E-Rate for FY 2026 – Application Window:

Application Window: The Form 471 application window for FY 2026 opened last 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 during application review.

E-Rate for FY 2025:

USAC issued Wave 38 for FY 2025 on Thursday, January 22nd, for $22.3 million.  Total funding for FY 2025 as of Wave 38 stands at $2.54 billion.  Currently, USAC has funded 94.9% of submitted applications, representing 86.1% of the dollars requested.

Cybersecurity Pilot Program:

USAC has still not issued a second Cyber Pilot funding wave.  After one Cyber wave, issued on December 17th, funding for the Cybersecurity Pilot Program stands at $18.7 million.

The lack of additional funding commitments for the Pilot program is disappointing and stands in stark contrast to USAC’s traditional post-window funding progress in the E-Rate program.  Four months after the close of the FY 2025 E-Rate application window, for example, and an equivalent amount of time after last September’s close of the Cybersecurity Pilot application window, USAC had funded roughly 80% of the E-Rate applications, representing half of the dollars requested.  We urge USAC to devote additional resources to the processing of pending Pilot applications.

Upcoming Dates:

GAO Cites E-Rate Program for Fraud, Waste, and Abuse Prevention:

In a study of five federal funding programs, the Government Accounting Office (“GAO”) found that only USAC’s E-Rate Program had documented procedures to meet all nine leading practices “to oversee and prevent fraud, waste, and abuse in awards, including grants, contracts, and loans” (see GAO summary).  The nine requirements are:

1. Dedicated entity to lead fraud management activities.
2. Senior Management Council to assess and monitor deficiencies in internal control.
3. Maintain agencywide and program-specific risk profiles.
4. Assess program specific risks, including fraud.
5. Determine risk responses and document an antifraud strategy.
6. Implement specific control activities to prevent and detect fraud.
7. Establish collaborative relationships with stakeholders and create incentives to help ensure effective implementation of the antifraud strategy.
8. Conduct risk-based monitoring and evaluate all components of the Fraud Risk Framework.
9. Evaluate audits, including recovery audits and single audits.

As if to highlight the E-Rate program’s commitment to addressing instances of fraud, the U.S. Attorney’s Office for the Eastern District of New York announced last week that the principal of a New York-based E-Rate consulting firm had pleaded guilty to an agreement to steer E-Rate and ECF funds to school vendors in exchange for a share of the associated vendors’ profits.

FCC Formalizes the Ineligibility of Hotspots:

A rule filing, entitled “Addressing the Homework Gap Through the E-Rate Program; Partial Withdrawal,” was published in the Federal Register last week.  The filing grants a petition for reconsideration filed by Maurine and Matthew Molak, finding that the best reading of Section 254 of the Communications Act of 1934, as amended, does not permit funding of off-premises use of Wi-Fi hotspots and the associated wireless internet services with E-Rate program support.  In doing so, the FCC denied petitions for reconsideration filed the by Schools, Health & Libraries Broadband Coalition (“SHLB”) and the Los Angeles Unified School District (“LAUSD”) arguing to the contrary.

We suspect that this publication in the Federal Register will be the final step necessary leading to the formal denial by USAC of the roughly 830 pending FY 2025 FRNs for hotspot service.  With less FCC formality, USAC had already denied 489 FY 2025 school bus Wi-Fi FRNs last month (see our newsletter of December 22nd).

USAC’s E-Rate Special Edition News Brief dated January 21, 2026, announced the opening of the FY 2026 Form 471 application filing window last Wednesday, January 21st.  The window will close at 11:59 p.m. EDT on April 1st.

Besides noting the window closing date, the News Brief also mentions that Wednesday, March 4th is the last day to file a Form 470 to begin a competitive bidding process, wait the required minimum of 28 days before selecting a vendor, secure a contract(s), and file a timely Form 471 on the last day of the application window.  We caution that waiting to file a Form 470 on March 4th, while technically feasible, is a highly risky strategy given how smoothly all other steps in the process must go on April 1st — which, coincidentally, is April Fool’s Day.

One new aspect of the Form 471 this year is that applicants will be asked to specify their preference for BEAR or SPI invoicing for each funding request.  This choice can be changed post-commitment via a Form 500.

The primary purpose of last week’s News Brief was to summarize the required steps leading up to the filing of a Form 471 application, including:

• Obtaining EPC access.
• Reviewing the FY 2026 Eligible Services List.
• Filing the Form 470 to start the competitive bidding process.
• Filing the Form 471 application for FY 2026 services.

USAC will be hosting an E-Rate pre-commitment process Q&A session on February 19th (register).