If you manage E-rate for your school or library, the transition into July is one of the points where I see avoidable mistakes most often. Funding Year 2025 begins to wrap up on June 30, 2026, and FY2026 services start the very next day.
It’s a quick transition, and missing a few small details can easily lead to delayed payments or funding complications down the road.
The good news is that nothing here is overly complex. With a little attention and the right sequence, you can move through the transition with confidence.
For Applicants
One of the main things to consider is making sure you’re on track to close out FY2025. With your recurring services coming to an end and non-recurring on the horizon you’ll want to address the following items:
Close out FY2025
- Confirm recurring services end by June 30 and non-recurring work is on track for the September 30 deadline. Consider filing for a service delivery deadline extension, if September doesn’t seem feasible.
- Double check FY2025 invoices match the services requested and delivered on your approved Funding Request Numbers (FRNs). If you experienced a change this past year, was a proper service substitution requested and approved?
- If a Form 471 is still pending, follow up on Program Integrity Assurance (PIA) inquiries and make sure your application didn’t slip into summer deferral.
Get ready to launch FY2026 on July 1
- Confirm your Funding Commitment Decision Letter (FCDL) has been issued and your Form 486 has been processed. Without these, services can begin, but seeking reimbursements cannot proceed.
- Use the FY2026 FRN for every service that begins July 1, and expect discounted billing to lag a cycle or two.
Set your invoicing up to succeed
Invoicing problems usually trace back to a missing prerequisite, and Form 486 is the one with a clock on it.
- File FCC Form 486 promptly once a commitment is issued and services begin (deadline: 120 days after the service start date or the FCDL date, whichever is later)
- Confirm your Children’s Internet Protection Act (CIPA) certification is accurate
- Make sure your provider’s SPAC (Form 473) is approved.
- Confirm your method, Service Provider Invoice (SPI) or Billed Entity Applicant Reimbursement (BEAR), matches your plan. (New to the choice? Here’s how to decide which is right for you.)
- Set a cadence so you know when discounts actually arrive
- Use the FY2026 FRN for every service that begins July 1, and expect discounted billing to lag a cycle or two
One of the most common transition errors I see is billing new services against the old year or referencing last year’s FRN on a service that’s carried over into the new year.
A few other housekeeping items to handle as we look ahead:
- Update your EPC administrators and user permissions
- If you use the BEAR method, confirm your SAM.gov registration, Unique Entity ID, and banking details are current
For Service Providers
Your applicants’ clean transition depends on yours as well:
- Close out FY2025: submit all invoices on time, double check your SPAC (Form 473) was filed, and clear any SPIN changes, if applicable.
- Transition to FY2026 where recurring services continue from FY2025. Make sure to update systems to reference the FY2026 FRNs.
- Complete setup: file your new SPAC early, update Form 498 with your SAM.gov UEI and banking info, and confirm services remain eligible under the FY2026 ESL
- If there was a product or service change during the past year, were all substitution requests filed and approved.
Documentation and Audit Readiness (Applicants and Service Providers)
Most compliance findings aren’t about whether you did the work. They’re about whether you can prove it years later:
- Keep all E-rate documentation for 10 years from the last date of service
- Retain contracts and amendments, invoices and payment records, and installation and delivery records
- Make sure those records clearly show services were delivered on time and billed accurately against approved FRNs
A Word on Where Transitions Go Wrong
The June-to-July handoff is easy to underestimate, which is exactly why the same mistakes show up year after year. The usual compliance culprits are predictable: billing against the wrong funding year, missing the move to the correct FRN on July 1, a late Form 486, and missed invoice deadlines. These rarely make noise right away. They surface later, when deadlines or audits are looming. In the end, they can mean delayed payments, funding reductions, or recovery actions. Working the steps above, and keeping the documentation to back them up, is what keeps your funding flowing without interruption.
The July 1 transition is one of the topics we’re covering live at our next My E-rate Guides (MEG) session on July 9. Bring your questions about funding year closeout, FRN alignment, and invoicing. Register for the July 9 MEG today.
About the Author: Sean Lock is a veteran E-rate Guide at Funds for Learning with nearly two decades of industry experience. Since entering the field during the 2007 financial collapse, Sean has dedicated his career to helping clients—from individual charter schools to the nation’s largest districts—maintain compliance and maximize their E-rate benefits. When he’s not untangling federal funding regulations, Sean enjoys spending time outdoors and staying active, whether it’s running socially with his local group or training for a new personal best.
