If your application is still in Program Integrity Assurance review, your contract dates are one of the first things worth checking. And if you are looking ahead to Funding Year 2027, the time to get your dates right is before you post your Form 470, not after USAC asks. The Funding Year 2025 decision data shows why.
Across Funding Year 2025 decisions issued so far, the Universal Service Administrative Company (USAC) has corrected the Contract Award Date on 1,345 Funding Request Numbers (FRNs). That is roughly 1 in every 43 funding requests decided to date, based on data tracked in E-rate Manager®. With about 6.5% of Funding Year 2025 funding requests still in review, that count will keep climbing. Even if your application looks routine, your contract dates are getting reviewed.
When the dates do not hold up, the consequences scale fast. 2,815 FRNs have been fully denied in Funding Year 2025 to date. A meaningful share of those denials trace back to two specific contract date issues: how your bidding process was sequenced, and whether your contract dates align with the funding year you requested.
The contract date is the paper trail that proves you followed competitive bidding rules, requested discounts for the right funding year, and received services inside the eligible window. When that date is off, USAC has reason to question everything around it.
Here are the two places contract dates do the heavy lifting on your application, and where Funding Year 2025 data shows the most funding is at risk.
1. Competitive Bidding (Form 470) Sequencing
If your contract dates are going to cost you funding, this is where it is most likely to happen.
In the decisions issued so far, 251 FRNs have been flagged for competitive bidding violations. Almost none of them were funded. The denial rate on those FRNs was 97.6%. If your competitive bidding has a flaw, your funding is almost certainly at risk.
Failure modes drove most of those denials:
- 28-day waiting period violations. 13 FRNs denied. The Form 470 has to be posted for a full 28 days before any contract activity can move forward. That includes evaluating bids, signing a contract, or otherwise locking in a vendor. All of these inside the window violate program rules.
- No contract in place at Form 471 certification. 14 FRNs denied. If you certify before a legally binding agreement is in place, hoping to fix it later, you cannot.
The fix is sequencing. Post the Form 470, wait the full 28 days, evaluate bids, sign the contract, and then certify the Form 471. In that order, every time. If your application is still in review, confirm now that your contract was signed after the 28-day window closed and is fully executed in your files. Catching an issue before USAC does gives you room to respond.
2. Contract Date Alignment with the Funding Year
Your contract dates should cover the full funding year. When they do not, USAC adjusts the Service Start Date, and your funding shifts with it.
So far, 59 FRNs have had Service Start Date changes tied to dates not aligning with the funding year. Most of these are not denials. They are adjustments that change what gets funded and when, and you may not realize anything has shifted until your commitment letter arrives.
The most common alignment problem is a contract dated for the wrong funding year, or a service start date that pulls eligible expenses outside the program year window. Schools and libraries typically work in fiscal year terms, while E-rate works in Funding Year terms. These are not the same dates, and they get misinterpreted often. If your commitment letter does not match what you filed, a Service Start Date adjustment is one of the first things to look for. And before you sign a contract for Funding Year 2027, confirm the dates align with the funding year you will request.
Whether You Are in Review Now or Preparing for Funding Year 2027, Check These Two Things
- Your Form 470 and contract sequencing. Was the contract signed after the full 28-day window closed? Is it fully executed and in your files?
- Your contract dates and service start date. Do they fall inside the funding year you are requesting? If your commitment letter shows an adjustment, this is where to look.
If your application is still in Program Integrity Assurance review, catching an issue now gives you room to respond before USAC does. And if you are looking ahead to Funding Year 2027, the date decisions you make over the next few months determine whether your application sits in this same data next year.
Whether you are in review now or planning for Funding Year 2027, contract dates are not the place to guess. Schedule a consultation to see what working with a Guide could look like for you.
About the Author: Todd has spent the last 15 years helping schools and libraries get the E-rate funding they need to keep students connected. He got into the work in 2010, when Idaho schools were caught in a state network validity dispute and needed someone to help them recover. Outside of E-rate, he is on the trails or with his wife, kids, and grandchildren.
