The reply comment period for the FCC’s draft FY2027 Eligible Services List closed on August 14. A thorough review of the comments and subsequent replies shows clear agreement among schools, libraries, service providers, and other organizations: E-rate funding for Managed Internal Broadband Services should be retained. Attempts to limit or redirect eligibility will result in a disproportionately negative effect on the applicants who rely on MIBS most, while having very little practical impact on the overall E-rate funding landscape.
What the reply comments show
In our reply comments, Funds For Learning emphasizes the clear agreement among commenters who support retaining MIBS as an eligible service, while presenting program-wide statistics and analysis supporting commenters’ claims. In particular, our findings demonstrate four major themes:
- MIBS is a statistically small part of overall E-rate program funds,
- Smaller E-rate applicants tend to rely on MIBS significantly more than their larger counterparts,
- MIBS frequently makes up the entirety of smaller applicants’ Category Two spend; and,
- Applicants who stop applying for MIBS do not reliably replace it with Internal Connections equipment purchases.
Where commenters asked for more guidance
Several commenters suggest that the FCC bolster program guidance for MIBS eligibility to address concerns about ineligible staff augmentation or support services for ineligible equipment like end-user devices. NCTA — The Internet & Television Association suggests that the FCC could provide more specific guidance on the aspects of a service which would require cost-allocation, and we suggested a requirement that competitive bids proactively provide information about the equipment to be managed and monitored by the service.
Other eligibility questions in the record
Other reply comments address various aspects of product and service eligibility, with Infoblox highlighting the need for reliable DNS and DHCP service, and several others debating the pros and cons of “on demand” network services.
What happens next
The FCC is expected to publish the final Eligible Services List for FY2027 by the end of the calendar year, accompanied by authorization for USAC to open the annual application filing window.
Do you have questions about the draft ESL and what it could mean for FY2027 applications? Bring them to our next My E-rate Guides webinar on September 10 at 11:00 a.m. ET, a free session where you can put them straight to our Guides during the live Q&A. Register today.
About the Author: Brian Stephens has spent more than 15 years in the E-rate program, working with the full range of applicants and service providers. As an E-rate Guide at Funds For Learning, he’s known for making complicated rules make sense and giving participants a practical path forward. Based in Oklahoma City, Brian spends his time away from E-rate cooking up some amazing meals.
