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John Harrington, CEMP

The FCC Is Asking Big Questions About E-rate. Here’s How We Answer.

Last week, the FCC released a draft Notice of Proposed Rulemaking that asks some of the biggest questions the E-rate program has faced since it began. Should the program be narrowed? Has it fulfilled its mission? Should eligibility, discount rates, and even the way contracts are bid be reconsidered? 

I have worked in this program since 1997. I have seen funding crises, rule overhauls, court challenges, and a pandemic. Questions like these can generate a lot of noise. Headlines tend toward alarm. Rumors travel faster than facts. And school and library leaders, people with real jobs educating students and serving communities, are left wondering what it all means for them. 

In moments like this, the most useful thing anyone can offer is clarity. 

What this is, and what it isn’t 

This week, our team hosted a client-only webinar to walk through the draft NPRM line by line. We opened with the most important point, because our clients deserved to hear it first: nothing changes today. This is a proposal, not a decision. The FCC is asking questions and seeking public comment. Congress created E-rate, so the Commission cannot rewrite the program alone. The comment record will shape the outcome. 

That framing matters. When the questions are existential, the temptation is to react. The discipline is to understand. Our job at Funds For Learning is to read all seventy pages so our clients don’t have to, to separate the questions that could change how applicants operate from the ones that are policy debates for another audience, and to tell people plainly which is which. 

Some of what the FCC is asking is consequential for applicants: how existing contracts can be used in competitive bidding, deadlines that affect reimbursement, and how screen time and internet safety policies might one day connect to E-rate eligibility. Some of it asks questions that reach well beyond the IT office, into curriculum, instruction, and the conversations districts have with parents. We told our clients the honest version of both. Here is what could touch your operations. Here is what to start coordinating internally. And here is what doesn’t require any action from you at all.

The record is built from voices like yours 

There is a second thing this moment requires, and it isn’t something we can do alone. 

A rulemaking is an invitation. The FCC has asked the E-rate community to put evidence on the record: Is the program working? What has it made possible? What would change in your schools and libraries if it were limited? The Commission will make its decisions based on what the record shows, and the record is built from the experiences of the people the program actually serves. 

That is exactly why we field the annual E-rate applicant survey. For years, the survey has been the single largest collection of applicant voices in the program — data we put directly in front of policymakers so that decisions about E-rate reflect the reality of the schools and libraries who depend on it. This year, that evidence matters more than it ever has. 

So here is my ask. If you are an E-rate applicant, take eight minutes and complete the 2026 Applicant Survey. Then share it with a colleague who should be counted too. 

Take the survey today: www.surveymonkey.com/r/2026USF 

The FCC has asked its questions. The answers should come from you. 

We’ll be with you every step of this process. 

– John Harrington, CEO, Funds For Learning 

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