It occurred to me that there is a reform not mentioned in the NPRM: lowering the maximum discount to something below 90%. This reform was proposed years ago by the Task Force on Waste, Fraud and Abuse, has been supported in past NPRMs by all commenters except the 90%-discount districts, and has been widely expected to become policy some time soon.
Let's hope that it's not in this NPRM because the FCC plans to make it a policy before the end of the comment period (almost 6 months from now!).
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