E-Rate for FY 2025:
Wave 29 of Funding Commitment Decision Letters (“FCDL”s) for FY 2025 was released on Thursday, November 6th, for $28.1 million. Total funding for FY 2025 is $2.28 billion. Currently, USAC has funded 92.0% of submitted applications, representing 74.1% of the dollars requested.
Cybersecurity Pilot Program:
The Form 471 application window for the Cybersecurity Pilot Program closed on September 15, 2025. Total pilot funding is capped at $200 million for 690 applicants. PIA review of Pilot applications is proceeding with some applications reported to be “Wave Ready.” Issuance of the first Funding Commitment Decisions Letters (“FCDLs”), however, will require FCC post-shutdown review.
FCC, USAC, and the Government Shutdown:
The government shutdown is still affecting the FCC. USAC, however, is operational and fully staffed. From an E-Rate perspective, the most visible aspect of the difference between the two is that USAC continues to issue funding decisions on FY 2025 funding requests and to review and pay BEAR and SPI invoices. The FCC’s activities, in contrast, have been sharply curtailed, with significant reductions in staffing. This has undoubtedly cut into the processing of FCC E-Rate waivers and appeals and led to the cancellation of USAC webinars (which require FCC review). More importantly, it has slowed the release of the Eligible Services List for FY 2026, which could delay the opening of the Form 471 application window. Lack of coordination between USAC and the FCC is also causing delays in the release of Cybersecurity Pilot Program FCDLs.
One other aspect of the shutdown that we are following closely, although not immediately related to E-Rate, is funding for the Supplemental Nutrition Assistance Program (“SNAP”). SNAP funding was cutoff on November 1st and is now being partially restored under a court order from contingency funds. As discussed in our newsletter of November 3rd, the 2025 budget reconciliation bill, currently stalled in Congress and at the heart of the shutdown, proposes sweeping reductions — approximately $287 billion over ten years — in the SNAP program by tightening eligibility criteria. If enacted, as currently proposed, the number of families eligible for SNAP benefits would be reduced by millions. Over time, such a change would begin to limit CEP participation and NSLP percentages which, in turn, would lead to lower E-Rate discount rates for certain applicants.
In the short term, of course, the most immediate concern is making sure that SNAP-eligible families are being fed. A study issued this past weekend by the Food Research & Action Center (“FRAC”) shows SNAP benefit status by state. For New York, full benefits will be available this week.