The FCC’s April 30 order got most of its attention for the new competitive bidding portal. We’ll cover that in depth in future issues. But the same order included six other changes that will affect applicants starting well before Funding Year (FY) 2028. Here’s the quick version, with detail below for each:
- Form 486 eliminated beginning in FY 2028; CIPA certifications move to the Form 471
- Late invoice extension requests now allowed up to 15 days after the deadline
- Rejected invoices can be refiled within 60 days without going through the appeal process
- Mid-year service provider transitions get a new post-commitment process that allows date adjustments and funding increases
- Mid-year bandwidth increases are now permitted via service substitution at the existing commitment amount
- 90% ancillary use presumption extended from Internet access to all recurring category one services
1. Form 486 Eliminated
Beginning in FY 2028, applicants will no longer be required to file the Form 486. The FCC found that its core function — notifying USAC that services have started — is already duplicated by the invoicing forms, and that errors on the 486 caused funding denials without any real program benefit.
The CIPA certifications currently on the Form 486 move to the Form 471. Consortium leads need to take note: you’ll need to collect the FCC Form 479 from member entities before the Form 471 is filed, rather than afterward. This is a meaningful timeline shift that requires planning ahead of FY 2028. Applicants with open commitments from prior years continue filing the 486 for those existing commitments.
2. Late Invoice Extension Requests
Applicants and service providers who miss the invoice filing deadline can now request a 120-day extension from USAC, as long as the request is filed within 15 days of that missed deadline. Previously, missing the deadline without a prior extension request meant filing a waiver under a tough standard that few requests cleared. The Bureau has also been directed to retroactively grant pending waiver requests that were filed within that 15-day window.
3. Rejected Invoice Refiles
If a timely filed invoice is rejected by USAC, applicants and service providers now have 60 days from the rejection notice to correct and refile. No appeal required. If the refiled invoice is also rejected, the standard appeal process remains available.
4. Mid-Year Service Provider Transitions
Applicants transitioning between service providers during a funding year can now file partial-year funding requests for both providers during the application window, using their best estimate of the cutover date. Once the actual transition occurs, they file a post-commitment request to adjust the dates and USAC is now authorized to grant that request even if it results in a higher funding commitment. Both providers can also be reimbursed for the services they actually delivered during the transition month, with no overlap.
For applicants who already struggled with this before the new rules, the Bureau has authority to find good cause for a waiver if the transition was indicated at the time of filing and the delay was beyond the service providers’ control.
5. Mid-Year Bandwidth Increases
Applicants who need more bandwidth mid-year can now submit a service substitution request to increase bandwidth at the existing commitment amount without triggering a new competitive bidding requirement. If a higher funding commitment is needed for future years, a new Form 470 and bidding process may be required going forward. Applicants whose original bidding process already covered the higher bandwidth and price shouldn’t need to rebid to use the increased bandwidth.
6. 90% Ancillary Use Presumption Expanded
The 90% ancillary use presumption — previously limited to Internet access — now applies to all recurring category one services, including data transmission and wide area network services. If at least 90% of a recurring category one service at an eligible location is used for eligible purposes, cost allocation is not required for the remainder. The presumption applies only to on-premises use; off-campus use still requires cost allocation.
We’ll have full coverage of the competitive bidding portal in upcoming issues. In the meantime, if you have questions about how any of these changes affect your current funding year planning, don’t hesitate to reach out. We will also discuss this on tomorrow’s, May 7th, 2026, My E-rate Guide webinar. You can register here.
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Verlyne Jolley leads a Guide Team at Funds For Learning and has spent the past 20 years helping schools and libraries navigate the E-rate program. She stays at Funds For Learning because she enjoys the people she works with and being part of a team that’s focused on expanding internet access and educational opportunity.
