The FCC's Notice of Proposed Rulemaking (NPRM) reviewing the E-Rate program was officially published in the Federal Register this morning. The notice, titled "FCC to Review E-Rate Program to Ensure Congress's Vision," marks the formal start of the public comment period on proposed changes to the program.

You can read the full notice here: FCC to Review E-Rate Program to Ensure Congress's Vision

Download the NPRM here: NPRM

Key Dates

• Comments due: on or before October 13, 2026
• Reply comments due: on or before November 12, 2026

Stakeholders interested in weighing in on the future of the E-Rate program should plan to submit comments well ahead of the October deadline, with an opportunity to respond to other filings through mid-November.

SECA has filed an Ex Parte letter with 'pre-comments' to the Draft Order on E-Rate reforms.

Download SECA Letter

Download Draft Order

The FCC has released a final Report and Order and Order on Reconsideration that approves the implementation of a competitive bidding portal.

The Order also implements simplifications to the E-Rate Program including (but not limited to):

• providing guidance for transition of services
• clarifying that cost-allocation is not required for ANY category 1 service (including transmission only)  if at least 90% of an applicant’s requested recurring C1 service will be used for an eligible purpose during the funding year
• providing limited exceptions for mid year bandwidth increases
• clarifying absent a deadline in the narrative, applicants should consider all bids received before the evaluation process, which may occur sometime after the minimum 28-day waiting period
• eliminating the FCC Form 486 beginning in Funding year 2028
• moving CIPA certifications to the FCC Form 471
• specifying that consortia will need to collect the annual FCC Form 479 prior to certifying CIPA compliance on the FCC Form 471
• modifying invoice filing deadline to one based on the date of the FCDL
• amending program rules to permit a single 120-day extension of the original invoice filing deadline if the request is made within 15 days of the original invoice filing deadline
• adopting a rule providing for a one-time, 60-day grace period to resubmit corrected versions of requests for reimbursement that were timely filed before the invoice filing deadline but rejected by USAC
• updating E-Rate definitions and rules

Download Report and Order

SHLB Coalition, State E-Rate Coordinators’ Alliance, American Library Association, AASA, The School Superintendents Association, American Federation of School Administrators, National Education Association, and CoSN – Consortium for School Networking have filed a joint ex parte letter expressing concerns with the adoption of an E-Rate Bidding Portal as outlined in the Commission’s draft Report and Order and Order on Reconsideration (Draft Order).

Download Letter

The FCC has released a Report and Order and Order on Reconsideration that would, if approved at the April 30 Open Commission Meeting, implement the competitive bidding portal that has been under consideration for several years.

Download Report and Order

SECA has filed an ex parte letter asking for service delivery deadline relief for the Cybersecurity Pilot Program.

Download Filing

1) Internal Connections Expanded

Software-based services are now classified as Internal Connections.

Previously, these services were split between Internal Connections and Basic Maintenance of Internal Connections (BMIC), causing confusion and frequent funding denials.

For FY2026, Internal Connections now includes:

• Software-based services
• Bug fixes and security patches
• Software-based technical assistance
• Remote configuration changes

2) Basic Maintenance of Internal Connections Narrowed

BMIC configuration changes are now limited to on-site, in-person only.

For FY2026, The following services have been removed from BMIC:

• Online and telephone-based technical support
• Software upgrades
• Security patches

3) Pro-ration and Splitting Requirements Removed

• Ends the requirement to split parts of a single license or service between IC and BMIC
• Removes the requirement to break out the one-time cost of a license over several funding years
• Applicants will be required to seek reimbursement in the funding year when the costs are incurred
• Applicants that are requesting software- or remote-based services that they have previously purchased and sought pro-rated reimbursement under the prior eligibility requirements may seek support for the remainder of the contract in funding year 2026 or continue requesting pro-rated support

In two decisions released on September 30, 2025, the FCC has rescinded the use of E-Rate funds for hotspots to provide at-home internet services for students and library patrons and of Wi-Fi services to provide Internet services to students on school buses.

Bus Wi-Fi services became E-Rate eligible in FY2024 while hotspots were to become eligible in FY2025.

An Order on Reconsideration (FCC 25-62) rescinds the eligibility of off-premises use of Wi-Fi hotspots and associated wireless Internet services effective FY2025, and directs USAC to amend the FY2025 Eligible Services List and to deny pending requests.

A Declaratory Ruling (FCC 25-63) declares that the provision of Wi-Fi on school buses is ineligible for E-Rate beginning in FY2025 and directs USAC to deny pending requests for funding in FY2025 and in subsequent funding years.

1. Congress properly delegated authority to the FCC
2. The FCC's use of USAC as program administrator is permissible
3. Neither delegation violated the nondelegation doctrine
4. USF is in fact constitutional