Category: E-Rate Updates

  • E-rate Update: May 22, 2026

    Executive Summary

    This brief highlights critical changes including the upcoming August 2026 mandatory SAM.gov and UEI integration for all BEAR invoice filers, significant FY2028 program reforms by the FCC introducing a competitive bidding portal and eliminating Form 486, and disaster relief provisions for areas impacted by Typhoon Sinlaku. Timely response to PIA inquiries and Form 486 filing for FY226 are also critical.

    Important Deadlines & Dates

    • June 30, 2026: Last day to receive recurring services for FY2025.
    • July 1, 2026: Begin invoicing for FY2026 recurring services.
    • August 2026: Mandatory transition to SAM.gov banking information for all Universal Service Fund invoices. All BEAR filers must have an active SAM.gov account with a UEI on their FCC Form 498. Payments will be held for non-compliance.
    • May 22, 2026 – September 11, 2026: E-Rate “Summer Deferral” period for PIA inquiries. Applications contacted for the first time on or after May 22 without a response will be deferred until after September 11.
    • September 21, 2026: Deadline for disaster-affected applicants (Typhoon Sinlaku) to submit Requests for Review/Waiver and FCC Forms 486, 472, 474.
    • September 30, 2027: Extended FY2025 non-recurring service implementation deadline for disaster-affected applicants.

    Critical Updates

    Invoicing Method Modification for FY2026

    • Before FCDL: Submit a Receipt Acknowledgment Letter (RAL) Modification Request.
    • After FCDL: Use the new “Invoicing Method” change request via FCC Form 500. This must be done before any invoice submission for the FRN.
    • BEAR to SPI Change: Requires documentation of service provider agreement for the change.

    Mandatory SAM.gov and UEI Requirement for FCC Form 498

    • Effective August 2026: All service providers and E-Rate applicants using BEAR invoicing (FCC Form 472) must have an active SAM.gov account with a Unique Entity Identifier (UEI) on their FCC Form 498.
    • USAC will use SAM.gov banking information for all disbursements; existing FCC Form 498 banking information will no longer be used.
    • Failure to update your FCC Form 498 with a UEI and maintain an active SAM.gov account will result in held payments.
    • An e-learning module on filing/modifying FCC Form 498 for applicants is available.

    Service Provider Annual Certification (SPAC) – FCC Form 473

    • Required for FY2026: Service providers must file and certify their FCC Form 473 as soon as possible.
    • USAC cannot pay invoices (FCC Form 472 or FCC Form 474) until both the FCC Form 486 and FCC Form 473 (SPAC) are certified and approved.
    • Failure to submit SPAC forms will lead to referral to the FCC Enforcement Bureau.

    Interim SPIN Usage for FY2026 Applications

    • Applicants who used the interim SPIN 143666666 for FY2026 funding requests must submit a RAL modification request to provide the actual SPIN.
    • USAC will not issue an FCDL until the interim SPIN is updated.

    FCC Adopts E-Rate Competitive Bidding Portal and Program Rule Changes (FCC 26-30)

    The FCC has adopted a Report and Order (FCC 26-30) introducing significant changes, primarily effective in FY2028:

    • Competitive Bidding Portal (FY2028):
      • Mandatory USAC-managed portal for service providers to submit bids.
      • Applicants must upload bid evaluations, vendor selections, and contracts to the portal.
      • Will serve as a document repository.
      • Mandatory portal use for competitive bidding communications, including bidder questions and applicant responses.
    • Service Transition Process:
      • A future process will allow post-commitment requests to change service start/end dates and potentially increase commitment amounts for transitioning services, subject to OMB approval and specific criteria.
    • Cost Allocations:
      • The 90% ancillary use presumption now applies to all Category One (C1) services (e.g., data transmission, WAN, Ethernet). If 90% of a recurring C1 service is for an eligible purpose at eligible locations, cost allocation for the remaining ineligible use is not required.
    • Competitive Bidding Exception (Bandwidth Increase):
      • A limited exception allows service substitution requests to increase bandwidth during the funding year at the existing commitment amount. A new FCC Form 470 will be required for subsequent funding years.
    • Elimination of FCC Form 486 (FY2028):
      • The requirement to file FCC Form 486 will be eliminated starting in FY2028. CIPA certifications will move to FCC Form 471.
      • Crucial Note: FCC Form 486 is still required for FY2026 and FY2027, and for any prior year open commitments or approved appeals.
    • Invoice Filing Deadline Relief:
      • A single 120-day extension from USAC is now permissible if requested within 15 days of the original deadline.
      • A one-time 60-day grace period for resubmitting corrected versions of timely-filed but rejected invoices.

    Disaster Relief for Typhoon Sinlaku Affected Areas (DA 26-396)

    For applicants and providers in areas affected by Typhoon Sinlaku:

    • Deadline Extensions:
      • Up to 150 calendar days (until September 21, 2026) to submit requests for review/waiver and FCC Forms 486, 472, 474.
      • FY2025 non-recurring services implementation deadline extended to September 30, 2027.
    • Service and Equipment Substitutions:
      • Waiver of the “same functionality” requirement, allowing greater flexibility for substitutions. Submit a Service Substitution request to USAC.
    • Document Retention:
      • Waiver for records destroyed by the weather events, provided certification of destruction.

    Filing the FY2026 FCC Form 486

    • File FCC Form 486 after receiving a positive FCDL and services have started (or can be filed early under specific conditions).
    • Certifies service start and CIPA compliance.
    • Consortium members must provide their FCC Form 479 (CIPA Certification) to the consortium leader before the consortium can file the FCC Form 486.

    Current Status

    • FY2026 Commitments: As of May 20, 2026, over $1.05 billion has been committed, with Waves 1, 2, and 3 already released.

    E-Rate Outreach and Training

    • June 9, 2026: Beginning E-Rate Services Webinar (2-3 PM ET).
    • June 16, 2026: Open Data Webinar Part 1: Open Data Overview (2-3 PM ET).
    • June 18, 2026: E-Rate Invoicing Applicant and Service Provider Webinar (2-3 PM ET).
    • June 25, 2026: Open Data Webinar Part 2: Creating Reports and Visualizations (2-3 PM ET).
    • September 15, 2026: In-person E-Rate Training in Phoenix, AZ.
    • September 24, 2026: In-person E-Rate Training in Washington, D.C. (also live on FCC’s YouTube).

  • E-rate Update: April 17, 2026

    Executive Summary

    The FY2026 application window has closed, initiating the Program Integrity Assurance (PIA) review phase, with critical actions required for applicants, including RAL modifications for corrections and a new invoicing method change process via FCC Form 500. Additionally, a mandatory SAM.gov Unique Entity Identifier (UEI) is now required for all USAC invoice disbursements beginning August 2026.

    Important Deadlines & Dates

    • April 23, 2026: Registration opens for upcoming in-person E-Rate Training events.
    • August 2026: All service providers and BEAR filers must have an active SAM.gov account with a UEI on their FCC Form 498 for USAC invoice disbursements.
    • September 15, 2026: In-person E-Rate Training in Phoenix, AZ.
    • September 24, 2026: In-person E-Rate Training in Washington, DC.
    • June 30, 2026: Final reminder deadline for service providers to file their FCC Form 473 (SPAC).

    Critical Updates

    FY2026 Application Window: Post-Closure Actions & Tips

    • Window Waiver Requests: Applicants needing a waiver for the FY2026 window must certify and submit their FCC Form 471 in EPC before filing the waiver request with the FCC.
    • Interim SPINs: If interim SPIN 143666666 was used, submit a Receipt Acknowledgment Letter (RAL) modification request to provide the actual service provider SPIN. Funding Commitment Decision Letters (FCDLs) will not be issued until this is updated.
    • RAL Modifications:
      • Submit RAL modification requests to correct/update entity information (e.g., student counts, square footage, urban/rural status, CEP percentages, contact information), FCC Registration Number, and cost allocations.
      • Consider separating unique equipment types into distinct Funding Request Number (FRN) Line Items via RAL modification for faster PIA review.
      • RAL modifications must be submitted before receiving your FCDL. Post-FCDL changes require a FCC Form 500, Service Substitution, SPIN Change, or Appeal.
    • Competitive Bidding Documentation: Organize and retain all competitive bidding process documentation that supports your FCC Form 471 for a minimum of 10 years.
    • Prepare for PIA Review: Respond promptly to any Program Integrity Assurance (PIA) inquiries. Monitor your contact email and EPC account regularly. Alert service providers to be ready to assist with network diagrams or product descriptions if needed.

    Invoicing Method Changes for FY2026

    • New Process: For FY2026, the invoicing method (FCC Form 472/BEAR or FCC Form 474/SPI) was selected for each FRN on the FCC Form 471.
    • Pre-FCDL Modifications: Changes to the invoicing method can be made via a RAL modification request.
    • Post-FCDL Modifications: After receiving an FCDL, invoicing method changes can be requested using the new “Invoicing Method” change request within the FCC Form 500. This must be submitted before any invoice is filed for the FRN.

    Mandatory SAM.gov UEI for All Invoicing

    • Effective August 2026: USAC will transition to using SAM.gov banking information for all Universal Service Fund (USF) disbursements.
    • Requirement: All service providers and E-Rate applicants who invoice via FCC Form 472/BEAR must have:
      • An active SAM.gov account.
      • A Unique Entity Identifier (UEI) on their FCC Form 498 (Block 3, Line 24).
      • A valid bank account linked to their UEI in SAM.gov, specifically for USF disbursements.
    • Action Required:
      • Verify: Log into E-File (or EPC for BEAR filers) to confirm UEI on Form 498. Then, log into SAM.gov to confirm active account status, linked bank account, and annual renewal date.
      • Register/Update: If not active or missing, register at SAM.gov (process can take up to six weeks), obtain a UEI, link a valid bank account, and update the UEI on FCC Form 498.
    • Annual Renewal: SAM.gov accounts require annual renewal. Failure to renew will prevent USF disbursements.

    Program Integrity & FCC Debarment Rule Updates

    • FCC Rule Changes (March 26, 2026): The FCC adopted a Report and Order (FCC 26-18) that modified its suspension and debarment rules to align with OMB guidelines. This allows the FCC to more promptly and efficiently exclude bad actors from USF programs, consider a wider range of misconduct, and promote transparency by requiring disclosure of prior misconduct.
    • Reporting Misconduct: Report suspected waste, fraud, or abuse via USAC’s Whistleblower Alert or the FCC Office of Inspector General (OIG) Hotline (1-888-863-2244).

    Contract Award Date (CAD) Accuracy

    • Ensure the Contract Award Date (CAD) and other details for your contracts are accurate in your EPC contract records, especially if cited on your FCC Form 471.
    • An accurate CAD and uploaded contract copies can help expedite PIA reviews.
    • Note that submitted contract records in EPC cannot be edited; a new record must be created for any changes.

    Service Provider Annual Certification (SPAC) – FCC Form 473

    • Reminder: Service providers are required to annually file a FCC Form 473 (SPAC) for each funding year.
    • Impact: A certified SPAC is mandatory for USAC to pay any invoices (FCC Form 472/BEAR or FCC Form 474/SPI) for that specific funding year.

    Current Status

    • FY2025 Commitments: As of April 15, 2026, over $2.64 billion has been committed for Funding Year 2025. Wave 49 FCDLs were released on April 9, 2026.

  • E-rate Update: March 19, 2026

    Executive Summary

    The FY2026 FCC Form 471 application window closes definitively on April 1, 2026. Additionally, a critical change for all USF disbursements mandates active SAM.gov registration with a verified Unique Entity Identifier (UEI) on FCC Form 498 and linked bank account, effective August 2026.

    Important Deadlines & Dates

    • April 1, 2026, 11:59:59 p.m. E.T.: FY2026 FCC Form 471 application filing window closes.
    • March 26, 2026, 2 p.m. E.T.: PIA Review Process Webinar.
    • March 31, 2026, 2 p.m. E.T.: Service Provider Webinar.
    • April 1, 2026: Earliest date for Category Two non-recurring service installation and equipment delivery for FY2026.
    • August 2026: All USF disbursements via FCC Form 472 (BEAR) or FCC Form 474 require an active SAM.gov registration with a UEI on FCC Form 498 and a valid bank account.
    • September 15, 2026: E-Rate Training – Phoenix, AZ.
    • September 24, 2026: E-Rate Training – Washington, DC.
    • Annually: SAM.gov account renewal required to receive USF disbursements.

    Critical Updates

    FY2026 FCC Form 471 Filing Window Reminders

    • Interim SPIN: The interim SPIN (143666666) became available on March 18, 2026, for use on FY2026 FCC Form 471 funding requests when a provider’s specific SPIN is unknown.
    • Waiver Requests: If a waiver of the FY2026 FCC Form 471 deadline is necessary, applicants must certify and submit their FCC Form 471 in EPC before filing the waiver request with the FCC.
    • Post-Certification Corrections: For any corrections to a certified FCC Form 471, including entity profile, funding requests, additions, or removals, use a Receipt Acknowledgment Letter (RAL) modification request.

    Categorization of Right-to-Use and Support Licenses

    Both right-to-use and support licenses are classified under Internal Connections (IC). Their categorization as non-recurring or recurring services depends entirely on supporting contract documents and vendor billing:

    • Non-recurring: When supporting documentation reflects fixed (non-recurring) pricing.
    • Recurring: When supporting documentation reflects a monthly recurring charge.

    Advance Installation of Non-Recurring Services

    • Category One (C1): Non-recurring services may be installed up to six months prior to the funding year start (on or after January 1). Conditions apply: construction must begin after competitive bidding, a recurring service must depend on the infrastructure, the service start date must be on or after the funding year, and no invoices (FCC Forms 472 or 474) can be dated prior to July 1 of the funding year.
    • Category Two (C2): Non-recurring service installations may begin as early as April 1 prior to the funding year. Equipment orders for FY2026 can be placed before April 1, 2026, but delivery cannot occur before April 1, 2026. No invoices (FCC Forms 472 or 474) can be certified prior to July 1 of the funding year.

    Guidance for Competitive Bidding and Late Filers

    March 4, 2026, was the last day to certify and submit an FCC Form 470 to meet the 28-day waiting period and file the FY2026 FCC Form 471 by April 1, 2026.

    For applicants who have not yet certified an FCC Form 470:

    1. Certify and submit your FY2026 FCC Form 470 immediately. Upload any RFP documents.
    2. Observe the minimum 28-day waiting period before selecting a service provider, signing a contract, and submitting your FCC Form 471. Adhere to any state/local procurement rules requiring a longer waiting period.
    3. Certify and submit your FCC Form 471. It will initially be in “out-of-window” status.
    4. Promptly request a waiver of the FCC Form 471 application filing window deadline with the FCC, providing detailed circumstances for the late filing. Approved waivers will move the FCC Form 471 to an “in-window” status for PIA review.

    Extended Customer Service Center (CSC) Hours

    The E-Rate CSC will offer extended hours leading up to the April 1, 2026, FCC Form 471 deadline. Call (888) 203-8100 for assistance.

    • Saturday, March 28: 12 p.m. to 5 p.m. E.T.
    • Sunday, March 29: 12 p.m. to 5 p.m. E.T.
    • Monday, March 30: 8 a.m. to 8 p.m. E.T.
    • Tuesday, March 31: 8 a.m. to 8 p.m. E.T.
    • Wednesday, April 1: 8 a.m. to 11:59 p.m. E.T.

    SAM.gov Registration for USF Disbursements

    Beginning August 2026, USAC will exclusively use SAM.gov banking information for all Universal Service Fund invoice payments. To continue receiving disbursements, all service providers and applicants using the FCC Form 472 (BEAR) or FCC Form 474 for invoicing must:

    • Maintain an active SAM.gov account.
    • Have a Unique Entity Identifier (UEI) recorded on their FCC Form 498.
    • Have a valid bank account associated with their SAM.gov account.
    • Ensure the Taxpayer Identification Number (TIN) associated with the UEI in SAM.gov matches the TIN on their FCC Form 498.
    • Annually renew their SAM.gov account. Inactive accounts will prevent funding disbursement.

    To update the FCC Form 498 with the UEI:

    • For Service Providers (in E-File): An FCC Form 498 Company Officer must edit the existing FCC Form 498, navigate to “Federal FEIN, DUNS, FCC Registration Number (CORES ID), and SAM.gov UEI,” enter the UEI, click “Verify,” and then review and certify the form.
    • For E-Rate Applicants (in EPC): A School or Library Official with appropriate permissions must modify the FCC Form 498 through the Records tab, navigate to the “Organization Numbers” page, enter the UEI, click “Verify,” and re-certify the form.

    Changes to the FCC Form 498 typically process in 2-3 business days.

    Current Status

    • FY2026 FCC Form 470s filed: 22,663
    • FY2026 FCC Form 471s filed: 19,500
    • FY2025 Wave 45 Funding Commitment Decision Letters (FCDLs) released: March 12, 2026
    • FY2025 commitments total: Over $2.61 billion as of March 18, 2026