E-Rate for FY 2025:

Wave 31 of Funding Commitment Decision Letters (“FCDL”s) for FY 2025 was released on Thursday, November 20th, for $32.5 million.  Total funding for FY 2025 is $2.37 billion.  Currently, USAC has funded 92.6% of submitted applications, representing 79.2% 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 continuing, with some applications already reported to be “Wave Ready.”  Issuance of the first Funding Commitment Decisions Letters (“FCDLs”) will require FCC review and should begin shortly now that the government shutdown has ended.

In late September, just before the government shutdown, the FCC released a draft of the Eligible Services List (“ESL”) for FY 2026 seeking comments and reply comments later in October.  The shutdown delayed that process.  The initial comment period was extended until the shutdown ended, and reply comments are now due December 3rd.

To no one’s surprise, because the FCC had already moved to eliminate the eligibility of hotspots and school bus Wi-Fi and had reissued an amended ESL for FY 2025 retroactively eliminating those services, the draft ESL for FY 2026 did so as well.
The one positive element of the FY 2026 draft was the FCC’s proposal “to treat all currently eligible software- or remote-based services, including bug fixes, security patches, software-based technical assistance, and configuration changes the same and have applicants request all software- and remote-based services with the internal connections equipment that they support.”  Such a change would eliminate much of the historic confusion surrounding the differences between managed internal broadband services (“MIBS”) and basic maintenance of internal connections (“BMIC”).

Several sets of initial comments on the FY 2026 draft (e.g., SECA, SHLB Coalition, and Kellogg & Sovereign), not only support the proposed change but urge the FCC to go further by including basic maintenance as a managed service under MIBS, thus eliminating “BMIC” as a separate category altogether.  This additional simplification would be a boon to all Category 2 applicants.  Ideally, this could be made effective FY 2026, the start of the new Category 2 budget cycle.

Other comments we support were submitted by Funds For Learning and the Los Angeles USD.  Both parties supported MIBS/BMIC changes but added suggestions to broaden the definition of basic firewalls to include more advanced features now commonly included in modern firewalls.  For years, ESL comments to include cybersecurity products and services in the ESL have been rejected by the FCC, who only recently established the limited Cybersecurity Pilot Program.  Modernizing the eligibility of “basic” firewalls would be a small, but meaningful, step to improving cyber protection for schools and libraries beginning with the new Category 2 budget cycle.

We were not surprised to see a few comments decrying the loss of eligibility for hotspots and bus Wi-Fi (e.g., American e-Rate Solutions or the related Petition for Reconsideration by the California Public Utilities Commission).  No relief is expected in the final Eligible Services List for FY 2026.

Reply comments on the FY 2026 ESL are due Wednesday, December 3rd.

Dated October 31st, but not posted on the FCC website until November 13th following the end of the government shutdown, USAC posted a list summarizing all current USAC Administrative Procedures not otherwise explicitly stated or codified in an FCC rule or regulation.  In broad procedural categories, the list includes:

        Appeals to the Administrator
        Commitment Adjustments and Recovery of Improperly Disbursed Funds
        Equipment Transfer Request Dismissal
        Forms Processing
        Invoicing
        Overall Procedures
        Program Integrity Assurance
        Service Substitutions
        Service Provider Invoice Number (“SPIN”) Changes

The entire descriptions are worth reviewing, among which we would note:

• The variety of uses of the Form 500 to report or request equipment transfers, Service Start Date or Service Delivery Deadline changes.
• The requirement to address audit findings, which used to be required within six-months, but which has been reduced to 60 days as of January 1, 2023.
• The difference between the handling of split funding requests (“FRNs”) and split line items.
• The difference in deadlines for Corrective Service Substitutions depending upon whether the requested change is to the category of service or is to correct or adjust bandwidth.  The former must be filed before the Service Delivery Deadline (“SDD”); the latter must be filed before the Invoice Delivery Deadline (“IDD”).
• Corrective SPIN changes must be received no earlier than the date of the FCDL and received no later than the last date to submit an invoice.

Upcoming Dates:

USAC’s E-Rate News Brief dated November 18, 2025, covers the following topics:

• E-Rate Tips including:
  • Updates to USAC’s Category Two (C2) Budget Tool FY2021+.
  • Reminder to applicants to file their Form 486s after receiving FY 2025 FCDLs.
  • Reminder to service providers to file their Form 473 annual certifications.
• Funding Year (FY) 2025 Commitments.
• FCC Rescinds E-Rate Eligibility for School Bus Wi-Fi and Wi-Fi Hotspots.
• What to Do if You Missed Your October Invoice or FCC Form 486 Filing Deadline.
• Competitive Bidding – Set Yourself Up for Success.
• Tips for the EPC Administrative Window.
• Use Open Data to Confirm Invoicing and Service Delivery Deadlines.
• 2025 Training and Outreach.