 

Of the $7.2 billion appropriated in the Recovery Act, NTIA received $4.7 

billion for BTOP. In comparison, NTIA administered the PSIC program, a 

one-time grant program with an appropriation of about $1 billion for a 

single year, in close coordination with the Department of Homeland 

Security (DHS). Additionally, NTIA’s Public Telecommunications Facilities 

Program received an average of $23 million annually and its 

Telecommunications Opportunities Program received $24 million 

Page 9 GAO-10-80 Recovery Act
 

annually. RUS received $2.5 billion from the Recovery Act for BIP.11 In 

comparison, RUS’s Community Connect program’s average annual 

appropriation was $12 million and its Broadband Access Loan Program’s 

average annual appropriation was $15 million.12 According to preliminary 

information from the agencies, they received approximately 2,200 

applications requesting $28 billion in grants and loans in the first funding 

round. Based on the number of applications received and the funds 

requested, the average amount an applicant sought was $12.7 million, or 

almost half the size of the total average appropriation for NTIA’s 

Technology Opportunities Program. 

Figure 2: Average Annual Appropriations for NTIA Telecommunications and RUS Broadband Programs 

0 1,000 2,000 3,000 4,000 5,000

RUS Rural Broadband Access

Loan and Loan Guarantee

Program (FY 2003-2009)

RUS Community Connect

Grant Program (FY 2002-2009)

RUS BIP (FY 2009-2010)

NTIA Technology Opportunities Program (FY 1994-2004)

NTIA Public

Telecommunications Facilities

Program (FY 1996-2009)

NTIA Public Safety

Interoperable Communications

Program (FY 2007)

NTIA BTOP (FY 2009-2010)

NTIA and RUS programs

Source: GAO analysis of NTIA and RUS data.

Program appropriations for BTOP and BIP; and average annual appropriations for legacy programs (in million of dollars)

15

4,700

23

24

2,500

1,000

12

Legacy programs

Recovery Act programs

 

11RUS received $2.5 billion for both grants and the cost of loans. RUS stated that it will 

allocate $2 billion for grants and $500 million for loans. Based on the conditions prescribed 

by the Federal Credit Reform Act of 1990, RUS expects the $500 million allocation to 

support loans with a total principal amount of approximately $7 billion. 

12RUS officials indicated that, on average, the budget authority for these programs 

supported an estimated program level of $300-$400 million. 

Page 10 GAO-10-80 Recovery Act
 

Note: RUS’s loan allocation will support a principal amount exceeding the appropriation. For example, 

RUS expects the $500 million in budget authority allocated to loans under BIP will support a total 

program level of about $7 billion. Similarly, RUS officials indicated that the corresponding annual total 

loan level under the Broadband Access Loan Program was $300-$400 million. 

NTIA and RUS also face an increase in the number of applications that 

they must review and evaluate in comparison to similar programs (see fig. 

3). As mentioned previously, the agencies indicated that for the first round 

of funding alone, they received 2,200 applications.13 Of these 2,200 

applications, NTIA received 940 applications exclusively for BTOP and 

RUS received 400 applications exclusively for BIP and 830 dual 

applications for both programs. Both NTIA and RUS will review the dual 

applications; if RUS does not fund the project through the BIP program, 

NTIA can consider funding the project through the BTOP program. By 

comparison, NTIA received an average of 838 applications annually for the 

Telecommunications Opportunities Program; for PSIC, NTIA and DHS 

received 56 applications from state and territorial governments containing 

a total of 301 proposed projects. RUS received an average of 35 

applications annually for the Broadband Access Loan Program and an 

average of 105 applications annually for the Community Connect program. 

In addition, since BTOP and BIP will not carry over applications between 

rounds, applicants who do not receive funding in the first round must 

reapply to be eligible for consideration for funding in the second round. 

Therefore, a single proposed project may be evaluated multiple times by 

BTOP and BIP reviewers. Fourteen of 15 stakeholders with whom we 

spoke expressed concern that the agencies will face challenges in 

adequately reviewing the large number of expected applications in the 

time frame allotted. 

 

13Under the first funding round, NTIA will award up to $1.6 billion of its $4.7 billion 

budgetary authority, and RUS will award up to $2.4 billion in grants and loans. This $2.4 

billion is out of the projected $9 billion total award from RUS, not the $2.5 billion in 

budgetary authority. 

Page 11 GAO-10-80 Recovery Act
 

Figure 3: Average Annual Applications—NTIA Telecommunications and RUS Broadband Programs 

NTIA and RUS programs

Number of applications

Source: GAO analysis of NTIA and RUS data.

0 200 400 600 800 1,000 1,200 1,400 1,600 1,800 2,000

RUS Rural Broadband Access

Loan and Loan Guarantee

Program (FY 2003-2008)

RUS Community Connect

Grant Program (FY 2005-2008)

RUS BIP (first funding round)

NTIA Technology Opportunities

Program (FY 1994-2004)

NTIA Public Safety Interoperable

Communications Program (FY 2007)

NTIA BTOP (first funding round)

35

940

56a

838

105

Applications received

Applications reviewed by both BIP and BTOP

400 1,230

1,770

830

830

a

In 2007, through the Public Safety Interoperable Communications grant program, NTIA coordinated 

with DHS’s grants office to review 56 grant applications from states and territories, representing about 

301 individual projects, and awarded almost $1 billion in grant funds to assist public safety agencies 

in enhancing communications interoperability nationwide. 

Staffing challenges. NTIA and RUS will need additional personnel to 

administer BTOP and BIP. NTIA is establishing a new program with BTOP 

and will for the first time award grants to commercial entities. NTIA’s 

initial risk assessment indicated that a lack of experienced and 

knowledgeable staff was a key risk to properly implementing the program 

in accordance with the priorities of the Recovery Act. In its fiscal year 

2010 budget request to Congress, NTIA estimated that it will need 30 fulltime-equivalent staff in fiscal year 2009 and 40 more full-time-equivalent 

staff for fiscal year 2010. While RUS already has some broadband loan and 

grant programs in place and staff to administer them, it also faces a 

shortage of personnel. RUS’s staffing assessments indicated that the 

agency will need 47 additional full-time-equivalents to administer BIP. 

Prior to the Recovery Act, RUS had 23 full-time-equivalent staff in fiscal 

year 2008 for its Broadband Access Loan Program and no full-timeequivalent staff dedicated to the Community Connect program; RUS 

utilized personnel from the Broadband Access Loan Program for the 

Community Connect program. RUS indicated that it would have 

Broadband Access Loan Program staff also assist with BIP. 

Page 12 GAO-10-80 Recovery Act
 

Data challenges. NTIA and RUS lack detailed data on the availability of 

broadband service throughout the country that may limit their ability to 

target funds to priority areas. According to NTIA and RUS, priority areas 

include unserved and underserved areas. NTIA and RUS require applicants 

to assemble their proposed service areas from contiguous census blocks14

and to identify the proposed service area as unserved or underserved. 

However, RUS and NTIA will be awarding loans and grants before the 

national broadband plan or broadband mapping is complete. NTIA does 

not expect to have complete, national data on broadband service levels at 

the census block level until at least March 2010.15 Eight of 15 stakeholders 

with whom we spoke said that the agencies face challenges determining 

whether proposed service areas meet the requirements for underserved 

and unserved in order to effectively award funds. To work around this 

problem, the agencies plan to use existing FCC data16 on broadband 

service levels (Form 477 data) and state broadband service maps where 

available. However, the data collected by FCC are at the census tract level, 

not the census block level. In addition, although FCC and NTIA have 

discussed NTIA’s access to and use of the Form 477 data, the agencies 

have not developed formal procedures; RUS has not discussed use of the 

Form 477 data with FCC. Finally, not all states have broadband maps.17

 

14Census blocks are the smallest geographic areas for which the U.S. Bureau of the Census 

collects and tabulates decennial census data. Census blocks are formed by streets, roads, 

railroads, streams and other bodies of water, other visible physical and cultural features, 

and the legal boundaries shown on Census Bureau maps. 

15Under the Recovery Act, up to $350 million was available pursuant to the Broadband Data 

Improvement Act and for the purpose of developing and maintaining a nationwide map 

featuring the availability of broadband service. NTIA solicited grant applications from 

states for projects designed to collect data, develop state maps, conduct state planning, and 

deliver data to NTIA for the national broadband map. Grant applicants must complete the 

data collection by March 1, 2010. 74 Fed. Reg. 32545 (2009). 

16FCC collects information semiannually from service providers about broadband Internet 

access connections to households and businesses through its Form 477. 

17GAO, Telecommunications: Broadband Deployment Plan Should Include Performance 

Goals and Measures to Guide Federal Investment, GAO-09-494 (Washington, D.C.: May 12, 

2009). 

Page 13 GAO-10-80 Recovery Act
 

Two-step evaluation process. To address the scheduling and staffing 

challenges, NTIA and RUS are conserving scarce staff resources by 

screening applications and therefore reducing the number of applications 

subject to a comprehensive review by using a two-step process. In the first 

step, the agencies will evaluate and score applications based on the 

criteria delineated in the NOFA, such as project purpose and project 

viability. During this step, the agencies will select which applications 

proceed to the second step. After the first step is complete and the pool of 

potential projects is reduced, the agencies intend to conduct the second 

step—due diligence, which involves requesting extra documentation to 

confirm and verify information contained in an application. Since not all 

applications will proceed to the second step, not all applicants will be 

required to submit extra documentation. This will reduce the amount of 

information the agencies must review. In the NOFA, the agencies indicated 

that using this two-step process balances the burdens on applicants with 

the needs of the agencies to efficiently evaluate applications. 

NTIA and RUS Have Taken 

Steps to Address 

Challenges in Evaluating 

Applications and Awarding 

Funds 

Use of nongovernmental personnel. Both NTIA and RUS are using 

nongovernmental personnel to address anticipated staffing needs 

associated with evaluating applications and awarding funds. To evaluate 

applications, NTIA is using a review system, in which three unpaid, 

independent expert reviewers examine and score applications.18 To be 

considered an expert reviewer, the individual must have significant 

expertise and experience in at least one of the following areas: (1) the 

design, funding, construction, and operation of broadband networks or 

public computer centers; (2) broadband-related outreach, training, or 

education; or (3) innovative programs to increase the demand for 

broadband services. In addition, NTIA will use contractors in an 

administrative role to assist the expert reviewers. NTIA officials said that 

the agency issued three guides to be used by the reviewers for each of the 

three project categories—broadband infrastructure, public computer 

centers, and sustainable adoption—and conducted more than 15 Webbased training seminars. RUS will use contractors to evaluate and score 

applications. Both NTIA and RUS said that they are confident that an 

expert would be able to draw conclusions on the technical feasibility or 

the financial sustainability of a project based on information provided in 

the application. Regardless of who reviews the application, the final 

 

18NTIA released a Call for Reviewers on the www.broadbandusa.gov web site to solicit 

unpaid volunteer peer reviewers. 

Page 14 GAO-10-80 Recovery Act
 

selection and funding decisions are to be formally made by a selecting 

official in each agency. 

Publish applicant information. To address the challenge of incomplete 

data on broadband service, NTIA and RUS require applicants to identify 

and attest to the service availability—either unserved or underserved—in 

their proposed service area. In order to verify these self-attestations, NTIA 

and RUS will post a public notice identifying the proposed funded service 

area of each broadband infrastructure applicant. The agencies intend to 

allow existing service providers in the proposed service area to question 

an applicant’s characterization of broadband service in that area. 

According to the NOFA, existing service providers will have 30 days to 

submit information regarding their service offerings.19 If this information 

raises eligibility issues, RUS may send field staff to the proposed service 

area to conduct a market survey. RUS will resolve eligibility issues by 

determining the actual availability of broadband service in the proposed 

service area. Currently, NTIA has no procedures in place for resolving 

these types of issues, but said that it is developing these procedures using 

its contractors and other means. 

The Agencies’ Remaining 

Schedule May Pose Risks 

to the Review of 

Applications 

During the first funding round, the compressed schedule posed a challenge 

for both applicants and the agencies. As mentioned previously, NTIA and 

RUS initially proposed to utilize three separate funding rounds during the 

18-month window to award the entire $7.2 billion. As such, each funding 

round would operate under a compressed schedule. Eight of the 15 

industry stakeholders with whom we spoke expressed concern that a 

small entity would have difficulties completing an application in a timely 

manner. Specifically, some stakeholders said that small entities were 

having trouble locating the professional staff needed to assemble an 

application. The compressed schedule also posed challenges for the 

agencies. During the first funding round, the agencies missed several 

milestones. For example, RUS originally intended to select a contractor on 

June 12, 2009, and NTIA intended to select a contractor on June 30, 2009; 

however, both agencies missed their target dates, with RUS selecting its 

contractor on July 31, 2009, and NTIA selecting its contractor on August 3, 

2009. Also, the agencies intended to begin awarding the first-round grants 

and loans on November 7, 2009, but the agencies now expect to begin 

awarding funds in December 2009. 

 

1974 Fed. Reg. 33104, 33122. 

Page 15 GAO-10-80 Recovery Act
 

Because of the compressed schedule within the individual funding rounds, 

NTIA and RUS have less time to review applications than similar grant and 

loan programs. In the first funding round, the agencies have approximately 

2 months to review 2,200 applications. With other telecommunications 

grant and loan programs, agencies have taken longer to evaluate 

applications and award funds. For example, from fiscal year 2005 through 

2008, RUS took from 4 to 7 months to receive and review an average of 26 

applications per year for its Broadband Access Loan Program. NTIA 

officials acknowledged that the BTOP timeline is compressed compared 

with the timeline for the Public Telecommunications Facilities Program, 

which operated on a year-long grant award cycle. For the PSIC program, 

NTIA and DHS closed the application period in August 2007 and 

completed application reviews in February 2008, a period of roughly 6 

months. In California, the Public Utilities Commission took 4 to 6 months 

to review 54 applications and award funds for 25 projects in the first year 

of the California Advanced Services Fund, a $100 million broadband 

program. 

Based on their experience with the first funding round, on November 10, 

2009, NTIA and RUS reported that they will reduce the number of funding 

rounds from three to two. In the second and final funding round, the 

agencies anticipate extending the window for entities to submit 

applications. This change will help mitigate the challenges the compressed 

schedule posed for applicants in the first funding round. However, it is 

unclear whether the agencies will similarly extend the amount of time to 

review the applications and thereby bring the review time more in line 

with the experiences of other broadband grant and loan programs. NTIA 

officials indicated that the agency would like to award all $4.7 billion by 

summer 2010, to promote the stimulative effect of the BTOP program. RUS 

officials indicated that the agency will award all $2.5 billion by September 

30, 2010, as required by the Recovery Act, indicating a potentially longer 

review process. 

Depending on the time frames NTIA and RUS select, the risks for both 

applicants and the agencies may persist with two funding rounds. In 

particular, these risks include: 

• Limited opportunity for “lessons learned.” Based on the current 

schedule, NTIA and RUS will have limited time between the completion of 

the first funding round and the beginning of the second funding round. 

NTIA and RUS recently announced that the agencies will begin awarding 

funds for the first funding round in December 2009. On November 10, 

2009, the agencies sought public comment on approaches to improve the 

Page 16 GAO-10-80 Recovery Act
 

application experience and strengthen BTOP and BIP; the public has 14 

days to respond with comments following publication of the notice in the 

Federal Register. Because of this compressed time frame, applicants might 

not have sufficient time to analyze their experiences with the first funding 

round to provide constructive comments to the agencies. Further, the 

agencies might not have sufficient time to analyze the outcomes of the first 

round and the comments from potential applicants. As such, a compressed 

schedule limits the opportunity to apply lessons learned from the first 

funding round to improve the second round. 

• Compressed schedule to review applications. Due to the complex 

nature of many projects, NTIA and RUS need adequate time to evaluate 

the wide range of applications and verify the information contained in the 

applications. NTIA is soliciting applications for infrastructure, public 

computer center, and sustainable adoption projects. Therefore, NTIA will 

receive applications containing information responding to different 

criteria and it will evaluate the applications with different standards. Even 

among infrastructure applications, a wide variability exists in the 

estimates, projections, and performance measures considered reasonable 

for a project. For example, in RUS’s Broadband Access Loan Program, 

approved broadband loans for the highest-cost projects, on a cost-persubscriber basis, ranged as much as 15, 18, and 70 times as high as the 

lowest-cost project, even among projects using the same technology to 

deploy broadband. Previous experience with broadband loan programs 

also reveals the challenges inherent in evaluating an application based on 

estimates provided by the applicant. For example, as of fiscal year 2008, 55 

percent of RUS broadband loan borrowers were meeting their forecasted 

number of subscribers. Nine of the 15 stakeholders that we interviewed 

expressed concerns that NTIA and RUS lack staffing expertise to 

determine whether project proposals will generate sufficient numbers of 

subscribers and revenues to cover operating costs and be sustainable on a 

long-term basis. 

• Continued lack of broadband data and plan. According to NTIA, 

national broadband data provide critical information for grant making. 

Additionally, some stakeholders, including members of Congress, have 

expressed concern about awarding broadband grants and loans without a 

national broadband plan. Under the Recovery Act, up to $350 million was 

available pursuant to the Broadband Data Improvement Act to fund the 

development and maintenance of a nationwide broadband map for use by 

policymakers and consumers.20 NTIA solicited grant applications to help 

 

20Pub. L. No. 111-5, div. A, tit. II, 123 Stat. at 128 (2009). 

Page 17 GAO-10-80 Recovery Act
 

develop the national broadband map, and grant applicants must complete 

their data collection by March 1, 2010. Additionally, based on provisions in 

the Recovery Act, FCC must deliver to Congress a national broadband 

plan by February 17, 2010.21 To prepare the plan, FCC sought comment on 

a variety of topics, including the most effective and efficient ways to 

ensure broadband service for all Americans.22 By operating on a 

compressed schedule, NTIA and RUS will complete the first funding round 

before the agencies have the data needed to target funds to unserved and 

underserved areas and before FCC completes the national broadband 

plan. Depending on the time frames the agencies select for the second 

funding round, they may again review applications without the benefit of 

national broadband data and a national broadband plan. 

NTIA and RUS will need to oversee a far greater number of projects than 

in the past, including projects with large budgets and diverse purposes and 

locations. In doing so, the agencies face the challenge of monitoring these 

projects with far fewer staff per project than were available in similar 

grant and loan programs they have managed. To address this challenge, 

NTIA and RUS procured contractors to assist with oversight activities and 

will require funding recipients to complete quarterly reports and, in some 

cases, obtain annual audits. Despite the steps taken, several risks to 

adequate oversight remain. These risks include insufficient resources to 

actively monitor funded projects beyond fiscal year 2010 and a lack of 

updated performance goals for NTIA and RUS. In addition, NTIA has yet to 

define annual audit requirements for commercial entities funded under 

BTOP. 

NTIA and RUS Face 

Staffing Challenges in 

Overseeing Funded 

Projects, and Despite 

Steps Taken, Several 

Risks to Project 

Oversight Remain 

 

21Pub. L. No. 111-5, div. B, tit. VI, § 6001(k). 

22Federal Communications Commission, A National Broadband Plan for Our Future, 

Notice of Inquiry, 24 FCC Rcd 4342 (2009). 

Page 18 GAO-10-80 Recovery Act
 

NTIA and RUS will need to oversee a far greater number of projects than 

in the past. Although the exact number of funded projects is unknown, 

both agencies have estimated for planning purposes that they could fund 

as many as 1,000 projects each—or 2,000 projects in total—before 

September 30, 2010.23 In comparison, from fiscal year 1994 through fiscal 

year 2004, NTIA awarded a total of 610 grants through its Technology 

Opportunities Program—or an average of 55 grants per year. From fiscal 

year 2005 through fiscal year 2008, RUS awarded a total of 84 Community 

Connect grants, averaging 21 grants per year; and through its Broadband 

Access Loan Program, RUS approved 92 loans from fiscal year 2003 

through fiscal year 2008, or about 15 loans per year. 

A Large Number of 

Projects to Oversee 

Creates Staffing 

Challenges 

In addition to overseeing a large number of projects, the scale and 

diversity of BTOP- and BIP-funded projects are likely to be much greater 

than projects funded under the agencies’ prior grant programs. Based on 

NTIA’s estimated funding authority of $4.35 billion for BTOP grants and 

RUS’s estimated potential total funding of approximately $9 billion for BIP 

grants, loans, and loan-grant combinations, if the agencies fund 1,000 

projects each, as they have estimated, the average funded amount for 

BTOP and BIP projects would be about $4.35 million and $9 million, 

respectively. In comparison, from fiscal year 1994 to fiscal year 2004, 

NTIA’s average grant award for its Technology Opportunities Program was 

about $382,000, and from fiscal year 2005 to fiscal year 2008, RUS 

awarded, on average, about $521,000 per Community Connect grant 

award. Further, NTIA and RUS expect to fund several different types of 

projects that will be dispersed nationwide, with at least one project in 

every state.24 NTIA is funding several different types of broadband 

projects, including last- and middle-mile broadband infrastructure projects 

for unserved and underserved areas, and public computer center and 

sustainable broadband adoption projects. BIP can fund last- and middlemile infrastructure projects in rural areas across the country. 

 

23Based on the average request in the first funding round, NTIA and RUS may fund fewer 

projects than they originally estimated, but those funded projects may be of higher cost. 

For example, according to NTIA and RUS data, the average funding request for 

infrastructure projects in the first round was more than $20 million for BTOP, more than 

$12 million for BIP, and more than $15 million for projects requesting funding from either 

agency. If NTIA and RUS fund projects at the average requested funding amount—and 

based on the total available funding for the different types of projects—NTIA and RUS 

would award about 930 projects in total. 

24As required in the Recovery Act, NTIA shall, to the extent practical, award not less than 

one grant in each state. American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-

5, div. B, § 6001 (h) (1). 

Page 19 GAO-10-80 Recovery Act
 

Because of the volume of expected projects, NTIA and RUS plan to 

oversee and monitor BTOP- and BIP-funded projects with fewer staff 

resources per project than the agencies used in similar grant and loan 

programs (see table 2). In its fiscal year 2010 budget request to Congress, 

NTIA estimated that it would need a total of 70 full-time-equivalent staff 

for fiscal year 2010 to manage BTOP, which includes overseeing funded 

projects. After refining its spending and budget plans, NTIA said that it will 

need 41 full-time-equivalent staff for BTOP; at the time of our review, it 

had filled 33 of these positions. Based on NTIA’s estimate of funding 1,000 

projects and its estimated 41 full-time-equivalent staff needed, NTIA will 

have about 1 full-time-equivalent staff available for every 24 projects. 

Under the Technology Opportunities Program, NTIA had an average of 1 

full-time-equivalent staff in any capacity for every three projects funded 

annually from fiscal year 1994 through fiscal year 2004.25 NTIA reported 

that it is continually assessing its resources and is considering additional 

staff hires. Similarly, RUS reported that it will need 47 full-time-equivalent 

staff to administer all aspects of BIP, and the majority of these positions 

were to be filled by the end of September 2009. These 47 staff members 

are in addition to the 114 full-time-equivalent staff in the Rural 

Development Telecommunications program which support four existing 

loan or grant programs, including the Telecommunications Infrastructure 

loan program, the Distance Learning and Telemedicine loan and grant 

program, the Broadband Access Loan Program, and Community Connect 

grant program. If RUS funds a total of 1,000 projects, as estimated, based 

on the 47 staff assigned to BIP, it would have 1 staff of any capacity 

available for every 21 funded projects. Under its Broadband Access Loan 

Program, RUS had more than 1 full-time-equivalent staff for every loan 

made annually from fiscal year 2003 through fiscal year 2008. RUS 

reported that it could use other staff in the Rural Development 

Telecommunications program to address BIP staffing needs, if necessary. 

 

25In our review, we did not evaluate whether the per-project staffing levels available to 

NTIA for its Technology Opportunities Program or to RUS for its Broadband Access Loan 

program were sufficient or appropriate for those programs. 

Page 20 GAO-10-80 Recovery Act
 

Table 2: Estimated NTIA and RUS Full-Time-Equivalent Staff for Grant and Loan Programs 

Program 

Average number of projects 

funded per year 

Average full-timeequivalent staff per yearRatio of funded projects to fulltime-equivalent staff 

NTIA BTOP (FY 2010) 

(NTIA estimate) 

1,000 in FY 2010 41 24 to 1 

NTIA Technology 

Opportunities Programa

55 16 3 to 1 

RUS BIP (FY 2010) 

(RUS estimate) 

1,000 in FY 2010 47 21 to 1 

RUS Broadband Access 

Loan Programb

15 17 .9 to 1 

Source: GAO analysis of NTIA and RUS data. 

Note: In our review, we did not evaluate whether the per-project staffing levels available to NTIA for 

its Technology Opportunities Program or to RUS for its Broadband Access Loan Program were 

appropriate for those programs. 

a

NTIA Technology Opportunities Program data are for fiscal years 1994 through 2004. 

b

RUS Broadband Access Loan Program data are for fiscal years 2003 through 2008. RUS 

Community Connect Grant program data are not included here because RUS reported that it does 

not have full-time staff dedicated to this program. 

NTIA and RUS Are 

Addressing Project 

Oversight Challenges by 

Procuring Contractor 

Services and Requiring 

Funding Recipient Reports 

and Audits 

Contractor services. NTIA and RUS will use contractors to help monitor 

and provide technical assistance for BTOP and BIP projects, in addition to 

evaluating applications as discussed earlier. On August 3, 2009, NTIA 

procured contractor services to assist in a range of tasks, including 

tracking and summarizing grantees’ performance, developing grantmonitoring guidance, and assisting with site visits and responses to audits 

of BTOP-funded projects. Through its statement of work for contracted 

services, NTIA estimated that its contractor will provide about 35,000 

hours of support for grants administration and postaward support in 2010 

and about 55,000 hours of support for additional optional years.26 On July 

31, 2009, RUS awarded a contract to a separate contractor for a wide range 

of program management activities for BIP. RUS’s contractor will be 

responsible for a number of grant-monitoring activities, including 

developing a workflow system to track grants and loans; assisting RUS in 

developing project monitoring guidance and policies; and assisting in site 

visits to monitor projects and guard against waste, fraud, and abuse. 

 

26Based on an estimated 2,080 hours for a single staff year, the contracted hours 

correspond to 17 full-time-equivalent staff for grants administration and postaward duties 

in 2010 and about 26 full-time-equivalent staff for these duties in additional option years. 

Page 21 GAO-10-80 Recovery Act
 

In addition to its contractor, RUS intends to use existing field staff for 

program oversight. RUS reported that it currently has 30 general field 

representatives in the telecommunications program and 31 field 

accountants in USDA’s Rural Development mission area that may be 

available to monitor broadband programs. RUS field accountants conduct 

financial audits primarily within its telecommunications and electric utility 

loan programs. Two of the 30 general field representatives are dedicated to 

RUS’s broadband grant and loan programs, and RUS reported that the 

other general field representatives would be available to assist with BIP 

oversight if needed. Of the 47 full-time-equivalent staff that RUS has 

estimated needing to implement BIP, it plans to hire a total of 10 general 

field representatives and 10 field accountants on a temporary basis. In 

addition, RUS officials told us that Rural Development has an estimated 

5,000 field staff available across the country that support a variety of Rural 

Development loan and grant programs. Although these individuals do not 

have specific experience with telecommunications or broadband projects, 

according to RUS, this staff has experience supporting RUS’s business and 

community development loan programs, and this workforce could be used 

for project monitoring activities if there was an acute need. 

Recipient reports and audits. To help address the challenge of 

monitoring a large number of diverse projects, NTIA and RUS have 

developed program-specific reporting requirements that are intended to 

provide transparency on the progress of funded projects. Based on our 

review of the requirements, if NTIA and RUS have sufficient capacity to 

review and verify that information provided by funding recipients is 

accurate and reliable, these requirements could provide the agencies with 

useful information to help them monitor projects. The following reporting 

requirements apply to BTOP and BIP funding recipients: 

• General Recovery Act reports. Section 1512 of the Recovery Act and 

related OMB guidance requires all funding recipients to report quarterly to 

a centralized reporting system on, among other things, the amount of 

funding received or obligated, the project completion status, and an 

estimate of the number of jobs created or retained through the funded 

project. 27 Under OMB guidance, awarding agencies are responsible for 

ensuring that funding recipients submit reports to a central, online portal 

no later than 10 calendar days after each calendar quarter in which the 

 

27Pub. L. No. 111-5, div. A, tit. XV,§ 1512(c),(d) (2009). 

Page 22 GAO-10-80 Recovery Act
 

recipient receives assistance.28 Awarding agencies must also perform their 

own data quality review and request further information or corrections by 

funding recipients, if necessary. No later than 30 days following the end of 

the quarter, OMB requires that detailed recipient reports are made 

available to the public on the Recovery.gov Web site. 

• BTOP-specific reports. The Recovery Act requires BTOP funding 

recipients to report quarterly on their use of funds and NTIA to make these 

reports available to the public.29 NTIA also requires that funding recipients 

report quarterly on their broadband equipment purchases and progress 

made in achieving goals, objectives, and milestones identified in the 

recipient’s application, including whether the recipient is on schedule to 

substantially complete its project no later than two years after the award 

and complete its project no later than 3 years after the award. Recipients 

of funding for last- and middle-mile infrastructure projects must report on 

a number of metrics, including the number of households and businesses 

receiving new or improved access to broadband as a result of the project, 

the advertised and averaged broadband speeds and the price of the 

broadband services provided, and the total and peak utilization of network 

access links.30

• BIP-specific reports. RUS requires BIP funding recipients to submit 

quarterly balance sheets, income and cash-flow statements, and the 

number of customers taking broadband service on a per community basis, 

among other information. In addition, RUS requires funding recipients to 

specifically state in the applicable quarter when they have received 67 

percent of the award funds, which is RUS’s measure for “substantially 

complete.” BIP funding recipients must also report annually on the 

number of households; businesses; and educational, library, health care, 

and public safety providers subscribing to new or improved access to 

broadband. RUS officials reported that it plans to use quarterly reports to 

identify specific projects for on-site monitoring and to determine when 

 

28See OMB memorandum, M-09-21, Implementing Guidance for the Reports on Use of 

Funds Pursuant to the American Recovery and Reinvestment Act of 2009 (June 22, 2009). 

29Pub. L. No. 111-5, div. B, tit. VI, § 6001(i)(1) (2009). 

30In addition, BTOP recipients developing sustainable adoption and public computer 

centers must report a variety of project-specific information, such as the increase in the 

number of households, businesses, and community anchor institutions subscribing to 

broadband service and the primary uses of the public computer center. 74 Fed. Reg. 33104, 

33125. 

Page 23 GAO-10-80 Recovery Act
 

that monitoring should take place. 

NTIA and RUS also require some funding recipients to obtain annual, 

independent audits of their projects. The primary tool for monitoring 

federal awards through annual audits is the Single Audit report required 

under the Single Audit Act, as amended.31 We recently reported that the 

Single Audit is a valuable source of information on internal control and 

compliance for use in a management’s risk assessment and monitoring 

processes—and with some adjustments, we said, the Single Audit process 

could be improved for Recovery Act oversight.32 The Single Audit report is 

prepared in accordance with OMB’s implementing guidance in OMB 

Circular No. A-133.33 OMB’s Recovery Act guidance directed federal 

agencies to review Single Audit reports and provide a synopsis of audit 

findings to OMB relating to obligations and expenditures of Recovery Act 

funding. All states, local governments, and nonprofit organizations that 

expend over $500,000 in federal awards per year must obtain an annual 

Single Audit or, in some cases, a program-specific audit (referred to 

collectively in this report as a Single Audit). Commercial (for profit) 

entities awarded federal funding of any amount are not covered by the 

Single Audit Act, and states, local governments, and nonprofit 

 

3131 U.S.C. ch. 75. A Single Audit consists of (1) an audit and opinions on the fair 

presentation of the financial statements and the Schedule of Expenditures of Federal 

Awards; (2) gaining an understanding of and testing internal control over financial 

reporting and the entity’s compliance with laws, regulations, and contract or grant 

provisions that have a direct and material effect on certain federal programs (i.e., the 

program requirements); and (3) an audit and an opinion on compliance with applicable 

program requirements for certain federal programs. The audit report also includes the 

auditor’s schedule of findings and questioned costs, and the auditee’s corrective action 

plans and a summary of prior audit findings that includes planned and completed 

corrective actions. Auditors are also required to report on significant deficiencies in 

internal control and on compliance associated with the audit of the financial statements. 

Entities that expend federal awards under only one program may elect to have a programspecific audit in lieu of the Single Audit. 

32See GAO, Recovery Act: As Initial Implementation Unfolds in States and Localities, 

Continued Attention to Accountability Issues Is Essential, GAO-09-580 (Washington, D.C.: 

Apr. 23, 2009), and Recovery Act: States’ and Localities’ Current and Planned Uses of 

Funds While Facing Fiscal Stresses, GAO-09-831T (Washington, D.C.: July 8, 2009). 

33OMB Circular No. A-133, Audits of States, Local Governments, and Non-Profit 

Organizations, provides guidance to auditors on selecting federal programs for audit and 

the related internal control and compliance audit procedures to be performed. Under OMB 

Recovery Act guidance, funding recipients subject to an annual Single Audit must submit 

their financial reporting packages, which include independent Single Audit reports, within 

9 months after the end of the recipient’s fiscal year and the Single Audit reports are to be 

publicly available on the Internet. 

Page 24 GAO-10-80 Recovery Act
 

organizations expending less than $500,000 in federal awards per year are 

also not required to obtain an annual Single Audit under the Single Audit 

Act.34 RUS, however, requires all commercial recipients of BIP funds to 

obtain an annual, independent audit of their financial statements under 

requirements that also apply to RUS’s existing broadband grant and loan 

programs.35 However, RUS’s existing audit requirements are different from 

the Single Audit requirements.36 NTIA has yet to determine what annual 

audit requirements will apply to commercial grantees; NTIA reported that 

it intends to develop program-specific audit requirements and guidelines 

that will apply to commercial recipients that receive broadband grants and 

plans to have those guidelines in place by December 2009. See table 3 for a 

description of BTOP and BIP audit requirements. 

Table 3: Annual Audit Requirements for BTOP and BIP Funding Recipients 

Amount of federal awards 

expended annually Type of entity 

BTOP annual audit 

requirements 

BIP annual audit 

requirements 

More than $500,000 Nonprofit organizations, state and 

local government, or tribal authority

Single Audit, OMB Circular A133 Single Audit, OMB Circular A133 

Commercial organizations To be determined Financial statement audit, 

7 CFR 1773.3 

Less than $500,000 Nonprofit organizations, state and 

local government, or tribal authority

To be determined None 

Commercial organizations To be determined Financial statement audit, 

7 CFR 1773.3 

Source: GAO analysis of NTIA and RUS data. 

Several Risks to Project 

Oversight Remain 

Lack of sufficient resources beyond fiscal year 2010. Both NTIA and 

RUS face the risk of having insufficient resources to actively monitor 

BTOP- and BIP-funded projects after September 30, 2010, which could 

result in insufficient oversight of projects not yet completed by that date. 

 

34Under DOC regulations, for-profit hospitals and commercial and other organizations not 

subject to the Single Audit Act may be subject to an audit requirement to the extent one is 

included in the federal award document. See 15 C.F.R. § 14.26. 

357 C.F.R. § 1773.3. All RUS commercial grantees must obtain an annual audit of their 

financial statements by an independent, certified public accountant meeting the standards 

set by RUS. 

36For example, RUS audit requirements do not require an audit and opinions on the fair 

presentation of the Schedule of Expenditures of Federal Awards. 

Page 25 GAO-10-80 Recovery Act
 

As required by the Recovery Act, NTIA and RUS must ensure that all 

awards are made before the end of fiscal year 2010. Under the current 

timeline, the agencies do not anticipate completing the award of funds 

until that date. Funded projects must be substantially complete no later 

than 2 years, and complete no later than 3 years following the date of 

issuance of the award. Yet, the Recovery Act provides funding through 

September 30, 2010. The DOC Inspector General has expressed concerns 

that “without sufficient funding for a BTOP program office, funded 

projects that are still underway at September 30, 2010, will no longer be 

actively managed, monitored, and closed.”37 NTIA officials told us that 

NTIA has consulted with OMB about seeking BTOP funding after 

September 30, 2010, to allow it to close grants. RUS officials reported that 

given the large increase in its project portfolio from BIP, RUS’s capacity to 

actively monitor these projects after its BIP funding expires may be 

stressed. Without sufficient resources to actively monitor and close BTOP 

grants and BIP grants and loans by the required completion dates, NTIA 

and RUS may be unable to ensure that all recipients have expended their 

funding and completed projects as required. 

Lack of updated performance goals. The Government Performance and 

Results Act of 1993 (GPRA) directs federal agencies to establish objective, 

quantifiable, and measurable goals within annual performance plans.38

GPRA stresses the importance of having clearly stated objectives, strategic 

and performance plans, goals, performance targets, and measures in order 

to improve a program’s effectiveness, accountability, and service delivery. 

Specifically, performance measures allow an agency to track its progress 

in achieving intended results. Performance measures also can help inform 

management decisions about such issues as the need to redirect resources 

or shift priorities. 

NTIA has established preliminary program performance measures for 

BTOP, including job creation, increasing broadband access, stimulation of 

private sector investment, and spurring broadband demand. However, 

NTIA has not established quantitative, outcome-based goals for those 

measures. NTIA officials reported that the agency lacks sufficient data to 

 

37Department of Commerce, Office of Inspector General Recovery Act Flash Report: NTIA 

Should Apply Lessons Learned from Public Safety Interoperable Communications 

Program to Ensure Sound Management and Timely Execution of $4.7 Billion Broadband 

Technology Opportunities Program (Washington, D.C., March 2009). 

3831 U.S.C. § 1115. 

Page 26 GAO-10-80 Recovery Act
 

develop such goals and is using applications for the first round of funding 

to gather data, such as the expected number of households that will 

receive new or improved broadband service. According to NTIA officials, 

data collected from applications for the first funding round could be used 

to develop program goals for future funding rounds. 

RUS has established quantifiable program goals for its existing broadband 

grant and loan programs, including a measure for the number of 

subscribers receiving new or improved broadband service as a result of 

the programs. However, according to USDA’s fiscal year 2010 annual 

performance plan, RUS has not updated its goals to reflect the large 

increase in funding it received for broadband programs under the 

Recovery Act. In addition, RUS officials told us that the agency’s existing 

measure for the number of subscribers receiving new or improved 

broadband access as a result of its programs is based on the estimates 

provided by RUS borrowers in their applications. Consequently, these 

program goals do not reflect actual program outcomes, but rather the 

estimates of applicants prior to the execution of their funded projects. 

Undefined audit requirements for commercial recipients. At the time 

of our review, NTIA did not have audit requirements or guidelines in place 

for annual audits of commercial entities receiving BTOP grants. NTIA 

officials reported that because BTOP is the first program managed by 

NTIA to make grants to commercial entities, the agency does not have 

existing audit guidelines for commercial entities. However, NTIA reported 

that it intends to develop program-specific audit requirements and 

guidelines that will apply to commercial recipients that receive broadband 

grants, and it plans to have those guidelines in place by December 2009. 

Although award recipients that do not expend more than $500,000 per year 

in federal awards may not be subject to an annual audit requirement, NTIA 

officials reported that they do not yet know the extent to which they will 

make awards in this range. In the absence of clear audit requirements and 

guidelines for commercial recipients of BTOP funding, NTIA will lack an 

important oversight tool to identify risks and monitor BTOP grant 

expenditures. 

The Recovery Act established an ambitious schedule for NTIA and RUS to 

implement the broadband provisions. In particular, the agencies have 18 

months to establish their respective programs, solicit and evaluate 

applications, and award funds. Compounding the challenge, NTIA must 

establish the BTOP program from scratch, and the agencies face an 

unprecedented volume of funds and anticipated number of applications. 

Conclusions 

Page 27 GAO-10-80 Recovery Act
 

The agencies initially indicated that they would award Recovery Act funds 

in three rounds; but, on November 10, 2009, the agencies announced that 

they would consolidate the second and third funding rounds and award 

the remaining funds in a single, second funding round. However, the 

schedule of the new, second funding round is unclear. Based on the 

experience in the first funding round and their legacy grant and loan 

programs, the agencies might have little time to thoroughly review 

applications to ensure that funded projects meet the objectives of the 

Recovery Act. Without adequate time to gather lessons learned from the 

first funding round and to thoroughly review applications, the agencies 

risk funding projects that might not meet the objectives of the Recovery 

Act. 

In addition to reviewing an unprecedented number of applications, NTIA 

and RUS must oversee funded projects to ensure the projects meet the 

objectives of the Recovery Act and to guard against waste, fraud, and 

abuse. All funded projects must be complete no later than 3 years 

following the award of funds; therefore, some funded projects might not 

be complete until September 30, 2013. However, the Recovery Act only 

provided funding through September 30, 2010. Without adequate resources 

beyond fiscal year 2010, the agencies may not be able to ensure that all 

projects are completed as intended and to guard against waste, fraud, and 

abuse. 

Due to the compressed schedule and limited staff resources, NTIA and 

RUS have had limited time to develop outcome-based performance goals 

for their programs. However, the agencies use of sequential funding 

rounds provides them with an opportunity to collect important data from 

funding applicants early in the program that could be used to develop 

meaningful performance goals. For example, because applicants must 

provide estimates for and reports on the number of households and other 

entities that will receive new or improved broadband service as a result of 

the projects, NTIA and RUS should have a good basis to establish program 

goals for BTOP and BIP for the second funding round and to evaluate the 

effectiveness of federal spending for broadband deployment. Without such 

goals, future efforts to expand broadband deployment and adoption may 

lack important information on the types of projects that were most 

effective at meeting subscriber goals and other targets, thereby limiting 

the ability to apply federal resources to programs with the best likelihood 

of success. 

Finally, although NTIA and RUS have established a range of reporting 

requirements for funding recipients, NTIA has yet to define what annual 

Page 28 GAO-10-80 Recovery Act
 

auditing requirements, if any, will apply to commercial funding recipients 

under BTOP. Although we have previously reported that the Single Audit 

Act’s annual audit requirement is not a perfect tool to oversee Recovery 

Act funding, the absence of an annual audit requirement for commercial 

entities would hamper NTIA’s oversight of its Recovery Act funding. For 

example, NTIA would lack independent auditors’ assurances that its 

funding recipients have important internal controls in place to fully track 

expenditures and guard against fraud, waste, and abuse. 

We recommend that the Secretaries of Commerce and Agriculture take the 

following three actions: 

1. To reduce the risk of awarding funds to projects that may not be 

sustainable or do not meet the priorities of the Recovery Act 

Recommendations for 

Executive Action 

• delay the issuance of the second NOFA in order to provide time to 

analyze application and evaluation processes and apply lessons 

learned from the first funding round, and 

• provide review time in the second funding round comparable with 

other broadband grant and loan programs. 

2. To ensure that all funded projects receive sufficient oversight and 

technical support beyond September 30, 2010, and through their 

required completion dates, develop contingency plans to ensure 

sufficient resources for oversight of funded projects beyond fiscal year 

2010. 

3. To ensure that management has appropriate tools in place to evaluate 

the effectiveness of BTOP and BIP and to apply limited resources to 

achieve desired program outcomes, use information provided by 

program applicants in the first funding round to establish quantifiable, 

outcome-based performance goals by which to measure program 

effectiveness. 

We also recommend that the Secretary of Commerce take the following 

step: 

To ensure that NTIA has sufficient insight into the expenditure of federal 

funding by commercial entities that may receive BTOP grants, determine 

whether commercial entities should be subject to an annual audit 

requirement. 

Page 29 GAO-10-80 Recovery Act
 

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

Agriculture, to OMB, and to FCC for review and comment. In the draft 

report, we recommended that NTIA and RUS combine the second and 

third planned funding rounds into one extended funding round. The 

departments of Commerce and Agriculture agreed with our 

recommendations; FCC and OMB did not comment on our 

recommendations. Subsequently, on November 10, 2009, NTIA and RUS 

announced that they would award the remaining program funds in one 

round, instead of two. Therefore, we removed this recommendation from 

the final report. In its comments, NTIA noted that the agency will take all 

appropriate additional steps to apply the lessons learned and address 

GAO’s concerns, including utilizing experiences from the first round of 

funding to improve the program, establishing outcome-based performance 

measures, and implementing reasonable audit requirements for 

commercial grantees. NTIA’s full comments appear in appendix III. For the 

recommendations directed to RUS, RUS described steps it is exploring 

that are consistent with our first recommendation. RUS agreed with the 

second and third recommendations. FCC, NTIA, OMB, and RUS provided 

technical comments that we incorporated, as appropriate. 

Agency Comments 

and Our Evaluation 

In its comments, RUS noted that it has extensive experience awarding and 

managing grants and loans for rural America, including grants and loans 

for electric and telecommunications projects. RUS noted that by focusing 

on budget authority, our report does not reflect the true scope of its 

telecommunications programs. In particular, RUS noted that the 

Broadband Access Loan Program operated with a program level of $300 to 

$400 million. We chose to report the budget authority for the various 

programs to provide comparability between the grant and loan programs 

operated by NTIA and RUS. We acknowledge that RUS’s legacy programs 

operate at the program level exceeding the budget authority; however, the 

BIP program will also operate at a program level exceeding the $2.5 billion 

budget authority. RUS also noted that our report does not reflect the full 

scale of its existing staffing levels. In particular, RUS noted that it has 114 

full-time staff dedicated solely to telecommunications programs and 30 

General Field Representatives who can assist with oversight of the BIP 

program. In our report, we note the number of staff dedicated to RUS’s 

broadband programs, and we also note that RUS has additional staff, 

including 30 General Field Representatives, that the agency can draw upon 

for the BIP program. RUS’s full comments appear in appendix II. 

Page 30 GAO-10-80 Recovery Act
 

We are sending copies of this report to the Secretary of Agriculture, the 

Secretary of Commerce, the Director of the Office of Management and 

Budget, the Chairman of the Federal Communications Commission, and 

interested congressional committees. The report also is available at no 

charge on the GAO Web site at http://www.gao.gov. 

If you 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 

Mark L. Goldstein 

of this report. Major contributors to this report are listed in appendix IV. 

Director, Physical Infrastructure 

Page 31 GAO-10-80 Recovery Act
Appendix I: Stakeholder Organizations or Appendix I: Stakeholder Organizations or Individuals Interviewed 

Individuals Interviewed 

We conducted interviews with the following individuals or representatives 

from the following organizations: 

American Cable Association 

Alliance for Public Technology 

Robert C. Atkinson, Columbia Institute for Tele-Information 

California Public Utilities Commission 

Consumer Federation of America 

Communications Workers of America 

Dr. William Lehr, Massachusetts Institute of Technology 

National Association of Regulatory Utility Commissioners 

National Association of Telecommunications Officers and Advisors 

National Cable & Telecommunications Association 

National Telecommunications Cooperative Association 

Dr. Raul Katz, Columbia Institute for Tele-Information 

Satellite Industry Association 

United States Telecom Association 

Wireless Internet Service Providers Association 

Page 32 GAO-10-80 Recovery Act
Appendix II: Comments from the Department Appendix II: Comments from the Department of Agriculture 

of Agriculture 

Page 33 GAO-10-80 Recov ery Act
Appendix II: Comments from the Department 

of Agriculture 

Page 34 GAO-10-80 Recovery Act
Appendix II: Comments from the Department 

of Agriculture 

Page 35 GAO-10-80 Recovery Act
Appendix II: Comments from the Department 

of Agriculture 

Page 36 GAO-10-80 Recovery Act
Appendix II: Comments from the Department 

of Agriculture 

Page 37 GAO-10-80 Recovery Act
Appendix II: Comments from the Department 

of Agriculture 

Page 38 GAO-10-80 Recovery Act
Appendix II: Comments from the Department 

of Agriculture 

Page 39 GAO-10-80 Recovery Act
Appendix III: Comments from the Department Appendix III: Comments from the of Commerce 

Department of Commerce 

Page 40 GAO-10-80 Recovery Act
Appendix IV: GAO Contact and Staff Appendix IV: GAO Contact and Staff Acknowledgments 

Acknowledgments 

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

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

Director; Eli Albagli; Matt Barranca; Elizabeth Eisenstadt; Dean Gudicello; 

Tom James; Kim McGatlin; Sara Ann Moessbauer; Josh Ormond; and Mindi 

Weisenbloom made key contributions to this report. 

Page 41 GAO-10-80 Recovery Act

GAO Contact 

Staff 

Acknowledgments 

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