Category 1 Form 470/Bidding and Eligible Services
November 21, 2025
Hello E-Rate Community, and Happy Friday!
I would like to share with you a few updates and reminders regarding Category 1 eligibility and the Form 470 for FY2026.
~ C1 Eligibility and Form 470 Filing Guide Available ~
~ Understanding Form 470 Options ~
~ List of PA Applicants that May Need to File 470 for Recurring Services Available ~
The Form 470 marks the start of the FY 2026 funding year because it opens the competitive bidding process for equipment and services that aren’t yet under contract for FY 2026 (July 1, 2026 – June 30, 2027). On the Form 470, schools and libraries identify and seek proposals for the products and services they need, and for which they will be requesting E-Rate discounts, so that potential service providers can review those requests and submit proposals to you for consideration. An updated Form 470 Filing Guide for Category 1 services, which provides complete step-by-step screenshots showing how to complete the Form, is available at: FY2026-Form-470-Workshop-Cat-1.pdf.
Changes to FY 2026 Category 1 and Form 470
- Off-campus hotspots and related mobile wireless Internet services, along with school bus Wi-Fi, are no longer eligible for E-Rate funding. However, the services have not been removed from the Category 1 service list on the FY2026 Form 470.
- As a reminder, the Form 470 has the functionality to allow RFP documents to be uploaded to an existing Form 470, even if no RFP document was originally uploaded. The system will also ask if this is a substantial change. If you answer yes, the system clock will reset and extend your Allowable Contract Date by an additional 28 days. Note: USAC considers most changes to a Form 470 or RFP a substantial change. Find 470 > Related Actions > Add RFP Document.
- Functionality has also been added in EPC to allow you to cancel an existing Form 470 as long as it has not yet been cited on a funded Form 471. Find 470 > Related Actions > Cancel Form 470.
FY 2026 Eligible Category 1 Services
The FY2026 Eligible Services List (ESL) has not been released yet, but we do not anticipate any changes to the Category 1 eligible services. The FY 2026 Form 471 filing dates have not yet been announced, but they are expected to be similar to those of last year, which ranged from early January to mid-late March.
Note: If you are considering bidding Leased Dark Fiber (where you lease and light strands yourself) or Self-Provisioned Fiber (build your own network), please be sure to review the E-Rate rules related to the extra bidding requirements for these two services at: https://www.usac.org/e-rate/applicant-process/before-you-begin/fiber-summary-overview/ and let me know if you have any questions before bidding.
Understanding Which Form 470 Options to Select
The Form 470 services you’ll see are determined by your selections to multiple levels of options. They are designed to be descriptive options with progressive disclosures for Category 1 (meaning the form takes you to additional levels of questions, depending on the options you select). To make the options a little more understandable, the Form 470 Filing Guide located at FY2026-Form-470-Workshop-Cat-1.pdf contains screenshots of the form with plain language annotations to help you select the appropriate option(s) – see slides 24-32.
When Must a Form 470 be Filed?
- If a service is covered on a Month-to-Month basis (meaning no contract), a new Form 470 is required annually (unless using the CABIO option). To learn more about CABIO and whether your services qualify, see: CABIO-Bidding-Exemption-Guide-FY-2026.pdf
- At the beginning of any new contract. Note: If you posted a Form 470 in a previous year and then signed a multi-year contract that expires on or after June 30, 2027, you are not required to file a Form 470 for FY 2026. If you wish to exercise a voluntary extension of a contract without posting a 470, you may only do so if your original contract contains the terms of the voluntary extensions (meaning the exact number of years or dates that the extensions can be exercised, and it’s not just open-ended). Otherwise, you must post a Form 470 to extend the contract.
- If you’re upgrading bandwidth mid-contract and the upgrades and associated prices are not included in the original contract (or making any other significant changes to your original contract).
Who Must File a Form 470 for FY 2026
Based on the contract expiration date that you listed on your FY 2025 Form 471 and whether you indicated in the Contract Record whether the original contract contained optional extensions, I’ve created the “FRN Rebidding Status for FY 2026 C1″ spreadsheet located at FY2026-C1-Bidding-Status.xlsx
If you see that your contract expiration date (CED) is not accurate on the list, it likely means you entered it incorrectly on your FY 2025 Form 471. If this occurred, simply use the correct CED on your FY 2026 Form 471, and if PIA asks about the change, you can provide them with a copy of your contract showing the correct CED. Alternatively, you can create a new Contract Record with the corrected dates and cite to that when creating your Form 471.
Form 470 RFPs:
I encourage you to issue an RFP with your Form 470 to describe the services you want, address locations where circuits should terminate, minimum requirements for vendors, and possible disqualification factors, even if the RFP is just one page. Important: When any of the services or locations change, or if you provide additional, substantive information to bidders, you must provide this to all bidders using an RFP addendum, and then be sure that the bid due date is at least 28 days after the posting of that new information.
Deadline to File Form 470s
Although the very last possible date to file a Form 470 is 29 days before the Form 471 application filing window closes, do not wait this long to file. I encourage everyone to file their 470s by Thanksgiving, if possible. You will then receive vendor questions/proposals during the month of December, can evaluate your bids and select your vendors in January, have your board approve contracts in January or February (if required by local policy), and then sign your contracts and file your 471 in late February or early March.
Important Requirements/Reminders:
- List bid due date in Form 470 or RFP. If such a deadline isn’t stated, you must consider all bids received up until the date you conduct your bid evaluation. Therefore, I strongly recommend that all Form 470s/RFPs include a vendor proposal due date (be sure that this date is at least 29 days from the date this Form 470 is posted).
- All disqualification reasons must be stated on the Form 470 or in the RFP and must be able to be answered yes or no.
If you are using an RFP in addition to your Form 470, you must upload the RFP with the 470, AND upload any additional documentation given to bidders during the bidding process. If any of the new documentation materially changes the services being bid or entities served, you must ensure the deadline to submit bids is at least 28 days after the RFP addendum is uploaded into EPC. In light of this, you may also wish to add 2 weeks to the 28-day clock to allow for initial vendor questions (set a deadline for those questions and then upload the answers with the RFP).
- Installment Payment Plan with Vendors
If you would like to spread out the non-discounted (the applicant’s share) amount of the cost of special construction (installation), you must indicate so on the 470 under the ‘Payment Installation Plan’ section located beneath the narrative box.
- Use State/Local Procurement Requirements Narrative Box
This is the space where you place instructions on bidders, such as the final date to submit bids (must be at least 29 days after 470 filing date), where to submit bids, in what format, if references are required, if vendors must have SPIN numbers, if you require discounted bills, etc. Use this space wisely!
Hints for Form 470 Last Steps:
- Viewing Draft 470 Before Filing
At the end of the form, the system will prompt you to select ‘Review 470’ and indicate that it’s generating the PDF. To see the PDF, you must click on ‘Refresh’ until it appears. The PDF will not appear unless you click Refresh (and sometimes it takes up to 30 seconds to appear). Review the draft, and if you want to make changes to the form, click ‘Back’ to re-enter the form. To submit, check the certification box, and then ‘Continue to Certification’ to proceed with the certification/submission.
- Obtaining a Final, Submitted Copy of Your 470
After you’ve “certified” your Form 470, it’s often difficult to find a final copy. At the bottom of your Landing Page (home), scroll to the bottom where it says FCC Forms and Post-Commitment Requests. Select ‘Form 470’ and the funding year. Then click on the 470 Nickname that you gave the form, and it will show you a summarized version of the 470. To download an actual copy, click on ‘Generated Documents’ on the top toolbar, and then ‘Original Version.’
It’s important that you begin the Form 470 bidding process as soon as possible so you don’t run out of time during the Form 471 application window. If you have any questions about filing the Form 470, please email me at lgermann@e-ratepa.org. BTW, if you have
n’t already, please add my email address to your safe list to ensure you receive my replies.
Sincerely,
Lorrie–
Lorrie Germann
Pennsylvania E-Rate Coordinator
717-576-2737 – o
lgermann@e-ratepa.org
www.e-ratepa.org