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February 9, 2026

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.

With this edition of our weekly E-Rate newsletter, we celebrate this week’s 30th anniversary of the Telecommunications Act of 1996 that was signed into law on February 8, 1996.  The Act was the first major overhaul of U.S. telecommunications policy in more than six decades since the Communications Act of 1934.  Most importantly for those of us involved with schools and libraries, the ’96 Act was the basis for the E-Rate Program.  Let’s all raise a glass to celebrate the Telecommunications Act on its 30th anniversary!

E-Rate for FY 2026 – Application Window:

Application Window: The Form 471 application window for FY 2026 opened 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 as a RAL correction or updated during application review.

E-Rate for FY 2025:

USAC issued Wave 40 for FY 2025 on Thursday, February 5th, for $7.17 million.  Total funding for FY 2025 is now $2.55 billion.  Currently, USAC has funded 95.0% of submitted applications, representing 86.6% of the dollars requested.

Cybersecurity Pilot Program:

USAC has indicated that it expects to issue Cyber funding waves monthly with the next wave expected in March.  Current Cyber funding, after two waves, is now $28.8 million.

The FCC released a revised version of the Cybersecurity Pilot Program Frequently Asked Questions last week (changes to previous FAQs are denoted by an asterisk before each FAQ number).  The most significant change was to eliminate the conflicting guidance in FAQ 1.5a regarding the last date to receive services.  That end date is now clearly stated as “three years from the date of the first FCDL for each funding request number (FRN).”  What this means, — much to the dismay of many applicants — is that waiting to receive FCDLs before initiating continuing services (which may take a few months to get up and running) will mean that funding will not be available for a full 36 months.*

Upcoming Dates:

February 13 FY 2025 Form 486 deadline for applicants funded in Wave 26.  More generally, 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 2025 are:
Wave 27              02/20/2026
Wave 28              02/27/2026
February 19 USAC webinar with a Q&A session on the E-Rate pre-commitment process (register).
February 25     Extended invoice deadline for FY 2024 recurring services for applicants with approved extension requests.
March 4 Last day to file a Form 470 for FY 2026 in time to meet the 28-day minimum posting requirement and file a Form 471 for FY 2026 within the filing window.
April 1 The Form 471 application window for FY 2026 closes at 11:59 p.m. EDT.

FCC Streamlined Decisions:

The FCC issued another set of “streamlined,” precedent-based appeals and waivers on February 2nd.  As with past streamlined decisions, applicants facing problems similar 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 Electronic Comment Filing System under Docket 02-6 (E-Rate), Docket 23-234 (Cyber) or Docket 21-93 (ECF).

In its streamlined decisions (DA 26-85) for February, the FCC:

  1. E-Rate Dismissed:
    1. One request rejected for failure to comply with the FCC’s basic filing requirements.
    2. Two Requests for Review dismissed to allow appeals to be filed with USAC.
    3. One Petition for Reconsideration of a waiver for a late-filed application failing to identify any reasons warranting reconsideration (and specifically rejecting an argument that a waiver “is warranted because of employee confusion over the E-Rate rules”).
  2. E-Rate Granted:
    1. One Request for Review when a contract, with the only bidder, was signed without a bid review.
    2. Two Requests for Review (from one applicant) granting an additional 15 days to file additional discount rate information.
    3. Two Requests for Waiver granting additional time to respond to USAC on invoicing inquiries.
    4. One Petition for Reconsideration granting additional time to file a waiver when the applicant was working with USAC to resolve a clerical error on two timely-filed Form 471s.
    5. One Request for Review on a late-filed Form 486 with an incorrect Service Start Date.
    6. Four Requests for Waiver for ministerial and clerical (“M&C”) errors.
    7. Two Requests for Review to correct entity classifications.
    8. One Request for Waiver of the invoice filing deadline for a late USAC decision.
    9. Two Requests for Waiver of the appeal filing deadline for appeals “filed only a few days late or within a reasonable period of time after receiving actual notice of USAC’s adverse decision.”
  3. E-Rate Denied:
    1. One Request for Review and/or Waiver for a competitive bidding violation for which an applicant failed to indicate a need for installment payments in its Form 470.
    2. One Request for Waiver for a late-filed Form 471 application.
    3. One Request for Review for a late-filed Form 486.
    4. Nine Requests for Waiver for late-filed invoice deadline extensions.
  4. Cyber Pilot Denied:
    1. Four Requests for Waiver for late-filed CBR Form 471s, appeals, or waivers.
  5. ECF Granted:
    1. One Request for Waiver granting additional time to respond to USAC for invoicing information.

FCC Universal Service Monitoring Report for 2025:

Last week, the FCC released its annual Universal Service Monitoring Report for 2025 with a host of data on the four Universal Service Fund (“USF”) programs, including E-Rate.  E-Rate tables include:

  • E-Rate Funds - by Service Type, State, and Funding Year
  • Cumulative E-Rate Funds - by Service Type and State
  • E-Rate Disbursements - by Service Provider Type
  • E-Rate Funds per Student - by State
  • E-Rate Funds - by Applicant Type, State, and Funding Year

USAC Cybersecurity Pilot Program Newsletter Dated February 2nd

USAC’s Schools and Libraries Cybersecurity Pilot Program Newsletter dated February 2, 2026, notes the availability of the Pilot FCC Form 488 User Guide.  This  form may be used to request post-commitment changes (e.g., invoice mode) to an applicant’s approved Pilot Form 471.

The Newsletter also provides the following links to USAC’s earlier invoicing webinar and to the user guides for the Pilot Form 472 (for BEAR invoicing) and Form 474 (for SPI invoicing).

* The last paragraph of the previous version of FAQ 1.5a, which conflicted with the second paragraph of FAQ 1.5a, had indicated that the last date to receive services for continuing services would have been three years from the start of services — in our view, a more reasonable restriction.