More is changing in E-Rate right now than at any point in the program's history. Some of it is already final, most of it is still a proposal you can comment on, and the difference between those two categories is everything. This page is the one place to track all of it: every change, its status, who it hits, and what to do about it, with a link to our full deep dive on each topic.
Last updated: August 16, 2026
Latest developments
- May 1, 2026: The FCC adopted the competitive bidding portal order (FCC 26-30). The portal, the end of the Form 486, and the invoicing changes below are now final rules taking effect for funding year 2028.
- June 2026: The adopted portal order added items the circulated draft did not contain, including an entire new Lowest Corresponding Price section. Our draft-vs-adopted comparison walks the differences.
- August 14, 2026: the program review comment clock is running. The E-Rate program review (WC Docket 26-133), with 42 proposals spanning eligible services, discounts, CIPA, consultants, and competitive bidding, was published in the Federal Register. Comments are due October 13, 2026; reply comments are due November 12, 2026. Deep dive: all 42 proposals explained.
- August 14, 2026: The FY2027 Eligible Services List comment cycle closed (reply comments were due this day; initial comments closed July 30). The draft ESL public notice (DA 26-647, WC Docket 13-184) carried its own MIBS and NaaS questions; see change 43. The live path for MIBS comments now is the 26-133 window above.
- Summer 2026: The separate USAC reform proceeding (WC Docket 26-173) proposes extrapolated audit recoveries and pay-and-dispute, both of which reach schools and libraries directly. Deep dive: the 30 USAC reform changes.
What changed at a glance
Final (adopted in FCC 26-30, effective FY2028): the competitive bidding portal, Form 486 eliminated with CIPA moving to the Form 471, parallel state and federal bidding with submissions that must match, a document repository that eases audits, simpler Category One cost allocation, mid-year bandwidth increases, a clean mid-year provider switching path, friendlier invoice deadlines, and modernized definitions. All applicants: schools, libraries, and consortiums.
Proposed (WC Docket 26-133, comments due October 13, 2026): eligible services rollback including special construction and dark fiber, MIBS scrutiny, one-or-no-bid pricing caps, a discount formula review, a possible shift of support toward high-cost and rural areas, a sweeping CIPA modernization (device coverage, network filtering, screen time, age tiers, policy contents, hearings), new consultant rules including an annual form and a percentage-fee ban, the end of the existing-contract shortcut, sworn service substitutions, and full consortium member certifications.
Proposed (WC Docket 26-173, USAC reform): public turnaround-time reporting, AI-assisted reviews, deadline warnings, shot clocks, standardized audits, a possible small-recipient audit exemption, schools and libraries named in the audit rule, recovery by extrapolation, and pay-and-dispute.
Proposed (WC Docket 13-184, FY2027 ESL; window closed, input live via 26-133): MIBS bundling and IT-staffing scrutiny, BMIC-only limits for applicant-owned equipment, and whether NaaS variable pricing should remain ineligible.
The master table: every change at a glance
Status key: ADOPTED = final rule, effective FY2028. PROPOSED = open question, comment window applies. Who: S = schools, L = libraries, C = consortiums.
| # | Change | Status | Who | Do this now | Deep dive |
|---|---|---|---|---|---|
| 1 | Competitive bidding portal becomes the only bid channel | ADOPTED | S, L, C | Plan your FY2028 bid workflow | Portal for applicants |
| 2 | Form 486 eliminated; CIPA certification moves to Form 471 | ADOPTED | S, L, C (C: collect 479s early) | Consortium leads: replan the 479 calendar | CIPA overview |
| 3 | State and federal portal submissions must match | ADOPTED | S, L, C in portal states | Plan parallel, identical uploads | Portal overview |
| 4 | Portal repository holds your bid docs; audits get smoother | ADOPTED | S, L, C | Upload everything once live | E-Rate audits guide |
| 5 | Category One 90% ancillary-use presumption; C2 shared-equipment fix | ADOPTED | S, L, C | Drop unneeded allocation math in FY2028 planning | Category 2 guide |
| 6 | Mid-year bandwidth increases via service substitution | ADOPTED | S, L, C | Know the same-commitment rule | Applicant rules |
| 7 | Clean mid-year provider switching path | ADOPTED | S, L, C | Note the partial-year filing structure | Applicant rules |
| 8 | Invoice deadline relief: late extension requests, refile grace | ADOPTED | S, L, C | Calendar the new windows | Invoicing guide |
| 9 | Shared campus and WAN definitions modernized | ADOPTED | S, L | Check multi-school properties | Eligibility overview |
| 10 | Eligible services rollback: special construction, dark fiber questioned | PROPOSED | S, L, C with fiber plans | Comment if fiber is on your roadmap | All 42 proposals |
| 11 | MIBS (managed Wi-Fi) eligibility and pricing scrutiny | PROPOSED | Small S, L especially | Ask vendors for MIBS vs. internal-connections comparison | All 42 proposals |
| 12 | Pricing caps when you get one or no bids | PROPOSED | S, L, C | Document price reasonableness on single-bid awards | Form 470 guide |
| 13 | Discount formula review (NSLP, urban/rural) | PROPOSED | S, L | Model your budget one band lower | Program review for applicants |
| 14 | Limiting support to high-cost, rural, or single-provider areas | PROPOSED | Urban/suburban S, L | Watch closely; comment with real costs | Program review for applicants |
| 15 | Reversing the on-campus educational-purpose presumption | PROPOSED | S, L | Tighten acceptable-use documentation | All 42 proposals |
| 16 | "Educational purposes" and classroom screen time | PROPOSED | S | Review acceptable-use policy | All 42 proposals |
| 17 | Parental opt-out from screen-based instruction | PROPOSED | S | Watch item; operational lift if adopted | All 42 proposals |
| 18 | Pre-K and Head Start eligibility and cost allocation | PROPOSED | S with pre-K/Head Start | Identify affected sites and students now | Eligibility overview |
| 19 | CIPA extended to your whole network, including personal devices | PROPOSED | S, L | Check network-level filtering capability | CIPA overview |
| 20 | Required network-level filtering, possibly with screen-time limits | PROPOSED | S, L | Favor network-wide filtering at next renewal | CIPA overview |
| 21 | Defining "monitoring" and "unauthorized access" | PROPOSED | S, L | Review internet safety policy language | CIPA overview |
| 22 | Revisiting whether social media is "harmful to minors" | PROPOSED | S, L | Know your current social media stance | CIPA overview |
| 23 | Digital literacy course mandates with completion records | PROPOSED | S | Keep completion records if you already teach it | CIPA overview |
| 24 | A "child" definition and age-tiered filtering | PROPOSED | S | Check per-group policy support in your filter | CIPA overview |
| 25 | Internet safety policy minimum contents, possibly public | PROPOSED | S, L | Rewrite template-only policies in your own words | CIPA overview |
| 26 | Public notice and hearing enforcement, possibly with recovery | PROPOSED | S, L | Keep a documented notice-and-hearing trail | CIPA overview |
| 27 | Annual consultant form (Form 5654), even with no consultant | PROPOSED | S, L, C | Add to your annual calendar if adopted | All 42 proposals |
| 28 | Missed Form 5654 could hold, then reject, your other forms | PROPOSED | S, L, C | Treat as a gating item if adopted | All 42 proposals |
| 29 | Percentage-based consultant fees banned; LOAs and records required | PROPOSED | S, L, C using consultants | Review your consultant fee structure now | All 42 proposals |
| 30 | End of the existing-contract (Kalamazoo) option | PROPOSED | S, L, C | Never sign before the ACD, starting now | Form 470 guide |
| 31 | Service substitutions in writing, sworn, pre-approved | PROPOSED | S, L, C | Build in approval lead time | Applicant rules |
| 32 | Consortium members certify the full Form 471 set in EPC | PROPOSED | C and every member | Leads: plan early member certification | Program review for applicants |
| 33 | All form certifications written into the rules | PROPOSED | S, L, C | Make sure signers understand what they certify | Applicant rules |
| 34 | USAC publicly reports turnaround times | PROPOSED | S, L, C (helps) | None; visibility win | USAC reform: 30 changes |
| 35 | AI-assisted application, audit, and appeal review | PROPOSED | S, L, C | Watch item | USAC reform: 30 changes |
| 36 | USAC warns you before filing deadlines | PROPOSED | S, L, C (helps, with caveat) | Keep owning your own calendar | E-Rate deadlines |
| 37 | Shot clocks on USAC processes | PROPOSED | S, L, C (helps) | Comment with specific delay stories | USAC reform: 30 changes |
| 38 | Standardized audit and letter processes across USF programs | PROPOSED | S, L, C | None yet | E-Rate audits guide |
| 39 | Possible audit exemption for small recipients (de minimis) | PROPOSED | Small S, L | Comment: ask for applicant-inclusive language | USAC reform: 30 changes |
| 40 | Schools and libraries written into the audit rule by name | PROPOSED | S, L, C | Understand the pairing with change 41 | USAC reform: 30 changes |
| 41 | Audit recoveries by extrapolation from a sample | PROPOSED | S, L, C | Comment on the undefined projection base | USAC reform: 30 changes |
| 42 | Pay recoveries while you appeal (pay-and-dispute) | PROPOSED | S, L, C | Model the cash impact of open disputes | USAC reform: 30 changes |
| 43 | FY2027 ESL: MIBS limits, BMIC-only, NaaS variable pricing | PROPOSED | S, L (small especially) | ESL window closed; file via 26-133 by Oct 13 | Eligibility overview |
Section A: Final rules, effective FY2028 (FCC 26-30)
The FCC adopted the competitive bidding portal order on May 1, 2026. These nine changes are done. They are not up for comment, and they take effect beginning funding year 2028. Full applicant-side breakdown: the bidding portal for applicants.
1. The competitive bidding portal becomes the only bid channel ADOPTED
Starting FY2028, bids on your Form 470 arrive through a USAC-managed portal, and you will not be permitted to consider bids received outside it. The portal brings structure to bid intake: spam and no-pricing bids can be disqualified as non-responsive, and duplicates only need to be disqualified once.
What it means for you. Your bid evaluation process gets a defined home and cleaner inputs. Between now and FY2028, the job is learning the workflow, not changing your current-year filings. Deep dive: applicant portal guide, general portal overview.
2. The Form 486 is gone, and CIPA moves to the Form 471 ADOPTED
A genuine simplification. The FCC found the "services started" notice duplicative and removed the Form 486 requirement "beginning in funding year 2028," transferring the remaining CIPA certifications to the Form 471 (FCC 26-30, para. 57). One less form, one less deadline to blow.
The consortium catch. Because CIPA now rides on the Form 471, consortium leads must collect members' Form 479 CIPA certifications before certifying the 471, not later in the year. The FCC acknowledged "this will be a shift in the filing procedures of consortia" and told leads to start planning before the FY2028 window (para. 60). If you lead a consortium, this is your biggest calendar change in the adopted order.
Action item: consortium leads, move Form 479 collection into your pre-471 window planning now. Deep dive: CIPA overview.
3. Your state or local portal is not going away, and submissions must match ADOPTED
This is the one that catches people off guard. The federal portal sits on top of state and local bidding requirements, not in place of them (new 47 CFR 54.503(b)). You run both, with parallel uploads. And the FCC clarified that submitting different information to a state portal than to the federal portal "may be treated as a competitive bidding violation and the E-Rate funding requests could be subject to denial" (para. 25).
What it means for you. If your state or district has its own bidding system, build one procurement package and submit it identically to both. A version mismatch is now a funding risk, not a clerical wrinkle.
4. The portal repository makes audits smoother ADOPTED
Because your competitive bidding documents live in the portal, you "no longer need to separately retain documentation uploaded to the portal," and USAC pulls what it needs directly "instead of through document requests" (para. 19). The portal also keeps an audit log recording who accessed each bid, when, and from what IP address (para. 31), which helps you prove compliance with state sealed-bid or fixed-open-time rules.
What it means for you. Future audits and PIA reviews should involve less digging through old files and fewer "please send us this" letters, because USAC reviews records it already holds. Everything outside the portal still follows normal retention rules. Deep dives: E-Rate audits, PIA reviews.
5. Cost allocation got simpler ADOPTED
Two real wins. First, Category One: if at least 90 percent of a recurring Category One service is used for an eligible purpose, the rest is presumed ancillary and "cost allocation will not be required" (para. 49). This now covers all recurring Category One services, not just internet access. The hard line: off-campus use is not ancillary and still must be allocated out (para. 50). Second, Category Two: shared equipment such as a district switch no longer needs cost allocation for a non-instructional facility's use, as long as you chose the most cost-effective option without regard to that facility (para. 75, Order on Reconsideration, amending 54.502(d)(6)).
What it means for you. Less allocation math on your FY2028 applications, especially for districts with NIFs and libraries with mixed-use connectivity. Deep dive: Category 2 guide.
6. You can raise bandwidth mid-year ADOPTED
A limited exception to the bidding rules lets you increase bandwidth during the funding year through a service substitution at your existing commitment amount; you cover any price difference yourself and rebid the higher tier through a new Form 470 next cycle (para. 51).
What it means for you. When enrollment or usage outruns the pipe you bought, you no longer wait out the year. The support number stays flat, but the connectivity problem gets fixed.
7. Switching providers mid-year finally has a clean path ADOPTED
Applicants transitioning services file partial-year funding requests for both the old and new service, flag the transition on the Form 471, and file a post-commitment request once real cutover dates are known, "which USAC will be permitted to grant even if the date change results in a higher funding commitment" (para. 44).
What it means for you. If a provider relationship goes bad mid-year, you have a documented exit process instead of a funding-year hostage situation.
8. Invoicing got more forgiving ADOPTED
Three linked changes. You can request the single 120-day invoice extension up to 15 days after the deadline, not just before it (para. 64). A timely invoice that USAC rejects gets a one-time 60-day grace window to refile corrected, instead of forcing an appeal (para. 67). And the deadline itself is now the latest of four dates written into 47 CFR 54.514(a), covering service end, the FCDL, a revised FCDL after appeal, or a first rejection notice.
What it means for you. Honest slips stop being fatal. But the relief has edges: it is still a single 120-day extension, and anything beyond it needs a Commission waiver under the strict standard the FCC kept in place (para. 66). Treat the new windows as a safety net, not a schedule. Deep dives: invoicing guide, deadlines guide.
9. Definitions caught up with reality ADOPTED
Multiple schools on the same property can now share a single school campus, which helps with Category Two budgets and cabling between buildings, and "voice" was removed from the wide area network definition since voice is no longer eligible (para. 72).
What it means for you. If you have co-located schools, revisit how you define campuses before FY2028. Deep dive: eligibility overview.
Section B: Proposed in the E-Rate program review (WC Docket 26-133)
Everything in this section is a proposal or an open question, not a rule. The comment window is your lever. Full catalog: all 42 proposals in WC Docket 26-133, and the draft-vs-adopted comparison for how this proceeding has already shifted.
Program scope and funding
10. Which eligible services still fit, including special construction and dark fiber PROPOSED
What is proposed. A line-by-line reconsideration of what E-Rate funds, asking whether currently eligible services are "no longer necessary or ... inconsistent with the statute," and specifically whether special construction, self-provisioned networks, and dark fiber remain justified given BEAD and today's connectivity rates. Options floated: limit special construction to single-provider areas, require disclosure of other funding sources, or eliminate it entirely (para. 14).
Why the FCC says it is proposing this. The eligible services list "has expanded significantly since its inception," the program "has been subject to recent criticism for such expansion" (bus Wi-Fi and hotspots were already reversed in 2025), and the Commission cites "ongoing concerns about facilitating subsidized overbuilding and distorting competitive markets."
What it means for you. Nothing changes today. But if a service comes off the list, new requests would be denied going forward; existing multi-year contracts are typically honored to term, but renewals would not be funded. Special construction has been eligible since FY2016 and totals only about $136.6 million in disbursements, which is partly why it is an easy "does this still fit" candidate. If a fiber build is on your multi-year roadmap, document now why E-Rate rather than BEAD is the right funding fit, and say so in a comment.
11. MIBS (managed Wi-Fi): eligibility and cost under the microscope PROPOSED
What is proposed. The FCC questions how to ensure MIBS contracts are cost-effective "and whether it should continue to be a supported service," floating hours-based reimbursement with tickets attached to invoices, required comparisons against straight internal-connections bids, or limiting MIBS eligibility by school or library size (para. 73).
Why the FCC says it is proposing this. It is "concerned about the ability to review the cost effectiveness" of MIBS contracts, including providers "offering contracts at rates that exceed the value of the network itself."
What it means for you. MIBS is common for smaller districts and libraries without in-house IT, and those are the applicants most likely to keep it under a size-based limit. Either way, expect to justify a MIBS choice against an internal-connections alternative, so start asking vendors for an apples-to-apples comparison now. The Bureau's FY2027 ESL public notice stacks further questions on top of these, including BMIC-only limits and NaaS pricing: see change 43.
12. Pricing caps when you receive one or no bids PROPOSED
What is proposed. Where a Form 470 draws one bid or none, the FCC asks whether to cap reseller reimbursement "at or near the underlying carrier or manufacturer cost," require the applicant to justify or absorb the markup, or build reimbursement caps from USAC Open Data pricing by geography (para. 72).
Why the FCC says it is proposing this. With limited competition, "E-Rate support does not reflect market-based pricing" risk rises and existing safeguards weaken.
What it means for you. When you get a single bid, keep documentation showing the price is reasonable: vendor quotes, published list prices, comparable pricing. The burden of proving cost-effectiveness could shift toward you, and "most cost-effective" is headed for closer scrutiny. Deep dive: Form 470 guide.
13. Is the discount formula still right? PROPOSED
What is proposed. A review of whether NSLP eligibility plus urban/rural status remains the right way to set your 20 to 90 percent discount, including whether to phase out funding for areas with the lowest NSLP participation (para. 17).
Why the FCC says it is proposing this. It asks whether the current approach "allocate[s] funds fairly, efficiently" or whether "a disproportionate share of funding flow[s] to large, well-resourced school districts with substantial local tax bases."
What it means for you. If the matrix is retuned, discounts most likely move down for higher-income and urban applicants. Model your budget one band lower so a change cannot blindside your local share, and keep your NSLP and poverty data current. Deep dive: program review for applicants.
14. Limiting support to high-cost, rural, or single-provider areas PROPOSED
What is proposed. Whether E-Rate support should be limited to areas where applicants face the highest costs, "to rural areas or to areas served by a single provider" (para. 18).
Why the FCC says it is proposing this. Broadband prices are generally falling but remain "demonstrably higher in less competitive areas and those that lack competition entirely."
What it means for you. If you are a well-served urban or suburban applicant, this is among the most consequential ideas in the whole proceeding for your funding. Track it, and if your real costs tell a different story than the premise, put those costs in a comment.
15. Reversing the on-campus educational-purpose presumption PROPOSED
What is proposed. Today, activity on school or library property is legally presumed educational and thus eligible. The FCC asks "whether this presumption should be reversed" (para. 15).
What it means for you. If reversed, you may need to affirmatively show a given use is educational rather than assume it. That means tighter acceptable-use documentation and readiness to defend how funded services are actually used.
CIPA, child safety, and screen time
Step back from the individual questions and the theme is unmistakable: CIPA is the centerpiece of this proceeding. The draft pokes at nearly every part of the rule at once: covered devices, filtering, screen time, social media, age tiers, policy contents, hearings, and monitoring. The FCC frames all of it as updating CIPA for a world of 1:1 devices and personal phones. Our foundation guide: CIPA overview.
16. Does classroom screen time count as an "educational purpose"? PROPOSED
What is proposed. The FCC asks whether uses like screen time to "calm or reward students" fit the required certification that services are used "primarily for educational purposes," what schools are doing to limit screen time, and whether school and library standards should differ (para. 20).
Why the FCC says it is proposing this. Children's screen time "often exceeds the recommendations of experts" and can include content that is not "integral, immediate, and proximate" to education.
What it means for you. If "educational purposes" tightens, devices-as-reward and open browsing could draw scrutiny. Tightening your acceptable-use policy and keeping basic usage records now is cheap insurance.
17. A parental opt-out from screen-based instruction, as a funding condition PROPOSED
What is proposed. Whether receiving E-Rate support should require schools to give parents "a meaningful opportunity to opt their children out of screen-based instruction," and whether the FCC even has legal authority to require it (para. 21).
What it means for you. If adopted, this is an operational lift, not a form: board policy, an opt-out workflow, and non-screen alternatives for those students. Watch item; nothing to build today.
18. Pre-K and Head Start eligibility and cost allocation PROPOSED
What is proposed. Whether pre-K and Head Start students should keep receiving support, whether schools must cost-allocate them out of funding requests, or whether eligibility should be limited to programs that are part of a public school or district, as several states already do (para. 23).
What it means for you. Allocation would shrink the discount base and add math; a public-school-only limit could remove non-public pre-K and Head Start programs entirely. Identify now whether any funded sites or students fall in this category.
19. CIPA could extend from your computers to your whole network PROPOSED
What is proposed. The FCC currently reads CIPA as covering school- or library-owned devices. It asks whether Congress intended that a third-party device on the same E-Rate network "need not protect minors," whether to read the statute to cover any device accessing the internet through a supported network, and even whether schools should block third-party devices from E-Rate networks altogether (paras. 25-26).
What it means for you. This is the big one. Network-wide CIPA means filtering student and staff personal phones and laptops, which in practice means network-level or DNS filtering, captive-portal or device-posture controls, and updated policies. Nothing to change today, but this is the item most worth a comment, and worth confirming whether your current filter can enforce at the network level.
20. Required network-level filtering, possibly with screen-time limits PROPOSED
What is proposed. Whether technology protection measures should be required to filter "at the network level," applying to any device that connects, and whether such filtering should "include limits on screen time" (para. 27).
What it means for you. Device-by-device filtering may no longer be enough. When your filtering contract next renews, favor a solution that works network-wide and supports time controls.
21. Defining "monitoring" and "unauthorized access" PROPOSED
What is proposed. The FCC asks what "monitoring the online activities of minors" means, whether "unauthorized access" covers material without educational purpose (students scrolling social media instead of researching), and even whether exceeding a policy's "prescribed number of hours" could count (para. 28).
What it means for you. Definitions turn soft expectations into auditable requirements, and a time-based reading of "unauthorized access" is another path to enforceable screen-time limits. If these get defined, your internet safety policy needs explicit monitoring language. Raise privacy concerns in a comment if you have them.
22. Is social media "harmful to minors"? PROPOSED
What is proposed. The Commission determined in 2011 that social networking sites are not per se harmful to minors under CIPA. It now asks whether to revisit that conclusion in light of changes since 2011 and newer research (para. 29).
What it means for you. A reversal could make blocking specified platforms a funding condition. Many schools already restrict social media; if yours does not, be ready to.
23. Digital literacy mandates with completion records PROPOSED
What is proposed. Whether required digital and media literacy courses would help, and whether schools should have to produce documentation showing students "attended and completed the courses" (para. 30).
What it means for you. If you already teach digital citizenship, you are most of the way there. Keep completion records and consider the student-privacy implications of producing them.
24. A "child" definition and age-tiered protections PROPOSED
What is proposed. CIPA defines "minor" as under 17, and most districts run one filter district-wide. The FCC asks whether to adopt a separate "child" definition, possibly COPPA's under-13, with "heightened online safety requirements for younger children" (para. 31).
What it means for you. Age tiers would turn one filter into several profiles mapped to grade bands, which requires a filter or MDM with per-group policy, a student information system feeding grade data into it, and answers for shared devices, mixed-grade buildings, and BYOD. If your filter cannot do per-group policy, that is worth knowing now, and worth a comment.
25. Internet safety policy: minimum contents, possibly public PROPOSED
What is proposed. The FCC questions "the adequacy of these frequently used template policies," whether they meet CIPA's statutory bar, and whether to expand required policy contents (para. 34).
What it means for you. This is the most actionable CIPA item because it is squarely in your control. A template policy nobody has reopened in years is the exposure. Make sure yours addresses every CIPA element in your own words and reads like something you would be comfortable posting publicly.
26. Public notice and hearings: the quiet gap gets teeth PROPOSED
What is proposed. Whether USAC should reduce commitments or recover disbursed funding when an applicant "failed to provide the required public notice and/or hold a public hearing," and whether any CIPA violation should be curable (para. 36).
What it means for you. The missed public hearing is the most common quiet compliance gap in CIPA. If recovery becomes the penalty, a paperwork miss puts dollars at risk. Keep a documented notice-and-hearing trail for every adoption or amendment of your policy.
Watch item: the FCC also asks whether it has authority beyond CIPA to set per-day screen-time hour caps (paras. 38-41). Treat that as a watch item, not a near-term build.
Consultant rules
27. A new annual consultant form (Form 5654), even if you have no consultant PROPOSED
What is proposed. Every applicant and service provider would submit an annual consultant certification and disclosure form completed by each consultant; those who use no consultant "would also be required to submit this form and certify to not having used a consultant" (para. 48).
What it means for you. If adopted, Form 5654 joins the 470 and 471 on your annual calendar, every year, consultant or not. Nothing to file yet; just know it is coming.
28. Miss the 5654 and your other forms could freeze PROPOSED
What is proposed. USAC would "hold any E-Rate-related FCC form(s) under review" until the 5654 is filed, and reject pending forms if it is not timely submitted (para. 51).
What it means for you. A forgotten administrative form could sink a whole year's applications. If this passes, the 5654 becomes a gating item on par with the filing window itself.
29. No percentage-based consultant fees; LOAs and payment records required PROPOSED
What is proposed. A strict prohibition on consultant fee arrangements "based on a percentage" of E-Rate contracts or disbursements (para. 59), plus required letters of agency submitted with the 5654 and retention of LOAs, fee agreements, and banking records showing consultant payments (para. 60). A consultant registration database with per-person CRNs and annual anti-fraud training applies to consultants themselves (paras. 53-58) but shapes who you can hire.
What it means for you. If your consultant is paid a percentage of your award, that model would be prohibited; you would move to flat or hourly and update the contract and LOA. Even though these rules target consultants, you hold and produce the paper. A simple per-funding-year consultant file, signed LOA, fee agreement, payment records, makes an audit a non-event.
Competitive bidding and contracts
The through line: the FCC wants a clean, well-documented bidding process and a clear cost justification for what you chose. Your bid evaluation, your "most cost-effective" decision, and the paper trail behind them are headed for closer review.
30. The end of the existing-contract (Kalamazoo) option PROPOSED
What is proposed. All contracts would have to be signed after the allowable contract date, 28 days after the Form 470 posts. Applicants "would no longer be able to request support for equipment and/or services under an existing contract that was not competitively bid" under the 2002 Kalamazoo Order on Reconsideration (para. 62). The FCC asks whether state master contracts need a carve-out (para. 64).
What it means for you. This changes a real workflow: no more locking in a contract first and papering it through a 470. The safe practice, starting now, is to never sign or date a contract until your 470 has run its 28 days and you have evaluated bids. If you rely on state master contracts, the carve-out question is your comment to file. Deep dive: Form 470 guide.
31. Service substitutions: in writing, sworn, pre-approved PROPOSED
What is proposed. Substitutions must be written, certified under penalty of perjury by an authorized person, and approved by USAC "prior to reimbursement being made" (para. 65). The FCC itself says this "should not result in a large difference" for most applicants; the goal is monitoring costs and discouraging undisclosed swaps.
What it means for you. Build in lead time, and do not deploy a substituted product expecting payment before USAC's written approval lands.
Forms and consortiums
32. Consortium members would certify the full Form 471 set in EPC PROPOSED
What is proposed. The Form 479, which members currently use only for CIPA, would carry the Form 471's certification statements, and members would submit it in EPC before the lead certifies the 471. The FCC's stated reason: when a member breaks a rule, "the consortium lead that made the certification may not be the appropriate party from whom to recover the funding" (para. 68).
What it means for you. Members become directly accountable for their own compliance instead of leaning on the lead, and leads need member certifications completed early in the window. If you are a consortium lead, this plus the adopted Form 479 timing change (change 2) means your member-wrangling calendar is changing twice. Plan for both at once.
33. Every form certification written into the rules PROPOSED
What is proposed. All certification statements on Forms 470, 471, 472, 473, and 474 would be incorporated into the Commission's rules, "without imposing any new or substantive obligations" (para. 70).
What it means for you. Housekeeping, but with a sharpened edge: once the rules spell out exactly what you certify, "I did not know" gets weaker. Make sure whoever signs your forms actually understands them. The Appendix A rule text also adds a new consultant definition (54.500), the ACD contract rule (54.503(c)), the perjury-certified substitution rule (54.504(d)), the new consortium certification rule (54.504(h)), and consultant records in the retention rule (54.516(a), 54.517).
Section C: Proposed in the USAC reform proceeding (WC Docket 26-173)
A separate proceeding, aimed at USAC itself, with nine items that reach applicants. Some genuinely help; two carry real financial teeth. Full breakdown of all 30 changes: the USAC reform NPRM explained.
For context on the audit frustration driving this proceeding: comments in the record describe audits lasting three years, a 14-cent finding that cost nearly $150,000 to defend, and documentation requests reaching back to 1995. Hold both truths: the frustration is real and documented, and the GAO found in 2024 that USAC's practices comply with FCC requirements.
34. USAC would publicly report turnaround times PROPOSED
The FCC proposes requiring USAC "to publicly report turnaround times or other metrics regarding responsiveness" (FCC-CIRC2608-02, para. 14). Not binding on any single application, but visible, and visibility changes behavior. A win for applicants waiting on funding decisions.
35. AI to speed reviews PROPOSED
The FCC repeatedly asks whether AI tools could reduce delays in application, audit, and appeal review "while maintaining accurate results" (paras. 13, 17, 30). Watch item: faster reviews would be welcome; accuracy is the open question.
36. USAC warns you before a deadline PROPOSED
USAC would monitor filing deadlines and contact parties "prior to the deadlines" (para. 14). The caveat lives in footnote 25: "a lack of notice from USAC will not excuse or cure a failure to timely file." Helpful backstop; still your deadline. Keep your own calendar. Deep dive: E-Rate deadlines.
37. Shot clocks on USAC processes PROPOSED
Hard deadlines for USAC processes, modeled on the FCC's 180-day merger clock (paras. 15-16). The carve-out to watch: a clock might apply only to "workable" applications, skipping ones waiting on more information, which are usually the slow ones. If USAC delay has cost you, comment with specifics: which process, how long, what it cost you.
38. Standardized audits and letters across programs PROPOSED
Every USF program audits and writes recovery and appeal letters differently; the FCC asks whether to make the processes uniform (para. 21). Low drama, mildly helpful. Deep dive: E-Rate audits guide.
39. A possible audit exemption for small recipients PROPOSED
A de minimis exemption from random audits for recipients under a dollar threshold (para. 22). Three cautions from our full analysis: it is a dollar threshold, not a risk model; it touches random audits only, with PQA carved out; and the paragraph twice slips into "carrier" language, so schools and libraries may not even be in view. If you are a small applicant who wants this, your comment should say explicitly that the exemption must name beneficiaries, not just carriers.
40. Schools and libraries written into the audit rule by name PROPOSED
Section 54.707 currently names only "contributors and carriers." The proposal adds beneficiaries, "including participating schools, libraries, and health care providers," to USAC's audit authority (para. 23, Appendix B). It is codification rather than new power, since beneficiaries can already be audited under other rules. It matters because it is the same rule about to gain a sharper recovery tool in change 41.
41. Audit recoveries by extrapolation PROPOSED
Today USAC recovers what it actually finds. Under this proposal, USAC could review a statistically valid sample (95 percent confidence, 5 percent margin of error), find an error rate, and project it across the disbursements at issue in the audit (paras. 24-26, proposed 54.707(d)). Same audit, potentially much larger recovery.
Three things belong in applicant comments. First, the projection base is undefined: the rule text says "disbursements at issue in the audit," while the narrative describes the whole population of claims by the auditee; one reads like a single Form 471, the other like everything you have ever claimed. Second, the proposed guardrails, reviewing and challenging the sampling method and proving the error rate does not hold outside the sample, are open questions (para. 25). Third, the FCC itself asks whether extrapolation even fits E-Rate, where every funding request runs through its own competitive bid (para. 26). No USF program sizes recoveries by extrapolation today. This is the crux of the proceeding for your audit risk.
42. Pay-and-dispute: pay the recovery while you appeal PROPOSED
Today in E-Rate, filing an appeal pauses a recovery. Under this proposal, once a Bureau or Commission-level decision upholds it, you pay while any further appeal is pending, with a refund if you win (para. 28). Be precise: this relocates cash from your district or library to the Fund during a dispute you may still win. The limiter: USAC's initial audit finding still gets a stay; the payment obligation starts only after a Bureau or Commission-level decision. Model the cash impact of any open dispute now, and if the number would hurt, that number belongs in a comment.
Section D: Proposed in the FY2027 ESL proceeding (WC Docket 13-184)
One more proceeding, narrow but pointed. On June 30, 2026, the Wireline Competition Bureau released the draft FY2027 Eligible Services List (DA 26-647). It proposes no other changes to the list, but it adds a MIBS and NaaS question set that goes beyond the program review's. Its comment window has closed (comments July 30, 2026; replies August 14, 2026); the Bureau encouraged MIBS comments in both dockets, so the live lane for this input is WC Docket 26-133, due October 13, 2026.
43. MIBS limits, BMIC-only maintenance, and NaaS variable pricing PROPOSED
What is proposed. Beyond the program review's MIBS questions (change 11), the Bureau asks how to keep MIBS from functioning as outsourced IT staffing (staffing costs are ineligible), how to keep ineligible services and equipment out of MIBS bundles, whether an applicant that owns its equipment should be limited to basic maintenance (BMIC) instead of MIBS, and whether MIBS should be made ineligible or limited by school and library size. It also takes up NaaS: today the Form 471 assumes a fixed monthly cost even for burstable service, and the Bureau asks whether variable-priced services should "remain ineligible" or whether the Forms 470 and 471 should be modified to accommodate them.
The Bureau's direct statements (DA 26-647, the Bureau's own words):
"In addition to these questions, we also seek comment on how to limit MIBS to ensure it is cost-effective for both the applicant and the E-Rate program. For example, how do we prevent MIBS from being used to augment a school's or library's information technology department or team when a school's or library's staffing costs are ineligible for E-Rate support? How can we ensure ineligible services and equipment are not being bundled with a MIBS service? ... If an applicant owns the internal connections, should the applicant be limited to seeking only basic maintenance of internal connections (BMIC) instead of MIBS for its owned equipment? Given our concerns about the cost-effectiveness of MIBS and ensuring only eligible services and equipment are funded, should the Commission make MIBS ineligible for E-Rate support or otherwise limit support to certain sized schools and libraries? We encourage commenters to file comments related to MIBS in both proceedings under WC Docket Nos. 26-133 and 13-184."
And on NaaS:
"While the FCC Form 471 permits applicants to indicate that a service is burstable, the cost of the service is fixed and the FCC Form 471 does not collect information to request variable amounts of bandwidth for each month and at different prices. We seek comment on whether or how the FCC Forms 470 and 471 could be modified to account for monthly variable services and pricing. ... Should services with variable costs, like NaaS, remain ineligible given the heavy administrative burdens associated with funding this type of services?"
What it means for you. If you own your equipment, a BMIC-only rule would change what you can request. If you buy managed Wi-Fi, expect bundling scrutiny and be ready to show your MIBS contract funds the network, not staff. And if a vendor has pitched you NaaS or usage-based pricing, know that it is not fundable today, and this question set decides whether that changes. The ESL window has closed, so put this input in your WC Docket 26-133 comments, due October 13, 2026.
Your applicant action checklist
Before FY2028 (adopted rules):
- Learn the portal workflow; read our applicant portal guide.
- Consortium leads: rebuild your Form 479 collection calendar so certs land before the 471.
- If a state or local portal applies, plan one identical package for both systems.
- Recheck campus definitions if you have multiple schools on one property.
- Update your invoicing calendar with the latest-of-four deadline and the 15-day extension window.
This comment season (proposed rules):
- Start a CIPA evidence file: your policy in your own words, notice and hearing proof, filter configuration, monitoring practices, and any digital-literacy completion records.
- Review your consultant arrangement; if it is percentage-based, plan the move to flat or hourly.
- Stop signing contracts before the 28-day ACD, even though the rule is not final.
- Document price reasonableness on any one-bid award.
- Identify pre-K and Head Start exposure in your funding requests.
- Model your budget one discount band lower.
- File comments on the items that hit your roadmap: the extrapolation base, CIPA network coverage, special construction, and the discount formula are where applicant voices matter most.
How to comment
Comments are filed in the FCC's Electronic Comment Filing System (ECFS) under the docket number: WC Docket No. 26-133 for the E-Rate program review items (changes 10 through 33) and WC Docket No. 26-173 for the USAC reform items (changes 34 through 42). The ESL questions (change 43) live in WC Docket 13-184, whose window has closed; the Bureau invited MIBS comments in both dockets, so fold that input into your 26-133 filing.
The 26-133 window is live now. The program review was published in the Federal Register on August 14, 2026: comments are due October 13, 2026, and reply comments are due November 12, 2026. The USAC reform deadlines are set by that item's own Federal Register publication; check the current dates before you write. See our program review coverage for how the 26-133 proceeding has run so far. You do not need a lawyer to file. Specific beats eloquent: what the proposal changes for your district or library, with numbers.
Our take
Two opinions, clearly labeled as ours and kept separate from the sourced summaries above.
On CIPA: compliance is going up, and documentation is everything. Across this proceeding the FCC is moving one direction on CIPA: more obligations, more enforcement. We do not see a version of this where CIPA gets easier. The most exposed applicants are the ones treating CIPA as a one-time checkbox with a template policy nobody has reopened. The single most valuable move, no rule change required: start a CIPA evidence file now and keep it current. It is exactly what an auditor, or a tougher future rule, would ask for.
On the bigger question: is E-Rate going away? We do not think so. Three reasons. The FCC just invested in E-Rate's future, adopting the bidding portal on May 1, 2026, weeks before the program review draft that leans on it. The concrete proposals strengthen the program: consultant registration, anti-fraud training, fee bans, codified certifications are program-integrity upgrades, not wind-down moves. And the "sunset" line is a question among dozens, not a proposed rule; demand remains strong at roughly $3.2 billion in FY2025 requests, and the cap was just raised for inflation. Our read: this is modernization of a program that achieved its original mission. Keep filing as normal, tighten your documentation, and comment where your roadmap is at stake.
FAQ
Which E-Rate changes are final and which are proposed?
The competitive bidding portal order (FCC 26-30) is final: the portal, Form 486 elimination, cost allocation simplifications, mid-year flexibility, and invoicing relief, all effective FY2028. Everything in the E-Rate program review (WC Docket 26-133) and the USAC reform proceeding (WC Docket 26-173) is proposed and open to comment. The FY2027 ESL public notice's MIBS and NaaS questions (WC Docket 13-184) are also proposals; that window has closed, with the live path for input running through 26-133.
When does the E-Rate competitive bidding portal start?
Funding year 2028. Bids on your Form 470 will then come through the USAC-managed portal, and bids received outside it cannot be considered.
Is the Form 486 going away?
Yes. Beginning funding year 2028 the Form 486 is eliminated, and its CIPA certification moves onto the Form 471. Consortium leads will need members' Form 479 certifications before certifying the 471.
Do these changes affect library E-Rate funding?
Yes. Libraries are covered by nearly every item here, and several hit libraries directly: the on-premises ancillary-use presumption is limited to on-premises use even where library Wi-Fi reaches into the community, MIBS limits would touch small libraries that outsource network management, and the CIPA questions apply to libraries as well as schools.
What changes for E-Rate consortiums specifically?
Two calendar changes: the adopted rule requires leads to collect Form 479s before certifying the Form 471 starting FY2028, and a proposal would have every member certify the full Form 471 certification set in EPC before the lead files. Members would become directly accountable for their own compliance.
How do schools and libraries comment on FCC E-Rate proposals?
File in the FCC's ECFS under WC Docket 26-133 (program review) or WC Docket 26-173 (USAC reform) before the deadline set by Federal Register publication. Concrete local impact, with numbers, is what moves the record.
Could my E-Rate discount rate change?
Possibly. The FCC is reviewing whether NSLP data and urban/rural status should keep setting the 20 to 90 percent discount matrix, including whether to phase down support where NSLP participation is lowest. It is a proposal, not a rule; prudent applicants are modeling budgets one band lower.
Is the E-Rate program going away?
We do not think so. The FCC just built new E-Rate infrastructure, the concrete proposals are integrity upgrades rather than wind-down steps, and the sunset language is one question among dozens with no proposed rule behind it. See "Our take" above.