On February 17, 2026, The Federal Communications Commission granted relief to several school districts and service providers whose E-rate reimbursement requests were denied after they relied on incorrect invoice deadlines generated by the Universal Service Administrative Company’s systems.
In an Order adopted and released on February 17, 2026, the FCC’s Wireline Competition Bureau waived strict invoicing rules under the E-rate program. The decision affects appeals from entities in California, New York, Illinois, and Texas whose reimbursement requests were treated as late-filed despite being submitted before the deadlines displayed in USAC’s systems and public-facing tools.
Reliance on Incorrect Deadlines
The FCC found that in each case, applicants or service providers reasonably relied on invoice filing deadlines provided by USAC’s electronic systems, including the E-rate Productivity Center and other deadline-reporting tools. Although the requests were submitted by the dates shown in those systems, USAC later determined that the deadlines had been inadvertently extended due to system errors and denied or sought recovery of funds accordingly.
The Commission noted that USAC manages tens of thousands of individualized invoice filing deadlines each funding year and that applicants often depend on USAC-generated information to determine compliance. In funding year 2022 alone, USAC created more than 110,000 invoice filing deadlines and processed hundreds of thousands of invoices.
Extraordinary Circumstances Standard Met
While the FCC has historically emphasized that invoicing deadlines should be enforced strictly and that waivers are generally not in the public interest, the Bureau concluded that these cases met the “extraordinary circumstances” standard required for relief.
The Order emphasized that there was no evidence of waste, fraud, or abuse by any of the petitioners. Instead, the procedural denials stemmed from misinformation generated by USAC’s own systems, placing applicants at a disadvantage despite timely action based on official data.
Next Steps
As part of the ruling, the FCC remanded the affected funding requests back to USAC for further action consistent with the Order. At the same time, the Commission reminded E-rate participants that they remain responsible for understanding and complying with program rules, including invoice filing deadlines, even as they rely on USAC systems.
The FCC Order can be viewed here.
