Upcoming Dates:
September 23 |
Due date for reply comments on school bus Wi-Fi in the FCC’s Section 706 Report proceeding (see our newsletter of September 15th). |
September 30 |
Last day to receive service, or to submit a Service Delivery Deadline (“SDD”) Extension request, for FY 2024 non-recurring services and prior year FRNs with a SDD of September 30, 2025. |
October 20 |
FCC deadline for nominating six new (or renewed) USAC Board members (see DA 25-738 and our newsletter of August 25th). |
October 28 |
Deadline to submit invoices for FY 2024 recurring services or to request a deadline extension. |
October 29 |
First FY 2025 Form 486 deadline for applicants funded in Waves 1-10. The Wave 11 deadline will be October 31, with subsequent Form 486 Wave deadlines following weekly. Specifically, the Form 486 deadline is 120 days after the FCDL date, or the Service Start Date (typically July 1st), whichever is later. |
October 29-31 |
AnchorNets: 13th Annual SHLB Conference, Crystal City, VA. E-Rate Central is a Gold-level sponsor of the event. |
USF Quarterly Contribution Factor Hits a New High — Yet Again:
The FCC announced (DA 25-840) that the Proposed Fourth Quarter 2025 Universal Service Contribution Factor will be 38.1%. This is one and a half percentage points higher than the previous high. Again, we say, “This cannot go on,” but it does.

As we have discussed in the past, the underlying problem continues to be, not so much that Universal Service Fund (“USF”) expenses are rising but that interstate telecommunications revenues (i.e., the contribution base) have fallen sharply over the last decade and a half. The only long-term solution is to expand the contribution base with internet service and/or content provider revenues.
With June’s Supreme Court decision that the Universal Service Fund (“USF”) is constitutional (see our newsletter of June 30th), a bipartisan and bicameral Congressional USF Working Group is exploring possible solutions. A call for comments on the subject closed last Monday. Although comments in response to specific questions posed by the Working Group are not expected to be made public, many of the participating responders have not been shy about releasing their own policy statements. Examples of positions we support include:
- USTelecom—The Broadband Association submitted formal comments urging Congress to seize this pivotal moment to modernize the USF and safeguard universal connectivity for the 21st century.
- The Consortium for School Networking (“CoSN”) and the State Educational Technology Directors Association (“SETDA”) issued a joint response urging Congress to:
- Reaffirm Congressional commitment to E-Rate.
- Modernize to address cybersecurity.
- Support sustainable home connectivity.
- Ensure long-term USF sustainability.
- The Schools, Health & Libraries Broadband (“SHLB”) Coalition submitted comments making some of the same points including:
- Preserving and strengthening E-Rate and RHC programs while streamlining their administration.
- Expanding the USF contribution base to stabilize the funding mechanism, while rejecting proposals to subject USF to the annual appropriations process.
- Establishing multi-gigabit benchmarks for schools, libraries, and health clinics to meet growing speed and bandwidth demand.
- Supporting cybersecurity protections for schools, libraries, and health clinics.