The Federal Communications Commission circulated a Notice of Proposed Rulemaking on June 4, 2026, ahead of its June 25th open meeting, where this item is on the agenda for a vote. The rulemaking would touch nearly every corner of the E-Rate program – from how schools manage children’s screen time to whether the program itself should be narrowed or restructured. It represents one of the most comprehensive reviews of the program in recent years.
The rulemaking is divided into two parts:
The first seeks public comment on whether E-Rate-funded networks are being used for genuine educational purposes and what role, if any, the FCC should play in limiting children’s screen time in schools and libraries.
The second proposes concrete changes to program administration and oversight, including new requirements around consultant registration and a prohibition on percentage-based consultant fee arrangements.
Nothing in the document is final. If adopted at the June 25th meeting, the notice will trigger a formal public comment period during which schools, libraries, service providers, and other stakeholders can weigh in before the FCC decides whether to adopt any of the proposals as binding rules.
What Comes Next
The item is scheduled for a vote at the FCC’s June 25 open meeting. Because the document was released as a circulation draft ahead of that vote, the scope and specific questions it contains remain subject to change before commissioners vote to adopt it. The version ultimately adopted on June 25 could be changed from what was circulated on June 4.
If the Commission votes to adopt the notice on June 25, a formal comment period will open once it is published in the Federal Register, which typically occurs within a few weeks of an open meeting. Initial comments will be due 30 days after that publication date, with reply comments due 60 days after. Until the Federal Register notice publishes, no official deadline is in effect.
Key Areas Under Consideration
The FCC is asking whether the program has outgrown its original mission now that virtually all schools report having broadband connectivity. Against that backdrop, the FCC is seeking comment on whether special construction, dark fiber, and other services added to the eligible services list over the years remain appropriate, or whether E-Rate should be scaled back to its core connectivity purpose.
On child safety and educational use, the FCC is asking whether schools are genuinely using E-Rate-funded networks for educational purposes and whether the Commission has authority to impose per-day screen time limits. It is also asking whether CIPA’s existing protections should extend to personal devices connecting to school networks, whether schools should be required to offer parents the ability to opt children out of screen-based instruction, and whether the FCC’s 2011 conclusion that social media is not per se harmful to minors should be revisited.
For applicants specifically, two proposals carry direct operational significance. The FCC is proposing to eliminate the long-standing Kalamazoo exception that has allowed applicants to memorialize existing contracts as compliant competitive bids. If adopted, all contracts would need to be signed after the allowable contract date established by the Form 470. The FCC is also proposing a firm June 30 deadline for service providers to file the FCC Form 473, their annual certification, which has been a recurring source of BEAR reimbursement delays for applicants whose service providers fail to file on time.
Why This Matters
The E-Rate program distributes approximately $3.5 billion annually to schools and libraries for broadband connectivity and internal network infrastructure. The proposals under consideration could affect every participant in the program. The screen time questions in particular reflect a broader national debate about children’s technology use that has drawn attention from Congress, state legislatures, and the U.S. Surgeon General.
The comment period will be the primary opportunity for the E-Rate community to shape the final outcome. Organizations and individuals with relevant experience and data are encouraged to file substantive comments addressing the specific questions the FCC has raised. Funds For Learning will continue to review and report on this proposal.
Want to weigh in on where E-rate is headed? Take a few minutes to share your experience in the 2026 E-rate Applicant Survey.
