Category: E-Rate Updates

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.

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