Children's Television Act: FCC Could Improve Efforts to Oversee Enforcement and Provide Public Information
Published: 2011-07-14T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The Children's Television Act of 1990 (CTA) and related Federal Communications Commission (FCC) rules restrict advertising during children's programs, whether aired by broadcast stations, cable operators, or satellite providers, and encourage broadcasters to air at least 3 hours per week of educational and informational programming for children (known as "core children's programming"). Broadcasters that certify in their license renewal application that they aired the minimum amount of core children's programming are eligible for expedited review. As requested, this report discusses (1) trends in children's programming, (2) FCC efforts to enforce the act, and (3) the extent to which parents value and use core children's programming. GAO analyzed FCC data, interviewed FCC and broadcast station officials, and conducted focus groups with parents.
section_title: What GAO Found
paragraphs: Broadcasters aired significantly more core children's programming in 2010 than in 1998, primarily because there are more broadcast channels and stations than there were then. An important source is multicasting, or the multiple channels aired by broadcasters since the digital television transition. Moreover, households increasingly rely on cable and satellite providers--to which core children's programming requirements do not apply--increasing the number of channels specifically targeted to children, but also increasing the impact of CTA and FCC's rules on advertising, which limit the duration of commercials and require their separation from children's programming on broadcast, cable, and satellite. Other media platforms, such as the Internet and MP3 players, are outside CTA's reach. FCC's reliance on broadcasters to self-report violations of CTA when they renew their operating licenses has resulted in about 7,000 violations of the advertising or public file rules resulting in fines of almost $3 million. The vast majority of violations were for exceeding advertising time limits. FCC has no comparable self-reporting enforcement approach to oversee cable operators' or satellite providers' compliance with these same advertising limits. Instead, FCC's oversight efforts have identified only seven violations by cable and satellite providers even though they televise much more children's programming than broadcasters. FCC has avoided developing specific standards for core children's programming or judging program content, due to free speech concerns, relying instead on a broad definition and oversight by the public. A lack of widely accepted standards to assess such programming makes it difficult for parents and broadcasters to evaluate the educational content of core children's programming, potentially leading to wide variation in its quality. In the past, FCC and the media industry have collaborated to resolve concerns about program content in other areas. Parent focus groups were largely unaware of CTA's requirements despite FCC's public education efforts. Once informed about the act and core children's programming, focus group parents believed requirements governing such programming should be more stringent than current rules. Core children's programming is designated as such by broadcast stations, but focus group parents believed independent standards or assessments of programming should be required, and parents in all focus groups perceived broadcast station involvement in the process to be a potential conflict of interest. Parents in our focus groups stated that important aspects of children's programming were that it be educational, age appropriate, and entertaining. Focus group parents had differing views on the importance and definition of educational television, but generally agreed that child-dedicated cable networks are more trustworthy for children's programming than broadcast stations and that a gap exists in appropriate programming for school-age children.
section_title: What GAO Recommends
paragraphs: GAO recommends that FCC (1) implement a strategy to oversee cable operators' and satellite providers' compliance, (2) work with industry to develop voluntary guidelines for assessing core children's programming, and (3) implement and assess the effectiveness of additional mechanisms to inform parents about core children's programming. FCC generally concurred with GAO's recommendations and discussed planned and ongoing actions to address them.

section_title: Letter
paragraphs: The television industry has continued to evolve since the advent of  broadcast television in the 1940s and 1950s. In recent years, the number of  stations has grown and the transition to digital television has further  increased the number of channels available to viewers. Studies show that  people’s viewing of television has also grown, including children’s viewing.  Congress enacted title I of the Children’s Television Act of 1990 (CTA) to  shield children from excessive advertising by commercial broadcast  stations and to help ensure that broadcast television met its public service  obligations to children by ensuring that some television was educational  and informational.  CTA required the Federal Communications  Commission (FCC) to (1) initiate and complete a rulemaking proceeding to  prescribe standards regulating commercial advertising transmitted during  children’s television programs, (2) limit the duration of advertising that may  be shown during children’s television programs, and (3) consider the extent  to which a broadcast station has served the educational and informational  needs of children through its overall programming when reviewing a  station’s application to continue broadcasting.  The advertising provisions  apply to cable operators as well as commercial over-the-air broadcasters.   By rule, FCC extended the advertising restrictions to direct broadcast  satellite providers (satellite providers).
In light of the significant role that television programming plays in the lives  of young viewers, you asked us to examine the status of the act, including  FCC’s efforts to enforce it as well as how FCC provides information on  children’s programming to parents who may wish to use it to help plan  their family television viewing. This report discusses (1) the trends in  children’s programming since CTA was implemented, (2) FCC’s efforts to  enforce the act, and (3) the extent to which parents value and use core  children’s programming.
To obtain information about the trends in children’s programming since  the act was implemented, we conducted a trend analysis of children’s  programming in eight designated market areas (DMA) of different sizes to  determine changes in the availability of core children’s programming  between 1998 and 2010. To ensure variation in size and geographic  dispersion, we selected the following DMAs: New York, New York; Dallas- Fort Worth, Texas; Denver, Colorado; San Diego, California; Grand  Rapids-Kalamazoo-Battle Creek, Michigan; Spokane, Washington;  Charleston, South Carolina; and Butte-Bozeman, Montana. In each DMA,  we identified commercial stations that reported airing core children’s  programming and obtained reports submitted by each station from FCC’s  public database for a randomly selected quarter in each year from 1998  through 2010. For each station, we collected data on the reported  average weekly hours of core children’s programming as well as  information on the program title, scheduled air day and time, and target  age group for each program. We did not include programming aired by  non-commercial broadcast stations, such as Public Broadcasting Service  (PBS) member stations, in our analysis of core children’s programming  because non-commercial broadcast stations are not required to report the  same data and thus comparable data were not available. We also  interviewed personnel from commercial and non-commercial broadcast  stations in five of these eight DMAs: Dallas-Fort Worth, Texas; San  Diego, California; Grand Rapids-Kalamazoo-Battle Creek, Michigan;  Spokane, Washington; and Charleston, South Carolina as well as  personnel from various industry stakeholders, including representatives of  industry associations, television networks specializing in children’s  programming, and providers of syndicated children’s programming.
To obtain information about FCC’s efforts to implement and enforce CTA,  we reviewed relevant statutes and FCC rules related to commercial  broadcast stations, cable operators, and satellite providers, as well as  available FCC data on violations and civil penalties it issued. We also  interviewed staff from several offices of FCC—including the Enforcement  Bureau and the Media Bureau—as well as personnel from commercial and  non-commercial broadcast stations in the five DMAs we visited.
To obtain information on the extent to which parents value and use core  children’s programming, we conducted 10 focus groups of parents in 5 of  the 8 DMAs noted above: Dallas-Fort Worth, Texas; Grand Rapids- Kalamazoo-Battle Creek, Michigan; Spokane, Washington; San Diego,  California; and Charleston, South Carolina. We recorded the focus groups  and analyzed written summaries of each, then multiple GAO analysts  coded the responses to identify trends across the focus groups and  worked to ensure agreement about the coding. In addition, we  interviewed personnel from FCC, commercial and non-commercial  broadcast stations, a child advocacy group, providers of syndicated  children’s programming, industry associations, and officials at various  networks that specialize in children’s programming. To obtain information  on the availability of FCC information on core children’s programming and  CTA to parents through internet search engines, we conducted an  analysis of search results using the three most popular internet search  engines in the U.S. using various search terms. To assess the reliability  of the data FCC provided, we interviewed FCC officials and determined  that the data were sufficiently reliable for the purposes of describing  trends in children’s programming and in FCC enforcement activities.
We conducted this performance audit from April 2010 to June 2011 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. Appendix I contains a more  detailed discussion of our objectives, scope, and methodology.
subsections: section_title: Background
paragraphs: In the United States, households with televisions are able to receive free,  over-the-air broadcast television programming or pay for a subscription  cable or satellite television service. Over-the-air broadcast television is  comprised of commercial broadcast television stations—such as affiliates  of networks like ABC or NBC—and non-commercial educational  broadcast television stations—such as PBS member stations. For a  subscription fee, cable operators and satellite providers generally offer a  greater number of channels than free, over-the-air broadcast—including  channels devoted to children’s programming—as well as other services,  such as on-screen program guides.
Following a decrease in the amount of children’s educational  programming in the 1980s and an increase in advertising during such  programming, Congress sought to limit children’s exposure to commercial  advertisements by requiring that FCC initiate a rulemaking proceeding to  prescribe standards regulating commercial advertising transmitted during  children’s television programs. Congress also sought to enhance  children’s educational programming by establishing that each  broadcaster’s obligation to serve the public interest includes an obligation  to serve the educational needs of children. It also required that FCC  consider before renewing any station license the extent to which the  station has served the educational and informational needs of children  during its license period.
As framed by CTA, the educational programming provision of the act only  applies to broadcast stations and not to cable operators or satellite  providers. Cable operators and satellite providers are, however, subject to  FCC’s restrictions on children’s television advertising—cable operators  because they were included by the statutory language and satellite  providers by FCC rule. Also by rule, non-commercial television stations,  such as PBS member stations, are required to comply with some, but not  all, of the same requirements as commercial television stations.
subsections: section_title: Programming Rules for Broadcasters
paragraphs: To help broadcasters select and air programming that serves children’s  educational and informational needs, FCC established a definition and  other criteria for such programming, known as “core programming” or  “core children’s programming.” Core children’s programming is defined by  FCC rules and is a subset of children’s programming, which is all  programming directed at children, including programming that is or is not  educational and informational. FCC rules broadly define core children’s  programming as any programming that is specifically designed to further  the educational and informational needs of children 16 years of age and  under in any respect, including the child’s intellectual/cognitive or  social/emotional needs. In addition, to be considered core children’s  programming the program must satisfy the following criteria:  It has serving the educational and informational needs of children  ages 16 and under as a significant purpose.
It is aired between 7:00 a.m. and 10:00 p.m.
It is a regularly scheduled weekly program.
It is at least 30 minutes in length.
It is identified on-screen throughout the program using the symbol ‘E/I’  so that viewers may identify the program as educational and  informational.    The educational and informational objective of the program and the  age range of the target audience are specified by the broadcaster in a  Children’s Television Programming Report that is filed quarterly with  FCC and included in the broadcaster’s public inspection file. Among  other things, this report identifies efforts made by the broadcaster  during the preceding quarter to serve the educational and  informational needs of children.    The program’s identification as educational and informational and an  indication of its intended age group are provided to publishers of  program guides. Such program guides could include newspapers,  magazines, or cable operators and satellite providers for their on- screen program guides.
Broadcast stations use the above FCC definition and criteria as a guide to  determine if a program can be classified as core children’s programming.
It is up to a broadcast station’s management or other personnel to  determine which programming will be designated by the station as its  core children’s programming.
To increase children’s access to educational and informational  programming, FCC’s rules state that broadcast stations that air a  minimum of 3 hours of core children’s programming per week are eligible  to have the children’s programming portion of their license renewal  application approved by FCC staff rather than by the full Commission.  This rule, while not requiring core children’s programming, represents an  incentive to broadcasters because approval by the full Commission could  delay the renewal. Thus, to avoid Commission-level review, most  stations choose to air at least 3 hours of core children’s programming per  week. In anticipation of the digital television transition, FCC expanded this  incentive to include multicast channels—that is multiple channels aired by  a single broadcast station. Digital stations providing more than one  stream of free programming are eligible for staff-level review of their  license renewal application if they air at least 3 hours of core children’s  programming per week on their main channel and additional hours on  their multicast channels.
section_title: Advertising Rules for Broadcasters, Cable Operators, and Satellite Providers
paragraphs: To shield children aged 12 and under from excess advertising, CTA limits  advertising shown during children’s programming by broadcasters and  cable operators to a maximum of 10.5 minutes per hour on weekends and  12 minutes per hour on weekdays. FCC has also developed rules to  create a clear distinction between program content and advertising in  children’s programs. For example, characters from a program are  prohibited from appearing in or delivering advertisements during that  program, an action known as “host-selling.” These rules apply to  commercials during any programming developed and intended for children  12 and under, including most, but not all, core children’s programming  because core children’s programming can be intended for children up to  age 16. FCC strengthened and expanded its rules in 2004 and 2006 to  include additional aspects of advertising, such as prohibiting the display of  some Internet web addresses during children’s programs. These rules do  not apply to commercials during programming intended for a general  audience, such as a game show, even though children 12 and under may  be watching. Table 1 summarizes key FCC rules and to whom they apply.
Submit quarterly reports to FCC on core  children’s programming aired (Children’s  Television Programming Reports).
Advertisements aired during any program  for children 12 and under cannot include  characters from that program (known as  ‘host-selling’).
Inform publishers of program guides of the  station’s core children’s programming.
section_title: Children’s Programming Has Increased with Varying Requirements for Complying with the Act
subsections: section_title: Core Children’s Programming on Commercial Broadcast Television Has Increased as a Result of More Channels and Stations
paragraphs: The amount of core children’s programming aired by commercial  broadcast stations in the television markets we reviewed increased  significantly from 1998 to 2010, with the increases ranging from 73  percent in the smallest market (Butte-Bozeman, Montana), to 477 percent  in the largest market (New York, New York). As shown in table 2, the  average weekly hours aired more than doubled for six markets. As a  result, viewers of broadcast television in these markets have more  educational and informational core children’s programming available to  them.
Based on our analysis, these changes are likely due to two trends: (1)  increases in the number of channels and broadcast stations and (2) the  emergence of some broadcast stations that air large amounts of  children’s programming. The digital television transition prompted many  broadcast stations to increase the number of channels that they  broadcast, a concept known as “multicasting.”  At the end of 2010, half  of all full-power commercial broadcast stations nationwide were  multicasting a total of more than 1,000 additional channels. Table 3  shows the changes in the number of television stations and channels in  the markets we analyzed. New broadcast stations also help account for  the increase in core children’s programming. Nationwide, there was an  increase of 754 licensed commercial broadcast stations, from 3,349 in  1998 to 4,103 in 2010—a 23 percent increase. Six of the eight markets  we studied added at least two television stations that are required to air  core children’s programming. For example, the Grand Rapids market  added two stations while the New York market added four. New  broadcast channels and stations tend to increase the total amount of core  children’s programming because each additional station and full-time  channel must air additional core children’s programming per week to  receive FCC staff-level approval at license renewal.
Increases in core children’s programming have also resulted from the  small number of commercial broadcast stations that have emerged in  some markets that air significantly more than 3 hours of core children’s  programming weekly. Prior studies of core children’s programming have  shown that most commercial broadcast stations aired an average of 3 to  4 hours of core children’s programming per week and none of the stations  we analyzed aired more than 10 hours per week in 1998. In 2010,  however, several stations aired much larger amounts. For example, one  commercial broadcast station in Charleston reported airing an average of  more than 82 hours per week, representing more than 75 percent of the  total weekly core children’s programming aired on the 11 channels in the  market. In some cases, these stations air more than all the other stations  in a given market combined. For example, one commercial broadcast  station in Grand Rapids reported airing an average of 66 hours a week of  core children’s programming, compared to a combined total of 63 hours  reported by the other stations in the same market. None of the stations  airing significantly more than 3 hours of core children’s programming are  affiliated with one of the major television networks.
Core children’s programming was more available in 2010 than 1998 in  that it airs across a wider range of days and times, for children of different  ages. Availability of such programming is an important factor since the  developmental needs of children vary by age. FCC regulations define  core children’s programming to meet the educational and informational  needs of children aged 16 and under and require that stations identify the  intended age range for each program. FCC does not require broadcasters  to target programming for specific age groups but FCC noted that  research has demonstrated that the ability of young children to  comprehend television content varies by age, and that educational  programming should be targeted to an age range spanning no more than  3 to 4 years to ensure that its content is appropriate to the developmental  level of the intended audience. Even though broadcasters are airing more  programming than previously, if programming for specific age groups  within a market is aired at the same time, overall availability may be  limited.
In the markets we studied, core children’s programming is generally less  concentrated on the weekends and more programs are aired throughout  the week than in 1998. In 2010, the percentage of all programming aired  on the weekend declined while the percentage during the week increased  in five of the eight markets we reviewed. We also found that core  children’s programming in the markets we reviewed is more available at  different times and for children of different ages than in 1998. To  demonstrate the broader availability of this programming in 2010, GAO  calculated the portion of each day—that is, between the hours of 7:00  a.m. and 10:00 p.m. when core children’s programming can be aired per  the FCC regulation—when at least one program aired for children of three  different ages. For this analysis, we chose the ages of 4, 8, and 13. For  each of these ages, the analysis shows the percentage of the day in each  of the markets when any programming is aired. For six of the eight  markets we looked at, the availability of core programming for all three  age groups increased significantly, as shown in table 4. In the remaining  markets, availability increased for 4-year olds and 13-year olds.
Children’s programming on cable and satellite services has also  increased, expanding the impact of the act’s advertising limits, which  restricts the duration of commercials and requires their separation from  children’s programming. The number of channels on cable and satellite  that focus either mostly or exclusively on children’s programming has  expanded from two channels in 1990 to at least eight in 2010. Some of  these channels show children’s programming 24 hours per day and 6 of  the 8 channels air commercials. Since FCC rules allow up to 12 minutes  of commercials per hour during children’s programming on weekdays and  10.5 minutes per hour on weekends, the potential amount of advertising  on these channels increases in direct proportion to the increase in  programming and is thus much higher than it was in 1990.
In addition, more households have access to this increased programming  and advertising. According to FCC, fewer households rely on broadcast  only for television; most instead get programming from a cable operator  or satellite provider. FCC reported in 2007 that 87 percent of television  households subscribe to a service provided by a cable operator or  satellite provider, up from 56 percent in 1990. Children’s programming  channels are carried by the largest cable operators and satellite  providers, making some of them available to nearly 100 million  households. Although not generalizable, most of the parents in our focus  groups also subscribed to a cable or satellite service at home—83 of 90  participants, or 92 percent—and many perceived that this service is better  for children than broadcast. For example, parents in most of the focus  groups we conducted said that their children did not watch commercial  broadcast television. With expanded core children’s programming on  broadcast television and increased programming and viewers of cable  and satellite services, the impact of the act’s advertising limits also  increases due to the larger amount of advertising subjected to the act.
section_title: Emerging Platforms for Children’s Video Programming Are Outside the Scope of the Act
paragraphs: Children are also using other media platforms—computers, wireless  devices such as cell phones, video game consoles, and MP3-type  players—to access television programming that does not have to meet  any of the requirements of CTA. A 2010 report from the Kaiser Family  Foundation found that the amount of time children spent watching  regularly scheduled programming on television declined by nearly half an  hour per day, but time spent watching television programming on other  platforms increased by nearly an hour. The act does not extend to  content viewed from these other sources; therefore, this content is not  required to comply with the core children’s programming or advertising  limits established in the act. For example, commercials presented as part  of a program viewed on another platform are not required to conform to  time or content restrictions. As other media sources account for a larger  percentage of children’s program viewing, parents may become less able  to rely on the E/I symbol to identify educational and informational  television for their children and the advertising limits placed on television  become less effective. : Media in the Lives of 8- to 18-Year Olds, A Kaiser Family Foundation  Study (January 2010).
section_title: FCC Relies on Broadcasters to Self- Report Violations but Lacks a Corresponding Oversight Approach for Cable Operators and Satellite Providers
subsections: section_title: FCC’s Oversight of Broadcasters Generally Relies on Stations to Self- Report Violations
paragraphs: CTA tasks FCC with overseeing broadcast stations’ efforts to provide  educational and informational television programming for children. With  respect to enforcing the act’s and FCC’s rules on advertising limits,  however, FCC relies on stations to self-report violations during the license  renewal process. The FCC must consider the extent to which broadcast  stations have complied with their legal requirements, including CTA, when  reviewing their license renewal applications. The application asks  stations to certify that they have complied with their legal obligations;  stations that are unable to certify that they met their obligations must  attach an explanation to the application. For example, if stations exceed  the advertising limitations, they are expected to include an explanation as  to how and why they exceeded the limits. According to FCC staff and  officials from commercial broadcast stations, broadcasters are motivated  to provide truthful information on their license renewal application, even if  it results in a civil penalty. Any unreported violations or other  misrepresentations could result in increased civil penalties or the eventual  loss of a station’s license.
According to FCC officials, almost all FCC enforcement actions related to  children’s television have stemmed from stations self-reporting violations  during the license renewal process. The most common violation  concerned running advertising exceeding allowed limits. Most of the  enforcement actions that FCC has taken against commercial broadcast  stations for violating rules regarding children’s television have been  written admonishments or civil penalties. According to FCC, the  Commission will generally issue civil penalties for more serious violations,  such as violations that occur over long periods of time; otherwise, FCC  will generally issue a written admonishment. For the last two license  renewal cycles in 1996 and 2004, FCC issued about 7,000 violations to  over 600 stations, and assessed civil penalties totaling almost $3 million.  Most of these violations were advertising length violations— advertisements aired during children’s programming that exceeded 10.5  minutes per hour on weekends or 12 minutes per hour on weekdays (see  fig. 1). The remaining violations concerned other advertising problems— such as host-selling or failure to create a clear distinction between  program content and advertising—or problems with a broadcast station’s  public inspection file—such as the station not including all the required  children’s programming documents in the file.
During the licensed period, FCC also oversees compliance with the act.  For example, it investigates complaints received from consumers  regarding core children’s programming. Furthermore, FCC reviews some  quarterly filings made by broadcasters that describe the core children’s  programming aired by the station during the previous calendar quarter  and scheduled to be aired the following calendar quarter. Through these  reviews, FCC staff is able to identify stations that are not airing 3 hours  per week of core children’s programming. According to FCC officials, the  Commission may informally ask the station for information as to why the  station did not meet the 3-hour minimum.
In addition to enforcement efforts during the license renewal cycle, FCC  also monitored the advertisements during a random selection of children’s  programs on selected commercial broadcast stations from 2000 to 2004  but stopped doing so after finding few violations. These monitoring  efforts—which each year looked at about 25 stations and 2 to 4 hours of  programming on each station—focused on verifying that the stations  complied with the rules regarding advertising shown during children’s  programming. FCC officials found one violation by a commercial  broadcast station during the 5 years it monitored advertisements.  According to FCC officials, the Commission stopped monitoring the  advertisements after 2004 because of these limited results, determining  that resources and staff should be used for other tasks.
Although CTA and FCC’s enforcement focuses on stations’ license  renewal, enforcement actions are sometimes implemented mid-license  term in response to an FCC random inspection of a station or a consumer  complaint, thus necessitating that stations monitor the length and content  of advertising aired during children’s television programming. Staff from  some commercial broadcast stations we spoke with stated that they have  processes in place to actively monitor their children’s programming in  order to minimize and prevent violations, but staff from an independent  commercial broadcast station said that they did not monitor the  programming and would not know if the programming streams they aired  violated the act.
Furthermore, FCC does not track potentially widespread advertising  violations that occur at the network level and are aired by affiliated  commercial broadcast stations. While commercial broadcast stations may  self-report a violation during license renewal, FCC does not have a  tracking mechanism in place to ensure the violation is actually reported by  each licensee. For example, in December 2006 a nationwide network that  provided children’s programming and advertising to its affiliated  commercial broadcast stations included an advertisement that violated  FCC rules. In January 2007, the network issued a memorandum to its  affiliated commercial broadcast stations explaining the incident and the  steps that would be implemented to prevent such a violation from  occurring again. The violation occurred toward the end of the previous  license renewal period, which ran from 2004 to 2007. As such, most of  the broadcast stations affiliated with this network have not yet filed their  renewal application, which would cover this event; most will do so when  the next license renewal period begins in 2012. Without a mechanism for  tracking these types of widespread violations, FCC cannot verify that all  affected stations are actually reporting the violation. FCC officials we  spoke with recognized this issue and stated that the Commission could  consider developing and implementing methods to ensure that similar  violations are tracked by FCC and reported by broadcasters. According to  FCC, the Commission has not established a tracking mechanism, in part,  because such violations are generally reported by each licensee in its  license renewal application.
section_title: FCC Does Not Currently Oversee Cable and Satellite Providers’ Compliance with Advertising Requirements, Resulting in Unbalanced Enforcement
paragraphs: CTA’s advertising requirements apply to cable operators as well as  commercial broadcasters and, as stated, FCC has extended similar  requirements to satellite providers by regulation. Unlike broadcast  stations, however, cable operators and satellite providers do not go  through the kind of license renewal process required to maintain an over- the-air broadcast license. As such, FCC does not have the same  opportunities to review compliance with the act and FCC rules as it does  with broadcast stations. According to FCC officials, no cable operator or  satellite provider has ever voluntarily self-reported any violations of the  act to FCC. Additionally, unlike the license renewal application process  for broadcasters, FCC lacks a mechanism for cable operators or satellite  providers to certify compliance with the act and identify advertising  violations, even though cable operators and satellite providers are  required to maintain records in their public inspection file that are  sufficient to verify compliance with FCC rules, and are subject to  investigations of consumer complaints by FCC.
FCC investigators have conducted reviews of cable operators’ and  satellite providers’ public inspection files to ensure that these entities are  maintaining records sufficient to verify compliance with FCC rules  regarding advertising during children’s programming. FCC investigators  found five instances between 2005 and 2010 in which cable operators did  not maintain sufficient records. All of the violations were for cable  operators, not satellite providers, and none resulted in civil penalties.
As noted above, FCC monitored commercial broadcast stations’  compliance with advertising rules from 2000 to 2004; the 2003 and 2004  investigations also observed cable operators’ compliance. FCC found  two cable operator violations in 2003 and none in 2004. These violations  occurred on separate networks that were carried by cable operators  across the country, reaching over 85 million households. One of the  violations involved advertising that conflicted with FCC’s advertising  content rules that was later determined to have been repeated 31 times  over the course of about 1 year. The other violation involved advertising  that exceeded FCC’s advertising time limits 591 times, representing over  1,000 30-second commercials. The act and FCC rules make cable  operators, not the networks that provide them the programming,  responsible for complying with the advertising limit rules. However, in  these two cases, the networks made voluntary contributions to the U.S.  Treasury, since they provided cable operators with the programming in  question.
FCC discontinued its investigations after 2004 and since then other  advertising violations may have occurred. Over the same period of time  that broadcasters reported over 6,000 advertising violations, cable  operators and satellite providers have not reported any, and FCC only  identified two advertising violations despite the large amount of children’s  television programming aired by cable operators and satellite providers as  compared to that aired by commercial broadcast stations. A senior FCC  official stated that FCC cannot be certain that there are no advertising  violations occurring on programming offered by cable operators or  satellite providers. We found an advertising industry self-regulatory  organization that identified advertising that potentially violated FCC’s  advertising rules in 2006. The advertising included pictures of a DVD  featuring characters from the program during which the commercial aired.  The responsible network acknowledged the violation and attributed it to  human error. However, when asked, a senior FCC official told us that he  was unaware of this potential violation and that FCC did not issue a civil  penalty.
As previously noted, FCC officials told us that they discontinued oversight  monitoring because most entities were found to be in compliance with the  rules and because enforcement staff and resources were dedicated to  higher-priority needs. In response to our findings, FCC told us that the  Commission currently has plans to conduct oversight of cable operators’  and satellite providers’ compliance with advertising rules on a consistent  basis. A senior FCC official also said that the Commission has methods  to oversee cable operators’ and satellite providers’ compliance with  advertising rules. For example, certain FCC offices subscribe to cable or  satellite services which would permit such offices to monitor compliance.  This and similar efforts would permit the Commission to have a better  understanding of advertising shown on stations offered by cable  operators or satellite providers. Without oversight, FCC cannot ensure  that cable operators and satellite providers are complying with the act,  potentially exposing children to excess or inappropriate advertising that  the act and FCC rules seek to minimize and leading to unbalanced  enforcement.
section_title: Concerns Remain about the Quality and Educational Value of Some Core Children’s Programming, but Regulating Program Content Is Challenging
paragraphs: While some definitions and standards for educational children’s  programming do exist—for example, PBS developed and implemented a  set of guidelines for use in producing its children’s programming—there  are no broadly accepted industry standards for educational programming  that broadcasters can use. FCC officials told us that the definition of core  children’s programming as currently established in FCC rules is  intentionally broadly written so as not to dictate specific programming  content. They said that a prescriptive definition of what constitutes  educational and informational programming could be seen, in their view,  as an attempt by the government to regulate program content, which  could potentially violate the free speech provision of the First Amendment  to the U.S. Constitution. Broadcasters are responsible for selecting core  children’s programming and certifying that it adheres to the definition  established by FCC rules. However, without standards, broadcasters can  not be sure that their programming is educational and informational under  the act.
FCC relies on the public, including parents and child advocacy groups, to  monitor and react to core children’s programming content. FCC officials  stated that by doing so, the Commission intends for the public’s  complaints to prompt broadcasters to self-regulate. While the public has  rarely filed complaints regarding the content of children’s programming  with FCC, some child advocacy groups have chosen to file petitions to  deny license renewal with FCC regarding the quality of core children’s  programming content aired by some broadcast stations. For example, in  a still pending case from 2004, a group filed a petition to deny the license  renewal of a broadcast station operating in the Washington, D.C., area. In  the petition to deny, the group cited a children’s media expert’s analysis  of a program shown on the broadcast station. The expert noted that the  program, designated as core children’s programming, had “no palpable  message, lessons, or curriculum at even the most modest level of depth  that would contribute to a child’s positive development in any sense.”
A lack of content standards makes it difficult for stakeholders—such as  parents, educational groups, and broadcasters—to evaluate the  educational content of core children’s programming and could lead to  wide variation in that content. Some child advocacy groups have raised  concerns regarding the quality of core children’s programming content,  generally stating that the content of these programs is neither educational  nor informational. For example, one group reviewed 90 episodes of core  children’s programming and used a variety of criteria—including the  clarity of the lesson presented and its applicability to the real world—to  determine the quality of those episodes. According to the study, the  group determined that the vast majority of the episodes it reviewed (86  percent) were either minimally or moderately educational; only 13 percent  were deemed highly educational. The same study noted that the  percentage of core children’s programs that it considers to be highly  educational fell over a 10-year period (from the 1997-1998 season to the  2007-2008 season), from 29 percent of core children’s programs to 13  percent of core children’s programs. Another study examining the quality  of children’s television programs, which used a different set of criteria to  judge program quality, determined about 60 percent of programs were of  moderate or low quality, with the remaining roughly 40 percent being of  high quality.
When commenting on an FCC notice of inquiry regarding the evolving  media landscape, the National Association of Broadcasters urged FCC to  continue its practice of relying on broadcast stations to certify that the  stations’ core children’s programming serves the educational and  informational needs of children. The National Association of Broadcasters  noted that FCC has very limited authority to regulate program content.  However, personnel at some broadcast stations we talked to said  program quality was not a high priority when selecting which core  children’s programs to air, expressing greater concern about meeting the  minimum requirements of the act. As we discuss later in this report,  parents in our focus groups believed that there should be independent  standards or oversight and that station involvement in designating core  children’s programming represented a conflict of interest.
FCC has previously collaborated with the media industry to implement  CTA and address other concerns. For example, FCC and stakeholders  collaborated in the rulemaking process to reach agreements on several  rules implementing the act, including the minimum number of hours of  core children’s programming to be aired per week, as well as the  extension of this minimum to each multicast channel. In the 1990s, FCC  recognized stakeholders’ development of a voluntary television rating  system to address concerns about violent, sexual, or other content in  programs as meeting statutory requirements. This rating system still  exists and several parents in our focus groups noted that they use the  ratings in deciding which programs their children watch.
FCC took steps to renew the dialog about children’s programming in 2007  by seeking public comments on the status of children’s programming. In  2009, FCC issued another notice of inquiry to collect broader information  about a changing media landscape which included some questions about  children’s television programming. Within that notice of inquiry, FCC  asked about the quality of core children’s programming provided by  broadcast stations. Comments submitted in response to the notice  disagreed over the quality of core children’s programming. The notice of  inquiry recently closed and FCC is still considering what further action, if  any, it will take in this proceeding. Without more specific standards of  what constitutes educational and informational programming, the extent  to which core children’s programming aired today is actually educational  and informational remains unclear and, thus, whether a broadcaster’s  compliance is in fact meaningful.
section_title: Parents in Focus Groups Were Generally Unaware of the Act and May Draw Incorrect Conclusions about Core Children’s Programming, but Valued Educational Children’s Programming
subsections: section_title: Despite FCC Efforts, Parents Are Uninformed about the Act and Its Requirements, Potentially Leading to Incorrect Conclusions about Core Children’s Programming
paragraphs: FCC has emphasized the importance of parents’ knowledge of CTA and  taken steps to educate parents about the act’s provisions. FCC has  stated that the act’s effectiveness and, thus, the effectiveness of the core  children’s programming aired as a result of the act, is, in part, dependent  on parents’ knowledge of children’s educational programming. The FCC’s  1996 Order on Children’s Television states several benefits of educating  parents on the act including that (1) public access to information would  permit the FCC to rely on marketplace forces to achieve the goals of the  act and facilitate enforcement through public monitoring and (2)  information on core children’s programming would assist parents in  planning their children’s viewing. To that end, FCC efforts to educate the  public include requirements that stations (1) display an E/I symbol on- screen during core children’s programming, (2) maintain a public  inspection file detailing the station’s core children’s programming  available to the public, and (3) supply publishers of programming guides  with information on core children’s programming.
We found, however, that parents are largely unaware of CTA’s contents  despite FCC efforts. For example, although not generalizeable, we found  that some parents in focus groups we conducted were unaware that any  children’s programming was aired on commercial broadcast stations at  all. Most parents in our focus groups also did not recognize the E/I  symbol or know its meaning. Specifically, of 90 focus group parents, 44  recognized the E/I symbol, but only 2 parents across all focus groups  knew what the symbol meant. Of the parents who thought they may have  seen the symbol before, many stated they may have seen it on PBS  member stations, which air a large amount of core children’s  programming.
In addition to this on-screen requirement, FCC requires broadcast  stations to maintain a public inspection file at the station location that is  available to the public and details the station’s core children’s  programming and air times in addition to program descriptions. Broadcast  station staff that we spoke to stated that members of the public rarely  seek access to this information. FCC has adopted a rule that would  require public inspection files to be made accessible via the station’s Web  site, but this rule is not yet in effect.
The most frequently cited tools for finding information on children’s  television in our focus groups were programming guides, internet  searches, and other parents, but FCC’s efforts and rules involving these  outlets may not be effective. While parents in our focus groups stated that  they look for information on children’s programming in their programming  guide, cable operators and satellite providers are not required to, and  generally do not, publish this information. Parents in our focus groups  also stated that Internet searches are an important tool for them to find  children’s programming. FCC’s ‘Parents’ Place’ Web site provides  parents and other members of the public with information on stations that  air core children’s programming, broadcast times, and general  background information on the programs. However, we found that this  site was difficult to find using popular internet search engines and a  variety of search terms.
Past studies, as well as statements from parents in our focus groups,  indicate that parents remain generally unaware of CTA or that core  children’s programming is even available. Without knowledge of the act’s  existence, parents are unable to seek out information on core children’s  programming through the outlets provided by the FCC, including the public  inspection files, the ‘Parents’ Place’ Web site, and on-screen tools such as  the E/I symbol. As a result of these disconnects between FCC efforts and  parent knowledge, parents are unable to find and take advantage of the  core children’s programming provided as a result of the act.
In addition to a lack of knowledge about the act, when parents in our  focus groups were informed about its existence and core children’s  programming we asked what their expectations would be for television  programs that have the E/I label, as opposed to programs that do not  have the label. Their beliefs about the requirements that should apply to  such programming were more stringent than current rules. For example,  parents in most of our focus groups stated that they believed that a panel  or review board consisting of a variety of experts and stakeholders should  review and approve core children’s programming. Some parents believed  or assumed that core children’s programming was designated in the  same way that television programs and movies are rated, that is, using  rating systems implemented by the National Association of Broadcasters,  National Cable & Telecommunications Association, and Motion Picture  Association of America. Parents in five of the focus groups stated that  they believed set criteria should exist for how programs are designated as  core children’s programming.
In addition to these beliefs about the process of core children’s  programming designation, parents within and across the focus groups we  conducted had varying beliefs about the types of groups that should be  involved in the process. Parents disagreed about the extent to which  local, state, and federal governments should be involved; however,  parents in all 10 focus groups stated that the television industry (including  producers, stations, and networks) should have either limited involvement  or no involvement, citing a conflict of interest. A small number of parents  approved of industry involvement. However, the core children’s  programming provided under the act is designated as such by each  broadcast station that airs the programming and neither the FCC nor any  independent group is responsible for reviewing or approving the  designation. Regarding criteria, while FCC rules do require that core  children’s programming have as its significant purpose the educational  and informational needs of children, this limited criteria for core children’s  programming content does not align with parents’ beliefs about what  should be required under the act. Further, resources provided by FCC to  inform parents about the act, such as the ‘Parents’ Place’ Web site and  the E/I on-screen symbol, do not provide parents with detailed information  on the process of designating core children’s programming as such.
Without a clear understanding of the limitations of the designation and  content requirements for core children’s programming, parents run the  risk of allowing their children to watch programming they would not  otherwise allow. For instance, after learning about the act’s existence and  stating their beliefs about the designation process for core children’s  programming, some parents in our focus groups stated that they would  use the E/I symbol as a determining factor when choosing programming  for their children, but others stated they would not rely on the symbol at all  or would use it as a guide to choosing programming in addition to other  information sources.
section_title: Focus Group Parents Valued Appropriate and Educational Content in Children’s Programming, but Found Cable and Satellite Programming to Be More Trustworthy Than Broadcast
paragraphs: When discussing children’s programming in general, parents in our focus  groups stated that important aspects of such programming include that it  be educational, generally appropriate for children, and entertaining.  Although not generalizeable, parents who participated in our focus groups  stated the following characteristics as desirable features for children’s  television:    Appropriate: Parents valued non-violent programs that display morals  and positive examples for children.    Academics: Parents valued programs that taught subjects such as  reading, foreign languages, and counting, as well as programs that  challenge children to think and ask questions.    Life lessons: Parents valued programs that presented age-appropriate  life lessons for children, such as the importance of brushing teeth for  young children.    Entertainment value: Parents valued programs that were entertaining  to their children.    Family entertainment: Parents valued programs that they would watch  with their children and provided entertainment for a wide age range.
Conversely, parents stated the following characteristics as negative  features of children’s television:    Advertising: Parents in several focus groups stated that children are  too affected by the amount and content of commercials they see.    Bad examples: Parents noted several negative examples, such as  children’s programs with characters that (1) engage in adult activities,  (2) bully others, or (3) encourage materialistic behaviors.
Inappropriate content: Parents noted dissatisfaction with programs  that are violent, encourage use of foul language, or portray sexual  situations or nudity.
While some parents in 6 of the 10 focus groups we conducted stated that  they see children’s television primarily as a means of entertainment, with  a parent in one group stating that educational content is not necessary,  other parents in five focus groups saw educational content as one of the  most important features of children’s television. Parents also had differing  opinions on what constitutes educational television programming, with  some stating that they were personally unclear of how to define such  programming. Some parents in our focus groups said that the definition of  educational can depend on the age and the preferences of the child. For  instance, parents in one focus group stated that they preferred programs  that did not teach life lessons because they prefer to teach those lessons  themselves according to their own values. Additionally, parents  expressed wide variation in programs that they consider to be  educational. Programs they mentioned included themes such as spelling,  counting, science, and reality programs focused on law enforcement and  teen pregnancy.
Some focus group parents generally viewed cable and satellite television,  along with a small number of broadcast stations like PBS member stations  and Qubo, as more trustworthy sources for children’s programming than  most broadcast stations. Furthermore, some parents stated that their  children do not watch programs on commercial broadcast stations at all.  Parents cited several reasons for this. First, parents like that there is less  risk of children being exposed to inappropriate content, such as  commercials or programs not meant for children, on cable and satellite  networks or stations geared toward children’s programming than on most  broadcast stations. Second, parents stated that it is easier for children and  parents to rely on channels that focus primarily (or exclusively) on  children’s programming instead of broadcast channels that only air a few  hours per week. For example, one parent stated that, on cable channels,  no matter what children want to watch, the programs are always available.  Third, some parents stated that there is not enough children’s programming  on broadcast stations or the programming is repeated too often.
We also found that parents in many of our focus groups perceived a gap  in the programming available for children of certain ages. Our trend  analysis showed that children’s programming is available for a wide range  of age groups, but parents in 8 of the 10 focus groups we conducted  raised the issue of a lack of programming appropriate for school-aged  children; parents in five of those eight focus groups specifically stated that  there was a lack of educational children’s programming for this age  group. The age range of this perceived programming gap as stated by  parents varied and included, in some cases, children as young as 6 and  as old as 15. For instance, one parent of a child between 6 and 9 stated  that high-quality educational programs are generally meant for children  aged 5 and under and that programs on some popular children’s cable  networks are aimed at children older than 9. The parent believed that this  gap leads her child to watch lower-quality programs because they are the  only ones aimed at children between 6 and 9 years old. Lending credence  to this perceived gap in programming, we found during our trend analysis  that the age range provided for some programs varied widely among  commercial broadcast stations and television markets. For instance, one  program is listed in various markets as being appropriate for three  separate age groups: ages 2 through 5, ages 6 through 10, and ages 10  through 14. Parents’ perception of this gap may be heightened by PBS,  which has chosen to focus its programming on children younger than 8  years of age. PBS officials said that children ages 2 to 8 are the age  group most in need of high-quality television.
section_title: Conclusions
paragraphs: FCC’s reliance on broadcasters to self-report violations to the Children’s  Television Act and related FCC advertising rules has limits—it depends  upon commercial broadcast stations closely monitoring their own  compliance and being sufficiently motivated to report their violations.  Nonetheless, it has been much more effective than FCC’s oversight of  cable and satellite advertising restrictions. Since the act went into effect,  broadcasters have self-reported about 7,000 advertisement and public file  violations. During the same period, FCC has only identified seven  violations by cable operators and satellite providers even though they  face these same requirements and generally televise much more  children’s programming than any individual broadcaster. The imbalance in  enforcement has resulted from a lack of oversight by FCC. FCC officials  told us that the Commission has not consistently enforced cable and  satellite compliance with CTA and FCC’s rules since 2004 and has no  way of knowing if violations have occurred. Any possible violations would  have exposed children to excessive advertisements. In addition, parents  in several of our focus groups cited advertisements as one of the things  they disliked the most related to children’s television.
The range of stakeholders on this issue disagree about the quality of the  educational content of core children’s programming and there are no  generally accepted standards by which to measure that quality. Some  child advocacy groups have charged that much of broadcasters’ core  children’s programming lacks educational value, and some broadcasters  said that educational content was not a top priority in selecting the  programming. Furthermore, most parents in our focus groups already  believed that core children’s programming should meet set standards or  receive independent approval before being certified educational and  informational by broadcasters. FCC officials agree that there are no  standards but said that the government is limited in what it can require  without impinging on broadcasters’ free speech rights afforded under the  First Amendment to the U.S. Constitution. However, FCC has effectively  worked with industry stakeholders in the past to develop voluntary  guidelines in other contentious areas, such as the voluntary television  rating system. Without such standards, moreover, broadcasters will  remain vulnerable to questions of the extent to which core children’s  programming is, indeed, educational and informational.
Educational standards, however, do not matter unless children benefit  from core children’s programming. Despite efforts by FCC and broadcast  stations to inform the public about core children’s programming provided  under the act, many parents are not aware of the act or its requirements  for children’s programming. Most parents in our focus groups said that  their children do not watch broadcast television and many did not even  realize that commercial broadcast stations still televise children’s  programs. Only 2 of 90 parents who participated in our focus groups  actually knew what the E/I label meant. Parents said that they look for  information related to children’s programming on the Internet, but detailed  information on the process of designating core programming as such is  not readily available to parents through popular Internet search engines.  Until stakeholders are able to agree upon standards for and increase  public awareness of the core children’s programming provided as a result  of the act, children will not fully benefit from the broadcasters’ efforts to  comply with the act.
section_title: Recommendations for Executive Action
paragraphs: To help ensure that children more fully benefit from the Children’s  Television Act of 1990, we recommend that the Chairman of the Federal  Communications Commission take the following three actions:    To improve enforcement of the act and the related rules, develop  and implement a strategy for overseeing cable operators’ and  satellite providers’ compliance with the required advertising limits.    To better ensure that core children’s programming meets the  educational and informational needs of children, collaborate with  the media industry to explore the potential for voluntary guidelines  or standards to be used in creating and assessing core children’s  programming.    To better inform parents about core children’s programming and  how it is designated as such, coordinate with broadcasters,  associations, parents, and other stakeholders to (1) identify  additional mechanisms—such as the recently launched ‘Parents’  Place’ Web site—for educating the public about core children’s  programming on commercial broadcast television stations and  assisting parents in making well-informed decisions about their  use of core children’s programming; (2) implement these  mechanisms; and (3) measure and assess the effectiveness of  these mechanisms.
section_title: Agency Comments
paragraphs: We provided a draft of this report to FCC for review and comment.  FCC  provided its written comments on the draft by a letter dated July 5, 2011.   These comments are included, in their entirety, as appendix II to this  report.  FCC generally concurred with our recommendations and  discussed planned and ongoing actions to address them.  In separate  correspondence, FCC also provided technical comments, which we  incorporated as appropriate.
We are sending copies of this report to the Federal Communications  Commission and other interested parties.  In addition, the report will be  available at no charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or goldsteinm@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: We were asked to review how the Federal Communications Commission  (FCC) provides information on children’s programming to parents who  may wish to use it to help plan their family television viewing. This report  discusses (1) the trends in children’s programming since the Children’s  Television Act of 1990 (CTA) was enacted, (2) FCC’s efforts to enforce  the act, and (3) the extent to which parents value and use core children’s  programming.
To obtain information about the trends in children’s programming since  CTA was enacted, we conducted a trend analysis of core children’s  programming in eight designated market areas (DMA) of different sizes to  determine changes in the quantity and availability of core children’s  programming between 1998 and 2010. DMAs are ranked annually by the  Nielsen Company according to the number of television households and  are widely used by both FCC and the media industry to report information.  We selected a non-probability sample of eight DMAs for our trend analysis  with regard for variation in both size and geographic dispersion based on  the Nielsen Company’s 2010 size ranking of all 210 DMAs in the United  States. For size, we divided the ranked markets into thirds representing  approximately 33 percent of television households and selected two DMAs  from the group with the largest markets and three DMAs from the  remaining two groups, for a total of eight DMAs. The selected markets,  along with their ranked size, are: New York, New York (1); Dallas-Fort  Worth, Texas (5); Denver, Colorado (16); San Diego, California (28); Grand  Rapids-Kalamazoo-Battle Creek, Michigan (41); Spokane, Washington  (75); Charleston, South Carolina (97); and Butte-Bozeman, Montana (190).
Broadcast stations were not required to report their core children’s  programming consistently until 1997, when FCC established a reporting  requirement and form for that purpose: the Children’s Television  Programming Report. As such, we excluded the first year of available data  (1997) based on concerns that stations may not yet have been reporting  consistently. In each DMA, we developed a list of broadcast stations by  identifying stations that reported airing core children’s programming in the  second quarter of 2010. We then obtained Children’s Television  Programming Reports submitted by each station from FCC’s public  database for a randomly selected quarter in each year from 1998 through  2010. We did not include programming aired by non-commercial broadcast  stations, such as PBS member stations, in our analysis of core children’s  programming because non-commercial broadcast stations are not required  to report the same data and thus comparable data were not available.  From each Children’s Television Programming Report, we collected data  on the reported average weekly hours of core children’s programming as  well as other information such as the program title, scheduled broadcast  day and time, and target age group for each program.
To show availability of programming for children of different ages in each  DMA, we divided the core children’s programming week—that is, between  7:00 a.m. and 10:00 p.m. each day of the week—into 30-minute segments.  We also selected three different ages—4, 8, and 13—to represent the  range of ages under 16. Using the trend analysis data, for each 30-minute  segment, we identified whether at least a single program with a targeted  age range that included one of the three selected ages aired in the DMA.  We calculated the percentage of time that at least one program was  available for each age by dividing the total number of those segments by  the 210 available segments for each week. For example, in Denver in  2010, in 114 segments of the week there was at least one program aired  that was targeted for an 8-year old. By dividing the total number of  segments with available programming (114) by the total number of  segments in the week (210), we found that, during the quarters in 2010 we  randomly selected, programming for an 8-year old was available 54  percent of the time in Denver. We repeated the analysis for each of the  three selected ages, for each of the eight selected DMAs in both 1998 and  2010. While conducting this trend analysis, we found some inconsistencies  in the data reported to FCC in the Children’s Television Programming  Reports, such as stations reporting that their core children’s programming  aired outside of the required time frame (7:00 a.m. to 10:00 p.m.) or  reporting that a program aired more times than possible in a given quarter.  The results of our trend analysis are not generalizable to all commercial  broadcast stations operating in the United States because we reviewed  data from only 8 of 210 DMAs. In addition to conducting a trend analysis,  we interviewed personnel from commercial and non-commercial broadcast  stations in five DMAs: Dallas-Fort Worth, Texas; San Diego, California;  Grand Rapids-Kalamazoo-Battle Creek, Michigan; Spokane, Washington;  and Charleston, South Carolina. We also interviewed various industry  stakeholders, including representatives of industry associations, television  networks specializing in children’s programming, and providers of  syndicated children’s programming.
To obtain information about FCC’s efforts to implement and enforce CTA,  we reviewed relevant statutes and FCC rules related to commercial  broadcast stations, cable operators, and satellite providers, as well as  available FCC data on violations and civil penalties it issued. We also  interviewed staff from several offices of FCC—including the Enforcement  Bureau and the Media Bureau—as well as personnel from commercial and  non-commercial broadcast stations in the five DMAs we visited.
To obtain information on the extent to which parents value and use core  children’s programming, we conducted 10 focus groups of parents in five of  the eight DMAs noted above: Dallas-Fort Worth, Texas; Grand Rapids- Kalamazoo-Battle Creek, Michigan; Spokane, Washington; San Diego,  California; and Charleston, South Carolina. We conducted two focus  groups of parents in each DMA, with parents divided according to the age  of their children. In three DMAs, we conducted focus groups of parents with  children between the ages of either 2 through 9 or 10 through 16. After  these focus groups were completed, we found that parents of children in  the older group (ages 10 through 16) had consistent responses and stated  that their children normally view programs meant for a general audience,  rather than programs aimed specifically at children. To gain more varied  information, the final four focus groups in the remaining two DMAs were  conducted with parents with children aged either 2 through 5 or 6 through  9. We recorded the focus groups and completed written summaries of  each, and then multiple GAO analysts coded the responses to identify  trends across the focus groups and worked to ensure agreement about the  coding. In addition, we obtained information by interviewing personnel from  FCC, broadcast stations, child advocacy groups, providers of syndicated  children’s programming, industry associations, and officials at various  networks that specialize in children’s programming. To obtain information  on the availability of FCC information on core children’s programming and  the act to parents through Internet search engines, we conducted analysis  of search results using the three most popular Internet search engines in  the United States using various search terms. To assess the reliability of  the data FCC provided, we interviewed FCC officials and determined that  the data were sufficiently reliable for the purposes of describing trends in  children’s programming and in FCC enforcement activities.
We conducted this performance audit from April 2010 to June 2011 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.
section_title: Appendix II: Comments from the Federal Communications Commission
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Keith Cunningham, Assistant  Director; Colin Fallon; Katherine Hamer; Bert Japikse; Kirsten Lauber;  Hannah Laufe; Janet Mascia; Faye Morrison; Ramzi Nemo; Daniel  Paepke; Terry Richardson; Jerome Sandau; Travis Thomson; Mindi  Weisenbloom; Jade Winfree; and Elizabeth Wood made key contributions  to this report.