Uncertainty Around the New Portal
You may have heard the buzz about the new competitive bidding portal set to arrive in Funding Year 2028 (FY2028). If your organization is gearing up for the next few E-rate funding cycles, here is what matters: most of the specifics are still unknown, and that uncertainty is worth planning around now.
The FCC and USAC have signaled that your procurement documentation will all need to go into a dedicated online system USAC is currently building. That includes posting Form 470s in your E-rate Productivity Center (EPC) account, gathering vendor bids, and a patchwork of other paperwork: bid evaluations, Requests for Proposals (RFPs), and applicant communications in particular.
This will be a significant change that every applicant and vendor will have to understand. At this point, though, we don’t yet know how the portal will look or work, what new documentation it will require, or, critically, how steep the learning curve will be for applicants who’ve filed the same way for the last ten years.
Many applicants already use a state or local bidding portal, so the general concept may feel familiar. Even so, they’ll need to adapt to this new system just like applicants who only use EPC today.
The Case for Multi-Year Contract Procurement Before FY2028
That uncertainty is exactly why now is a good time to think seriously about procuring a multi-year service contract, if your circumstances allow it.
The appeal is straightforward: a multi-year agreement with a service provider that begins in FY2027 means you don’t have to run a new competitive bid during the FY2028 bidding period, when the new portal goes live.
If FY2028 turns out to be a bumpy rollout, with USAC, applicants, and vendors all figuring out an unfamiliar system in real time, a multi-year contract already in place means your only concern is uploading whatever documentation ends up being required. That’s considerably better than trying to procure services, challenging enough on its own, while also learning a new process and a new tool by trial and error, under filing-deadline pressure.
Here are a couple of scenarios where this strategy may be worth leveraging.
Category One Services
The first case for a multi-year agreement is Category One service, your internet access and data transport, where you’re contracting for a recurring service rather than a one-time purchase.
Even a two-year contract in FY2027 puts you ahead of the portal changes. Your procurement is done, and you can run a new one a year after the dust settles, when we’ll all have a much clearer picture of what the portal actually requires. Giving yourself optional extensions, where applicable, is always worth considering for even more flexibility after the portal launches.
Category Two Equipment and Maintenance
Category Two internal connections usually work differently, since most of your spending goes toward equipment you buy once, so a one-year contract term is common. That option works fine too, but doing this procurement for FY2027 again sets you up with that piece completed. All you’d need to worry about is what documentation the portal requires you to upload from that procurement.
That said, some equipment purchases are tied to a multi-year contract or one with optional extensions. Maintenance and technical support agreements under Category Two usually run multi-year as well.
If you’re not sure exactly when you’ll purchase the equipment, maybe the need isn’t urgent, or you don’t know which fiscal year you’ll have budget for your non-discount share, then procuring in FY2027 for a multi-year agreement gives you room to make those purchases later and navigate the FY2028 changes more easily.
Phased Equipment Purchases
Phased equipment purchases raise a related but distinct question. If you’re planning to roll out equipment purchases across two or three years, structuring the solicitation as “up to X units, delivered in phases or multiple funding years” rather than a fixed one-time order, a multi-year bid is worth pursuing in FY2027 rather than going out to bid each year separately.
While this preserves flexibility, it’s worth noting that a phased hardware rollout produces a different paper trail than a recurring services agreement or a one-time equipment purchase. Each subsequent funding year, you may need to upload more documentation for those purchases, depending on what ongoing tracking the portal ends up requiring. All of the original procurement documentation will already be there, however you should plan to document each ongoing phase completely as it happens.
We Don’t Know What We Don’t Know
There’s one real concern with procuring in FY2027, before you know what the portal will require a year later: you’re guessing at what USAC will decide is relevant, and you may not think to document something at the time that turns out to matter.
A few things worth doing alongside your procurement, to keep complete records of each phase:
- Delivery and acceptance records
- Communications about procurement with vendors and consultants
- Serial numbers on an asset list
- Tagging and logging equipment for eligibility tracking
- Tracking lists of purchase dates and installation dates
- Licensing renewal terms, which sometimes run on their own separate clock
These are the kinds of documentation USAC could start requiring in the portal. Anticipating this now helps ensure you’re ready to provide whatever they ask for next funding year.
One Alternative Worth Considering
There’s one alternative worth considering instead of a traditional multi-year contract: an FY2027 procurement establishing a one-year contract with multiple one-year optional extensions, for either Category One or Category Two.
Then you wait and see what the FY2028 requirements turn out to be. From there, you can decide whether the new portal requirements make it better to re-procure and align with them, or whether you can simply extend your contracts and provide the portal with documentation from your FY2027 procurement without re-bidding at all.
Extenuating circumstances aside, for many applicants it probably makes sense to establish, extend, or renew into a multi-year term now, so there’s one less challenging process to manage while USAC works out the portal’s growing pains.
Wondering how the FY2028 portal transition could affect your own procurement plans? Bring your questions to our September 10 My E-rate Guides webinar. Register today.
About the Author: Dirk Schroeder has been part of the Funds For Learning team for 16 years and calls Edmond, OK, home. Outside of work, he likes to hit the golf course as long as it’s not 100 degrees out.
