The draft Funding Year 2027 Eligible Services List proposed almost no changes to what E-rate funds. Instead, the Wireline Competition Bureau asked questions about Managed Internal Broadband Services: whether MIBS should remain eligible, whether reimbursement should be limited to documented hours worked, and whether eligibility should be restricted by applicant size (WC Docket No. 26-133 / Public Notice DA 26-647). The initial comment window closed July 30. Eleven filings reviewed here answer those questions, and two facts stand out: no commenter recommended removing MIBS from the list, and every commenter who addressed hourly ticket billing opposed it.
The school districts spoke for themselves
Two school districts filed their own comments, and both urged the Commission to keep MIBS eligible. Cleveland Metropolitan School District (CMSD), serving more than 32,000 students across more than 100 buildings at a 90/85 percent discount rate, reported 89 sites under a competitively bid MIBS contract and roughly $2.37 million budgeted annually, with about $1.24 million committed through E-rate in FY2026. Los Angeles Unified reported using MIBS to manage uninterruptible power supplies at more than 700 schools and found the leased, managed solution cost less than separately priced equipment, installation, monitoring, and maintenance.
“For CMSD and districts like it across the country, MIBS is not a discretionary line item. It is part of how we keep schools open and running.”
Where the commenters landed
| Commenter | Position on MIBS | Notable point |
| Cleveland Metropolitan School District (school district) | Retain fully; “not a discretionary line item” | 89 sites under MIBS, ~$2.37M/year budgeted; a competitively bid fixed price is a market-tested measure of cost-effectiveness |
| CSM Consulting (Consultant) | Retain for all sizes; fold BMIC into MIBS instead | The Category Two cap plus the 2014 Order’s 1/5 presumption is the real cost guardrail |
| E-Rate Central (Consultant & NY State E-Rate Coordinator) | Not addressed; comments focus on firewalls | Make advanced firewalls explicitly eligible; only 31% of FY2025 firewall applications were approved as submitted, and full funding would have cost about $9M |
| Jason Kronemeyer (rural MI technologist) | Preserve MIBS and NaaS for small and rural entities | Size caps and hourly limits would fall hardest on the smallest applicants |
| Los Angeles Unified School District (school district) | Retain for all sizes, “full stop” | Uses MIBS to manage UPS units at 700+ schools; existing bidding rules suffice, enforce them |
| MetComm.Net (NY vendor) | Preserve; define eligibility by function, not size | A standardized fixed-price deliverables list would be easier to bid, manage, and audit |
| Ohio Information Technology Centers (regional service agencies) | Retain; adopt a clear MIBS definition instead | 61 of its 95 applicants rely on managed LAN/WLAN; USAC already has the data to flag cost outliers |
| SECA (state E-Rate coordinators) | No position; recommendations “not yet finalized” | Will review other stakeholders’ comments before taking a position |
| SentinelOne (cybersecurity vendor) | Preserve; add scope limits rather than eliminate | Asks the FCC to clarify that managed cybersecurity monitoring qualifies as MIBS |
| SHLB Coalition (300+ anchor -institution members) | Retain; reiterates FY26 comments | In FY25, 2,248 of 2,415 school MIBS applicants served fewer than 5,000 students; asks for “sufficient advance notice” because applicants are already under multi-year contracts |
| TechnologyLab (TN vendor) | Retain for all sizes | Fixed monthly fees let rural applicants budget and attract providers who must travel |
The FY2026 ESL proceeding produced a similar record: per the Ohio ITCs, fifteen of eighteen commenters urged the Commission to keep MIBS eligible.
Two principles the record supports
Consistency. Applicants are in year two of the five-year FY2026 through FY2030 Category Two budget cycle, and many hold multi-year MIBS contracts signed under the rules in effect. SHLB asked the Commission for “sufficient advance notice” of any changes because applicants “are already under multi-year contracts.” If the Commission removes or restructures anything, timing matters: changes should take effect going forward, respect budget cycles and existing contracts, and give districts and schools the lead time to plan and prioritize. The Commission has done this before, phasing down voice support by 20 percentage points a year rather than ending it overnight.
Simplicity. Conditional eligibility and cost allocation are hard on applicants and USAC alike. New York’s state E-rate coordinator reports that only 31 percent of FY2025 firewall applications were approved as submitted, a decade after the ESL last addressed firewalls directly, and estimates full funding would have cost about $9 million. The five-year budget cap is itself the cost control: applicants can only spend what is in their budget during the cycle, no matter how services are categorized. Clear, explicit eligibility, including advanced firewalls, would reduce cost-allocation disputes without increasing costs to the fund.
The record is still being written. Reply comments in the ESL proceeding are due August 14, 2026, filed through the FCC’s Electronic Comment Filing System referencing WC Docket Nos. 26-133 and 13-184. If your school or library is mid-contract or mid-budget-cycle, that fact belongs in the record: tell the Commission when your contracts end, how your five-year budget is committed, and what an abrupt change would mean for the services your students and patrons use every day. Funds For Learning will be submitting reply comments of its own, and we will be right beside you every step of the way.
