August 2025 E-rate Update
August 13, 2025
Happy August, E-raters! Below are several E-rate updates and reminders…
- Important – Timing of FY 2026 PEPPM Mini-Bids: If you intend to use the PEPPM Mini-bid system as the procurement vehicle for your FY 2026 Category 2 equipment purchases, NOTE THAT YOU CANNOT RELEASE A PEPPM MINI-BID TO VENDORS UNTIL AT LEAST JANUARY 2, 2026. The reason is that the current PEPPM contract expires at the end of 2025 and the next contract will not become available for use until January 2, 2026. Thus, no mini-bids can be issued to (what will be) the newly awarded vendors until at least that date. The Form 471 filing deadline is expected to be mid-late March, which means that, assuming your PEPPM procurement is conducted in early January, your C2 contracts will have to go to your school boards in late January or February.
- Virtual School Eligibility: We know several PA school districts have established virtual schools, for which often have a brick and mortar building that provides teaching, classes, labs, etc. Because students attending these schools have their data reported with their home schools within the district, there are no state reports that can be provided to PIA to meet their validation requirements. If you are in this situation, please let me know and I can provide you with a memo from PDE that provides the legal rationale to explain that these schools meet the definition of elementary or secondary school in PA.
- FY 2026 Form 470 Now Available: The E-rate Funding Year 2026 Form 470 is now available if you would like to begin your procurements early. There have been no changes made to the form. The FY 2026 eligible services list will be released later this fall (usually December).
- FY 2026 is First Year of New Category 2 Budget Cycle: In June, the FCC announced the budget multipliers and minimum building amounts for the upcoming FY 2026 – FY 2030 Category 2 Budget Cycle. They are:
| FY 2026 – 2030 | |
| Per Student (Schools) | $201.57 |
| Per Sq. Ft (Libraries) | $5.43 |
| Minimum/Building | $30,175.00 |
Applicants will be required to validate their student counts or library square footage in the first year they apply for C2 funding during the FY 2026 – 2030 cycle after which their C2 budget will be set for the five-year budget cycle. For example, if you don’t apply for C2 in the next budget cycle until FY 2027, USAC will validate your C2 enrollment at that time and it will then be set for the remainder of the cycle, ending FY 2030. Of course, if your enrollment increases in the remaining years of the budget cycle, you may submit increased enrollment data and ask USAC to perform a budget recalculation. C2 enrollments are updated during the annual “Administrative Window” which typically occurs between mid-October – early January. Training will be conducted this fall to explain how and when to update your C2 enrollment for FY 2026.
- Status of FY 2025 Funding Commitments: As of August 13, 84% of PA funding requests have been decided. PIA continues to actively review applications so if your application has not yet been decided, be checking your e-mail for PIA inquiries. If you need assistance with understanding the PIA review process or where to find the PIA reviewer’s questions, please see: PIA-Review-Guide-FY-2025.pdf. If you need assistance with responding to a PIA inquiry, please e-mail me. If you have an application still pending and have not received any PIA inquiries, or it’s been 60+ days since your last PIA correspondence, please send me your Entity Name, BEN, 471 #, and last date of PIA correspondence (not including Wi-Fi- hotspots or school bus Wi-Fi FRNs – see below).
- Off-Campus Wi-Fi Hotspot Eligibility Update: On May 8, the U.S. Senate passed S.J. Res. 7 to overturn the FCC’s decision to allow E-rate funding to be used for Wi-Fi hotspot lending by schools and libraries. However, the measure has not been passed by the U.S. House. It appears that USAC is not actively reviewing or funding/denying the applications, for which PA has 16 pending FRNs. I will keep you updated if there is further action on the eligibility of Wi-Fi hotspots.
- Update on School Bus Wi-Fi Applications/Eligibility: PA has 9 school bus wi-fi funding requests pending and although school bus wi-fi is technically eligible for E-rate funding in FY 2025, it does not appear that these applications are being reviewed and/or funded to date. In June, when the Supreme Court ruled that USF was constitutional, the SC majority included a sentence in their Opinion related to another suit brought by plaintiffs who were seeking to reverse the FCC’s Order of October 2023 (FCC 23-84) that made school bus Wi-Fi services eligible for E-Rate discounts. The sentence read: “We accordingly reverse the judgment of the Court of Appeals for the Fifth Circuit and remand for further proceedings consistent with this opinion.” In other words, the Supreme Court did not address the more specific issue of the eligibility of school bus Wi-Fi but sent it back to the Fifth Circuit Court. In July, both the petitioners and the FCC asked the Fifth Circuit to hold the case in abeyance pending the FCC’s review of the initial school bus Wi‑Fi Order, stating that only one Commissioner, Anna Gomez, had initially voted to approve the bus Wi-Fi measure. The current FCC majority, “is reevaluating the agency’s past actions” including school bus Wi-Fi eligibility. The Fifth Circuit granted the abeyance request subject to the condition, proposed by the FCC, that the FCC file a status report 90 days from the date of the order and every 90 days thereafter until such time as the order is lifted or the court gives further direction. I will keep you posted on this issue, but all signs seem to point to Off-Campus Hotspots and School Bus Wi-Fi no longer being eligible in FY 2026.
- Error Messages Logging in to EPC: I know applicants are still receiving this error message when logging into EPC: “AuthSDKError: Unable to parse a token from the URL”. USAC continues to try to resolve the error, but in the meantime, the best resolution is to simply hit your browser’s BACK button if you receive this error message.
- FY 2024 and FY 2025 BEAR Reimbursement Filings: Starting July 1, 2025, applicants can begin to submit BEARs for FY 2025 equipment purchases that were made on or after April 1, 2025 (service providers can also submit FY 2025 SPIs on or after this date). This is also about the time when applicants who did not receive discounted vendor bills for FY 2024 recurring services will begin to submit those BEARs as well, with a deadline of October 28, 2025 . The Form 472 BEAR Filing Guide is available at: https://e-ratepa.org/?p=36027. Deadline to file BEARs for FY 2024 recurring service reimbursements is October 28, 2025.
- Fall E-rate Trainings: Registration for fall E-rate trainings will be announced soon!
Reminders:
- File Your FY 2025 Form 486: The next step after receiving a FCDL (funding commitment decision letter) is to file the Form 486. It’s a very easy form to submit and I strongly encourage you to file it on the day you receive the FCDL so you don’t forget. Two reminders: Check the ‘Early Filing Box’ if filing the 486 before July 31, and be careful not to be “click happy” on the CIPA certifications. Full instructions on the Form 486 can be found at: Form-486-Filing-Guide-FY-2025.pdf. I’ll send out a 486 reminder in a few weeks with the list of applicants that haven’t yet filed.
- Label and Inventory Category 2 Equipment: If you applied for Category 2 discounts this year, don’t forget to label the equipment before it’s installed, and add the equipment to your asset inventory. For more details on these requirements, in addition to other C2-related issues, please review the Category 2 Purchasing Guide, available at: Equipment-Purchasing-Guide-FY-2025.pdf.
- Request Discounted Bills: Be sure to tell your vendors if you want to receive discounted bills where the vendor then seeks reimbursement. If you prefer to pay your vendor invoices in full and then submit the Form 472 BEAR to seek reimbursement, that’s your option, but you must stick with one invoicing method or the other for the entire funding year for each FRN.
- Changing EPC Account Administrators/Adding New EPC Users: Summer often brings staffing changes and it’s important that the new staff get set up in EPC so they are prepared to file E-rate forms as soon as they’re due. Hints: Only AA’s can create new EPC user accounts and assign User ‘permissions.’ Only AAs can transfer their AA ‘credentials’ to another existing EPC User. If the AA is the new staff member and the previous AA is no longer with the school or library, contact CSC at 888-203-8100 and they will set up a new EPC AA account (only CSC can do this). For a complete guide on how to add/remove EPC users, or change AAs, see: EPC-How-To-Guide-as-of-Nov-2024.pdf. Also, if you need any new E-rate contacts added to the PA E-rate Listserve, please e-mail me their contact information.
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org