E-Rate for FY 2026 – Application Window:

Application Window: The Form 471 application window for FY 2026 opened Wednesday, January 21st, and will close on Wednesday, April 1st, at 11:59 p.m. EDT.  The administrative window, which gave applicants the opportunity to update their EPC entity profiles, closed January 16th.  Any subsequent entity changes during the window period will have to be made as RAL corrections or updated during application reviews.

E-Rate for FY 2025:

USAC issued Wave 44 for FY 2025 on Thursday, March 5th, for $7.27 million.  Total funding for FY 2025 is now $2.57 billion.  Currently, USAC has funded 97.4% of submitted applications, representing 89.3% of the dollars requested.

A new invoicing requirement, scheduled to take effect next August (see our newsletter of February 16th), limits payments on both applicant BEARs and service provider SPIs to those entities whose Form 498s have been updated with UEI numbers and who have current SAM.gov accounts.  The new requirement will apply to both E-Rate and Cyber invoices (see additional mention in the latest Cyber Pilot newsletter discussed below).  Last week, USAC sent email notices entitled “Action Required: Obtain Your UEI Through SAM.gov” to EPC account holders who had not yet updated their Form 498s to include their UEI numbers.  Account holders will be required to maintain their registrations by renewing SAM.gov annually.  No future updates will be required within the Form 498 unless banking or UEI information changes.

Cybersecurity Pilot Program:

No additional Cyber Pilot funding wave was released last week; the next funding wave is not expected until late March.  USAC did, however, release an initial wave of Revised Funding Commitment Decision Letters (“RFCDLs”) approving changes that had been submitted via CBR Form 488s by previously funded Cyber applicants needing to update contract dates, service delivery dates, service details, and/or invoicing modes.

Cyber funding after three waves totals $49.8 million.

Upcoming Dates:

FCC Streamlined Decisions:

The FCC issued another set of “streamlined,” precedent-based appeals and waivers on March 2nd.  As with past streamlined decisions, applicants facing problems similar to those addressed in these decisions may garner useful information by carefully reading the additional FCC explanations found in the footnotes.  The original appeal and/or waiver requests can be found online in the FCC’s Electronic Comment Filing System under Docket 02-6 (E-Rate), Docket 23-234 (Cyber) or Docket 21-93 (ECF).

In its streamlined decisions (DA 26-171) for February, the FCC:

1. E-Rate Dismissed:
   1. Two requests rejected for failure to comply with the FCC’s basic filing requirements.
   2. Four Petitions for Reconsideration for failing to identify any reasons warranting reconsideration.
   3. Two Petitions for Reconsideration filed more than 30 days after the Bureau’s decisions.
2. E-Rate Granted:
   1. One Request for Review approving the acceptance of a competitive bidding award offering service above the district’s requested speed.
   2. Two Requests for Review granting fully compliant discount calculations.
   3. One Request for Review involving an RFP not using the phrase “or equivalent,” but instead indicating that “make/model all equivalent brands will be considered.”
   4. One Request for Review granting additional time to respond to a USAC request for information.
   5. Eight Requests for Waiver for ministerial and clerical (“M&C”) errors involving Form 471 or invoicing errors.
   6. One Request for Waiver for a timely filed appeal based on the associated RFCDL date.
   7. One Request for Waiver of the invoice filing deadline for a late USAC decision.
3. E-Rate Denied:
   1. One Request for Review for not filing a Form 470.
   2. One Request for Review and/or Waiver when price was not the primary factor in vendor selection.
   3. One Request for Waiver for failure to repay debt in a timely manner under the Red Light Rule.
   4. One Request for Review involving the recovery of funds for ineligible services.
   5. One Request for Review for a late-filed Form 486.
   6. Two Requests for Waiver for late-filed invoice deadline extensions.
   7. Four Requests for Waiver for late-filed appeals or waivers.
4. Cyber Pilot Denied:
   1. One Request for Reconsideration for late-filed appeal or waiver.
5. ECF Partially Granted:
   1. One Request for Waiver of the ECF invoice deadline, based on a reduced funding commitment, following a delayed service substitution decision.
6. ECF Denied:
   1. One Request for Review involving an unsupported 1:1 initiative.
   2. One Request for Waiver “when, among other flaws, the applicant did not provide sufficient evidence that the cost of the equipment was reasonable, nor that it represented the actual costs of the equipment.”
   3. One Request for Waiver for a late-filed appeal or waiver.

USAC’s Schools and Libraries Cybersecurity Pilot Program Newsletter dated March 2, 2026, summarizes the appeal and waiver process, and provides links to a webinar recording and user guides for Pilot Forms 472, 474, and 488.

Most importantly — and this applies to E-Rate as well as to the Cyber Pilot — the newsletter includes a succinct paragraph alerting applicants and service providers that, beginning sometime in August (exact date not determined), USAC will begin using SAM.gov banking information to remit BEAR and SPI payments.  The following is USAC’s newsletter information to which we have highlighted the key requirements:

Beginning August 2026, USAC will use SAM.gov banking information to remit payment for all Universal Service Fund (USF) requests for reimbursement. All service providers and E-Rate or Pilot Program participants who use the BEAR invoicing method to receive USF disbursements must have a Unique Entity Identifier (UEI) on their FCC Form 498, an active SAM.gov registration, and a valid bank account associated with their SAM.gov account. Please note that you must annually register on SAM.gov to keep your SAM.gov account active. You will not be able to receive USF disbursements if your SAM.gov registration becomes inactive. For more information, see the SAM.gov UEI Requirement.

For applicants and service providers who are already registered in SAM.gov and have a Form 498 on file in EPC with a UEI and appropriate bank account information, the only requirement will be to maintain their annual SAM.gov renewals.  Those who have yet to register for SAM.gov can look forward to a new experience in government bureaucratic systems.