Funds For Learning® has submitted comments to the Federal Communications Commission (FCC) in response to the proposed Eligible Services List (ESL) for Funding Year 2026. Our filing urges the Commission to take several important steps to streamline the E-rate program and align its rules with current technology and real-world practices in schools and libraries.
For more than 25 years, Funds For Learning has supported E-rate stakeholders nationwide, advocating for policies that promote fair access, efficient administration, and technological neutrality. The 2026 ESL proceeding provides an opportunity to continue that mission.
Our comments highlight four key recommendations:
- Modernize Firewall Definitions.
The FCC should update its firewall eligibility rules to reflect the integrated nature of today’s network security platforms. Schools and libraries should not have to perform complex cost allocations or lose funding because “basic” and “advanced” security functions are bundled together. - Treat Basic Maintenance as a Non-Recurring Service.
Maintenance agreements are purchased as one-time transactions tied to specific equipment. Recognizing them as non-recurring would simplify budgeting and align the program with marketplace norms. - Clarify the Eligibility of DNS, DHCP, and IP Address Management (DDI).
These core network functions are essential to the delivery of broadband and should be explicitly recognized as eligible internal connection services. - Simplify and Streamline Program Categories.
The distinctions between Internal Connections, Managed Internal Broadband Services (MIBS), and Basic Maintenance create unnecessary complexity and confusion. Consolidating these sub-categories into a single Category Two designation would make the program easier to navigate and administer.
These recommendations are aligned with the FCC’s Delete, Delete, Delete initiative, which aims to remove outdated and redundant requirements across Universal Service programs.
Our 2024 E-rate Trends Report shows that nearly 70% of participants describe the current application process as difficult or very difficult. Simplifying the ESL structure would directly respond to that feedback while strengthening confidence in the program’s future.
Funds For Learning will continue to advocate for a modern, equitable, and efficient E-rate program that helps schools and libraries connect their communities securely and reliably.
