The FCC has released the full text of its Notice of Proposed Rulemaking opening a review of the E-rate program. Here is what applicants should know.
First, the practical matter: nothing about your current obligations has changed. No rules have been amended, and no new deadlines are in effect. The comment deadlines will not be set until the notice is published in the Federal Register, which is expected in the coming weeks. Until then, continue your filing and competitive bidding exactly as before.
Beyond that, several aspects of the notice merit attention.
Much of the early coverage has centered on children’s screen time. That is one element, but the notice reaches considerably further. It raises questions about the size and scope of the program itself — including whether E-rate support should be narrowed, limited to particular areas, or withdrawn from certain services that are currently eligible.
A number of the proposals would affect the application process if adopted. Among them are changes to how the Children’s Internet Protection Act is applied, including the possibility of extending filtering requirements to personal devices students bring from home; questions about tying screen-time limits to funding eligibility; and revisions to the competitive bidding rules, including the use of existing contracts. None of these are settled. They are questions on which the FCC is seeking comment, and applicant input will help shape the outcome.
Related to E-rate consultants, the notice proposes a new certification form, a registration system, and a prohibition on fee arrangements based on a percentage of funding. These changes would apply primarily to consultants rather than to applicants directly.
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A review of this kind is an opportunity for schools and libraries to be heard. Funds For Learning will file comments, and once the deadlines are established we will provide guidance on how you can submit your own. The institutions that rely on E-rate are precisely those the Commission should hear from.
In the meantime, our 16th Annual E-rate Applicant Survey remains the most direct way to put the realities of the program in front of policymakers. You can take it here.
We are continuing to work through the details and will follow with closer analysis of the provisions that matter most to applicants. As always, your Funds For Learning Guide is available for your questions.
