Broadband Affordability After the ACP: What States and Administrators Must Do Now

How state agencies can turn BEAD-funded networks into subscriptions households can afford

By Max SheltonReviewed by PAP Editoral TeamUpdated October 15, 202616 min read

What you’ll learn in this article…

  • The Affordable Connectivity Program ended in 2024, shifting affordability to states.
  • Low-income city households spend 4.5 times more on broadband than wealthier residents.
  • Maryland's Emergency Broadband Benefit served 200,000 households before funding expired.

Publicly funded broadband networks only deliver their full public benefit when households can afford to subscribe. That assumption broke in 2024 when the Affordable Connectivity Program lapsed, leaving states with an unfunded affordability mandate. Pew's Oct. 14, 2026 article "Broadband Policy Cornerstone: Affordability" positions affordability as the cornerstone linking deployment to household use.

The inequity is stark: low- and moderate-income city households spend more than 4.5 times the share of monthly income on broadband as wealthier residents. Administrators must now weigh subsidies, ISP mandates, and public offerings under BEAD low-cost rules, measuring enrollment rather than build-out.

Why Affordability Is the Cornerstone Between Networks and Household Use

Affordability has shifted from an access afterthought to the central test of whether broadband investment produces public value. Pew identifies affordability as one of four cornerstones of a comprehensive broadband policy framework and the link between network deployment and actual household use.1

From Deployment to Subscription

During BEAD planning, every state named affordability as a barrier to broadband adoption. The distributional stakes are sharp: Pew's analysis notes that low- and moderate-income households in cities spend more than 4.5 times the share of their monthly income on broadband as wealthier residents do, according to one study.1 A separate report found low- and moderate-income communities paid 2.43 percent of median income for broadband, versus 0.51 percent in wealthier areas. For public administrators, this burden is not abstract; it shapes whether a household can sustain remote work, telehealth, or online learning.

State Strategies and ISP Incentives

Pew applies a 2 percent of monthly household income benchmark; its middle-class analysis yields a national median affordability standard of $93.21.1 Against that yardstick, Pew groups state approaches to universal access into three broad strategies that reflect federal-state partnership best practices: promoting competition, providing state-funded subsidies, and requiring providers to offer low-cost plans. These instruments also create a stable subscriber base for internet service providers, which supports return on capital investment. Networks built with public dollars that price out low-income households therefore deliver only partial public benefit, so administrators should use data-driven policymaking to measure subscription outcomes, not miles of fiber alone.

What Replaced the Affordable Connectivity Program?

Nothing at a comparable scale replaced the Affordable Connectivity Program. As of October 2026, no federal program has restored a nationwide monthly discount close to the ACP's $30 benefit, and the lapse has shifted affordability work to states.

What ended with the ACP

The ACP connected more than 23 million U.S. households at its peak.1 It offered up to $30 per month for internet service, up to $75 per month on qualifying Tribal lands, and a one-time $100 device discount.2 Eligibility generally reached households at or below 200% of the federal poverty guidelines or those enrolled in certain assistance programs.3 The program stopped new applications on February 7, 2024, and ended June 1, 2024 after Congress did not provide additional funding.2

What remains at the federal level

Lifeline is the main continuing federal broadband affordability program. It offers up to $9.25 per month, or $34.25 on Tribal lands, with a 135% poverty guideline threshold far narrower than the ACP's.3 As of October 2026, no enacted successor that restores ACP-level support appears in the Broadband Affordability Programs review; some households may rely on smaller alternatives such as certain Department of Veterans Affairs programs or provider discounts, but none match the ACP.

What this means for administrators

For state and local public administrators, the ACP sunset created an unfunded mandate with real consequences. States that had already identified affordability as an adoption barrier now must build low-cost service options, BEAD low-cost plan requirements, and other state policy tools into their public policy making and implementation work. That means treating affordability as an outcome to measure, not just a federal program gap: checking whether low-income households actually subscribe, not only whether networks are built.

State Affordability Programs After the ACP: A Snapshot

Some states respond to the post-ACP affordability gap by mandating that internet providers offer low-cost plans; others fund the discount themselves through a subsidy. New York and California illustrate the two paths.

New York: A Mandated Low-Cost Option

New York's Affordable Broadband Act requires internet providers serving more than 20,000 customers to offer qualifying households a reduced-cost plan. Eligible households can choose a $15 monthly plan with download speeds of at least 25 megabits per second, or a $20 monthly plan with at least 200 megabits per second. Qualification is tied to participation in SNAP, Medicaid, HEAP, the National School Lunch Program, or certain senior and disability rent increase exemptions; income-based eligibility is also accepted.1 Applicants confirm eligibility directly with their internet provider. New York City residents can call 311 for guidance, and residents elsewhere can call 211.1 Statewide enrollment figures are not yet published.1

California: A Subsidized LifeLine Pilot

California's Public Utilities Commission has taken a subsidy route through a California LifeLine broadband pilot. A pilot plan option must cost no more than $40 per month,2 with speeds of at least 100/20 Mbps and 1,280 GB of monthly usage; an earlier resolution specified 100/100 Mbps with latency of no more than 100 milliseconds.3 Because the program is a pilot, enrollment is limited and details may shift as the commission evaluates results.

Coverage remains uneven. A mandate puts the operational burden on providers but depends on enforcement and provider participation. A subsidy reaches eligible households directly but requires sustained state funding. Both approaches show that the post-ACP landscape is a patchwork, not a replacement.

The Policy Toolkit: Subsidies, ISP Requirements, and Public Offerings

Subsidies put public money in households, ISP mandates shift the affordability obligation to providers, and public offerings let a government or partner operate the service. Each instrument carries different fiscal exposure, administrative load, and take-up evidence. Strong state broadband offices are better positioned to run a mandate or public project, while lower-capacity states may lean on federal subsidy enrollment first.

Policy instrumentCost to governmentAdministrative burdenEvidence on take-up
Direct consumer subsidy (Affordable Connectivity Program)About $360 per participating household per year nationally; New York reported $331 per enrolled household.High: at least two-thirds of eligible households did not participate, pointing to enrollment and verification friction.Government Accountability Office reports about one-third of eligible households; Annenberg estimates 28 percent. New York enrolled 1.3 million households, and California enrolled 1.8 million households.
ISP low-cost plan mandateNot framed as a per-household state subsidy in the available data; mandates set price caps of $40 per month in Connecticut and $15 or $20 per month in New York.Moderate: requires defining eligibility, enforcing ISP participation, and monitoring plan offers.State-specific enrollment take-up for these mandates is not detailed in the available sources.
Municipal or public-private offering (California UWCA/CASF project)$250 requested from the California Advanced Services Fund per verified subscription; estimated total of $294.12 with leveraged and self-funding.Moderate: average reimbursement rates for similar enrollment work ranged from $15 to $30 per screening.Planned enrollment of 5,804 households in wireline or fixed-wireless broadband over two years.

BEAD Low-Cost Plan Requirements: What States Have Written Into Their Plans

Some states chose prescriptive price ceilings; others left the low-cost service option largely to provider proposals within a federal performance floor, a public policy split that shapes what administrators should expect to enforce.

The Federal Floor

BEAD requires a low-cost service option with at least 100 Mbps download, 20 Mbps upload, and latency at or below 100 ms.1 NTIA does not set a nationwide price ceiling because the Infrastructure Investment and Jobs Act bars rate regulation.1 Approved provider rates are not a federal ceiling, and states may add protections beyond Lifeline.1

Two State Approaches

California took the more prescriptive route: a $30 monthly plan for households at or below 200 percent of the federal poverty level, with a $75 Tribal rate.2 Its terms include no data caps, no installation fee, a free modem or router, no minimum service term, and 30 days' notice before any price increase.2

Wisconsin's post-award guidance lets providers submit their own plan as long as it meets the 100/20 speed and 100 ms latency standard, and may use an existing low-cost option.3 The cited state materials do not publish a fixed Wisconsin price ceiling or separate Tribal rate.3 Neither state's published materials describe a separate rural discount; the clearest geographic variation is California's higher Tribal ceiling.23

Timing and Verification

As of October 2026, most jurisdictions have approved proposals, but low-cost service is not uniformly live.5 Wisconsin approved awards in December 2025 with grant agreements expected in early 2026;4 California's final proposal was approved in July 2026 and the state utility commission authorized implementation in September 2026.6 Administrators should follow federal administration best practices and confirm their own state's approved final proposal for exact price, eligibility, consumer protections, Tribal terms, and grant execution milestones before telling residents a plan is available.

How to Measure Broadband Affordability

A fixed price ceiling and a percent-of-income burden measure answer different questions. One asks what a plan costs; the other asks what that cost means for a household.

Percent-of-Income Benchmarks

The most common yardstick is a share of household income. The FCC floated a 2% monthly household-income benchmark in 2016, and the Broadband Commission's target for developing countries is entry-level broadband at less than 2% of monthly gross national income per capita, down from an earlier 5% average-income goal. U.S. burden studies, including the Federal Reserve Bank of New York's broadband cost assessment for low- and moderate-income communities, show the distributional gap: low- and moderate-income communities devote about 2.43% of income to broadband, compared with 0.51% in high-income communities. The denominator matters because median household income, disposable income, and GNI per capita are not interchangeable.

Fixed Price Ceilings vs. Total Connectivity Cost

Fixed price ceilings are easier to administer. Virginia's Broadband Affordability Report, for example, treats a $30 monthly plan as broadly affordable for 93% of its population. But a standalone price omits taxes, equipment rental, installation fees, and the device needed to use the service. Total-cost methods add these recurring and amortized one-time costs, better reflecting real household burden but requiring more data and explicit assumptions.

Measure Subscriptions, Not Build-Out

Local affordability thresholds vary widely. The Federal Reserve study reported by Community Networks finds New York City's range is roughly 1.89% to 2.45% of income, while Detroit's runs from 3.15% to 6.10%. Because many plans in BEAD-eligible areas exceed affordability benchmarks, administrators should track adoption, enrollment, and take-up outcomes rather than miles of fiber or plans offered. A network that is built but not subscribed delivers only partial public benefit.

Municipal Broadband and Affordability Outcomes

Municipal broadband carries an intuitive appeal: public ownership should bend prices toward residents, while direct subsidies put money in households' hands. The evidence does not cleanly favor one path.

What the evidence shows

A 2026 study of 194 Tennessee and Iowa counties, 38 of them served by public utility providers, associated public-provider presence with a 6 percentage point higher adoption rate.1 The authors stress the design was cross-sectional and not causal, with income differences across counties. Price evidence remains thinner. One review found a municipal fiber-to-the-home offering was lower-priced than private service over four years, but jurisdictions, sample, and controls are unclear.2

Municipal price points and limits

Southeast Ohio's Buckeye Hills, a rural broadband case study, averaged about $90 per month, a level described as infeasible for many households. Madison, Wisconsin piloted a $20 per month subsidized connection in one low-income complex, then closed it after 18 months because most renters still could not sustain the cost.3 Wilson, North Carolina and Chattanooga, Tennessee are often cited for service and affordability, but broad rural price cuts and small-scale benefits remain inconclusive. Public-private models such as Westminster, Maryland's Ting partnership lack documented low-income take-up.4

Versus direct subsidies

Subsidy estimates vary widely: one analysis found a 10 percent price cut raises adoption between 0.5 and 6.2 percent, while a federal evaluation of the Broadband Technology Opportunities Program found no adoption effect.5 Municipal networks can anchor competition, but public policy and administration leaders should measure subscriptions and retention, not fiber miles.

Implementation Challenges for State and Local Administrators

What makes broadband affordability so hard to administer after the Affordable Connectivity Program ended? The answer starts with sequencing and ends with provider incentives, and it will determine whether publicly funded networks actually get used. Administrators face four linked challenges: capacity, eligibility verification, provider participation, and sunset risk.

Sequence Affordability With Deployment

States that wait until fiber is built before designing low-cost plans risk pricing households out of networks paid for with public money. As Pew Charitable Trusts' Broadband Policy Cornerstone: Affordability notes, networks built with public dollars that price out low-income households deliver only partial public benefit. Administrators should treat affordability instruments as a condition of deployment, not an afterthought. That means aligning state broadband offices, public utility commissions, and human services agencies early in the planning cycle as part of broader public service reforms.

Learn From ACP Eligibility Friction

The Affordable Connectivity Program relied on existing benefit eligibility, which created churn: households qualified one month and fell out the next. State programs can reduce that friction by accepting multiple proofs of income or using automatic renewal where state law allows, while still building audit trails to prevent fraud. Eligibility verification that is too burdensome pushes qualifying households away; verification that is too loose invites waste.

Keep Providers in the Program

Providers need a stable subscriber base to recover capital costs. If the low-cost option pays too little or demands excessive reporting, internet service providers will decline to participate. Return-on-investment security depends on predictable reimbursement, streamlined reporting, and long-term contract certainty. States that treat the low-cost option as a one-time mandate often find providers quietly exit after the first funding cycle.

Design for the Funding Cliff

When the ACP lapsed in 2024, responsibility shifted to states without a dedicated federal replacement. That intergovernmental shift created a funding cliff for households and agencies alike. Administrators should build sunset triggers and phase-down plans into affordability programs, so a political or fiscal shock does not abruptly cut off enrolled households.

Case Studies and What to Take Into Your MPA or MPP Practice

Maryland's Emergency Broadband Benefit, documented in the Maryland IIJA Facilitated Session, paired a $15 monthly state subsidy with the federal ACP and reached more than 200,000 households before it closed on February 29, 2024, when its $45 million allocation ran out. A 2023 survey found only 7% of households earning under $50,000 reported ACP enrollment and 82% reported no subsidy at all, pointing to awareness gaps.

New York's Price Caps

New York's Affordable Broadband Act, covered in the New York State Comptroller Report 20-2025 on Broadband Affordability, took effect in January 2025, capping 25 Mbps service at $15 and 200 Mbps at $20, taxes and fees included, for ISPs with over 20,000 in-state subscribers. First-year compliance reports from 16 providers produced usable data for only 9, and just 1,253 households appeared in the initial public figures. With roughly 1.2 million New York households receiving SNAP, the reported count leaves total reach unresolved.1

California's Enrollment Volume

California LifeLine, per the California LifeLine Overview Presentation, reported 1,874,244 active subscribers on March 1, 2026, a 5.17% increase from December 1, 2025. The figure confirms short-term enrollment growth but does not show eligible-household take-up or whether adoption or retention changed.

What These Cases Teach

Across Maryland, New York, and California, the recurring lesson is outcome accountability. Enrollment counts and price caps are outputs, not outcomes. Administrators must track disconnections, arrears, service quality, and whether low-income households keep using the connection for work, telehealth, or education. For MPA and MPP students, the core skill set taught in MPP & MPA Curriculum Reform includes benefit-aligned eligibility design, federal-state-local coordination, vendor and ISP negotiation, and evaluation plans built before launch, not retrofitted after.

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