Major education and broadband organizations have weighed in on the FCC’s proposed FY2026 Eligible Services List (ESL), calling for clearer guidance on software, managed services, and core network security. Filings from national coalitions, statewide groups, large school districts, and consulting firms reflect several shared priorities.
Broad support for treating software and licenses as Internal Connections
There is strong momentum behind the idea that manufacturer support licenses and software-based services should be classified consistently as Internal Connections (IC). Groups such as the State E-Rate Coordinators’ Alliance (SECA), the SHLB Coalition, Ohio’s Information Technology Centers, and several consulting firms argue that splitting similar licenses between IC and Basic Maintenance of Internal Connections (BMIC) has created confusion and led to unnecessary denials.
SECA highlights multiple examples where the same license was labeled differently on Forms 470 and 471, which caused funding delays or denials. These organizations recommend a single IC classification for all licenses, along with flexibility to allow multi-year prepaid agreements to be funded in the year of purchase.
Discussion shifts toward the future of MIBS and the need for BMIC
Many of the larger contributors support continued funding for Managed Internal Broadband Services (MIBS) and question whether BMIC still serves a distinct purpose. SECA, CSM Consulting, Kellogg & Sovereign, and others recommend transferring BMIC’s remaining work, such as on-site configuration and break/fix activities, into a unified MIBS structure. Hardware and licenses would fall under IC.
Statewide organizations outline the value of MIBS for rural and understaffed districts. SHLB’s filing includes examples from Washington, Indiana, Oregon, and Ohio, showing that MIBS can reduce costs and provide critical support for smaller school systems. One Ohio survey reported average annual savings of about $81,000 for districts using MIBS instead of hiring additional technology personnel.
Ohio ITCs emphasize that MIBS allows for continuous monitoring and preventive maintenance, which contrasts with BMIC’s reactive model. Several commenters also connect MIBS to emerging state cybersecurity expectations that require consistent patching and monitoring.
The Friday Institute at NC State and other education groups describe MIBS as a way to shift operational risk to the managed service provider while giving districts predictable budgets. The comment record includes a chart illustrating steady MIBS growth from 2016 through 2025.
Los Angeles Unified School District underscores the importance of MIBS for maintaining power and uptime across hundreds of campuses. LAUSD warns that narrowing the definition of MIBS could harm large public systems that rely on managed services to reduce classroom disruptions.
Security and DDI functions move to the forefront
Cybersecurity is another prominent theme. LAUSD and others note that modern firewall services rely on advanced inspection and intrusion-prevention capabilities that are difficult to separate from basic firewall functions. They encourage the FCC to recognize these features as essential rather than treating them as ineligible enhancements, at least while the cybersecurity pilot program remains separate.
Infoblox and Funds For Learning both ask the Commission to clarify that core network functions such as DNS, DHCP, and IP address management (collectively known as DDI) should be eligible. These functions may already be funded when bundled with other equipment or Internet access, and commenters argue that making them explicitly eligible would support more vendor-neutral design choices.
Call for simpler forms and clearer service categories
A range of organizations, including statewide coordinators, education research groups, consulting firms, and service providers, call for a simpler Category Two structure. SECA, the Friday Institute, Funds For Learning, and several consulting firms note that the current split between IC, MIBS, and BMIC on the Form 470 often leads to applicant errors. Some recommend consolidating categories for bidding while still collecting necessary detail on the Form 471. Others suggest reducing cost-allocation requirements for mixed-use ports and shared equipment, noting that the five-year Category Two budget already limits potential over-spending.
Funds For Learning’s filing supports reclassifying maintenance agreements as non-recurring, modernizing firewall definitions, explicitly recognizing DDI, and streamlining Category Two services. These recommendations draw on applicant feedback gathered through FFL’s national E-rate Trends Survey. A more detailed summary of FFL’s comments is available separately for readers who want deeper analysis.
What happens next
The Wireline Competition Bureau will now review the record before finalizing the FY2026 ESL, which typically occurs in December. Because the federal government shutdown delayed the schedule, the current deadline for reply comments is December 3, 2025, later than originally planned.
