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July 7, 2025

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

E-Rate for FY 2025:

Wave 11 of funding commitment decision letters for FY 2025 was released on Thursday, July 3rd, for $48.3 million.  Total funding is now $1.42 billion.  Currently, USAC has funded 73.4% of submitted applications, representing 44.3% of the dollars requested.

Cybersecurity Pilot Program – Application Window:

The Form 471 application window for the Cybersecurity Pilot Program opened on March 18th and will close on September 15th, 2025.  Total pilot funding is capped at $200 million for 690 applicants. 

Last Tuesday, July 1st, was the deadline set by the FCC to permit Pilot participants to voluntarily withdraw from the program without incurring any liability.  Based on our count, as of the end of last week, seventeen previously approved participants had notified the FCC that they were withdrawing. It would free up just over $8 million in previously allocated funding. It is more than enough additional funding to bring the twenty-six partially funded Pilot applicants up to the full budget level (currently a shortfall of $3.8 million).  It also gives the FCC the option, should they choose, to modestly add funding for new or existing program participants.

Upcoming Dates:

July 7 FY 2024 Form 486 deadline for Wave 46.  The Form 486 deadline is 120 days after the FCDL date, or the service start date (typically July 1st), whichever is later.  The next Form 486 deadlines for FY 2024 are:
Wave 47                      07/11/2025
Wave 48                      07/18/2025
Wave 49                      07/25/2025
Wave 50                      08/01/2025
August 18 Last day to certify a CBR Form 470 to meet the minimum 28-day posting period before filing the CBR Form 471.
September 5 Final day of the PIA summer deferral period (which began May 23rd).
September 9 USAC in-person training in Denver, CO.
September 15     Close of the Cybersecurity Pilot Form 471 application window and deadline for filing the Form 484 Part 2.
September 16 USAC in-person training in Washington, DC.

FCC Streamlined Decisions:

The FCC issued another set of “streamlined,” precedent-based appeals and waivers last week.  As with past streamlined decisions, applicants facing similar problems 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 Search for Filings under Docket 02-6 (E-Rate) or Docket 21-93 (ECF).

In June’s streamlined decisions (DA 25-509), the FCC:

  1. E-Rate Dismissed:
    1. Three Requests for Waiver dismissed as moot where USAC had already approved the underlying funding requests.
    2. One Request for Waiver dismissed to allow for an appeal to be filed with USAC.
    3. Two Petitions for Reconsideration failing to identify any reasons warranting reconsideration.
  2. E-Rate Granted:
    1. One Request for Review finding that the service provider had filed an updated Form 473 (“SPAC”).
    2. Three Requests for Review or Waiver granting additional time to respond to USAC inquiries (based on appeals filed over ten years ago).
    3. One Petition for Reconsideration on a Form 471 filed more than 30 days late due to a serious illness.
    4. Two Requests for Waiver for late-filed appeal/waivers filed only a “few days” late.
    5. One Request for Waiver for a late-filed appeal/waiver due to a USAC error.
    6. Two Requests for Waiver for late-filed Form 471s due to circumstances beyond their control.
    7. One Request for Waiver for a late-filed Form 471 due to a serious medical condition.
    8. Eight Requests for Waiver for late Form 471s filed within 14 days of the close of the window.
    9. Six Requests for Review and/or Waiver on ministerial and/or clerical errors on Form 471 applications.
    10. One Request for Review and Waiver on a ministerial and/or clerical error on a Form 486.
    11. One Request for Waiver on an invoice deadline extension request based on reconsideration of an FCC decision.
    12. One Request for Review remanded to USAC involving the reclassification of Internal Connections (based on an appeal filed over 20 years ago).
    13. One Request for Waiver based on a USAC decision issued after the invoice deadline.
  3. E-Rate Granted in Part:
    1. One Request for Declaratory Ruling or Waiver “finding that on-campus housing provided for teachers in remote Alaska is a non-instructional facility eligible for category one and category two E-Rate support, where it serves a unique population with an extremely harsh climate,” but denying a “request to categorize any housing that the school district owns or rents to provide housing to its teachers and limiting this finding to on-campus teacher housing located on the school campus that can be connected to the school network with a one-time installation cost and necessary internal connections.”
  4. E-Rate Denied:
    1. One Request for Review regarding categories of service.
    2. One Request for Review involving duplicative, partial-year, services.
    3. One Request for Waiver on providing additional time to file a Form 470.
    4. Three Requests for Review or Waiver for ineligible services.
    5. Twenty-two Requests for Waiver for late-filed Form 471 applications.
    6. Three Requests for Waiver for late-filed invoice deadline extension requests.
    7. One Request for Waiver for a Form 470 that did not seek bids on types of services later requested.
    8. Five Requests for Waiver for untimely filed appeals or waiver requests.
  5. ECF Denied:
    1. One Request for Waiver to extend a service delivery date beyond the expiration of the COVID-19 emergency period.