FCC Adopts E-Rate Competitive Bidding Portal and Provides Additional Guidance on Program Rules
May 22, 2026
Per USAC’s March 21st News Brief, the FCC adopted a Report and Order and Order on Reconsideration (FCC 26-30) on April 30, 2026, to strengthen E-Rate program integrity by creating a competitive bidding portal, streamlining program rules, and clarifying rules for transitioning services, cost allocations, and competitive bidding. In future funding years, it also eliminates the FCC Form 486 (Receipt of Service Confirmation and Children’s Internet Protection Act (CIPA) Certification Form) and moves that form’s CIPA certifications to the FCC Form 471. Some of the key changes are highlighted below.
Competitive Bidding Portal:
The order establishes a competitive bidding portal for FY2028 that will require prospective service providers to submit bids in the USAC-managed portal and will require applicants to upload bid evaluation and vendor selection documentation, including contract(s), after selecting service providers. The portal will also serve as a document repository for applicants and service providers, thereby reducing recordkeeping burdens. The FCC will require that the portal be used for competitive bidding communications, with exceptions based on local/state law requirements, and directs USAC to create a process for bidders to submit questions (with an option to submit anonymously) and for applicants to respond through the portal so all bidders may see the questions asked and the responses provided.
The portal will take effect for Funding Year 2028, with applicants able to begin competitive bidding through the portal on or around July 1, 2027, coinciding with the release of the FY2028 Form 470.
Please be aware that the bidding portal will have an impact on PEPPM and mini-bids. Updates will be provided as we work through the process.
For Funding Year 2027, nothing changes. Form 470 postings, competitive bidding requirements, and filing deadlines will work the way they always have.
Additional Guidance on Program Rules:
In addition to announcing the bidding portal, the Order also directed USAC to create a process for applicants transitioning services to file a post-commitment request that changes the service start and end dates and, if the applicant meets certain criteria, permits increases in the commitment amount. USAC may approve a post-commitment increase if the applicant filed partial funding year requests for funding from both service providers (or service offerings, in the case of a transition to a different service from the same service provider) during the application filing window using the best estimates of the transition dates, indicated on the FCC Form 471 that the requests were for a transition of service, and if there are available funds below the E-Rate program funding cap. This process will require changes to forms and will take effect in a future funding year after approval by the Office of Management and Budget (OMB).
For cost allocations, the FCC clarified that the ancillary use presumption explained in FCC 26-30 applies to all Category One (C1) services, including data transmission services, wide area network services, Ethernet, etc. That is, if at least 90% of an applicant’s requested recurring C1 service will be used for an eligible purpose during the funding year, the remaining ineligible use of the C1 service at eligible locations will be presumed to be ancillary, and cost allocation is not required.
The FCC also provided a limited exception to the competitive bidding rules so applicants can submit a service substitution request to increase bandwidth during the funding year at the existing commitment amount (i.e., total price of the current bandwidth service). Applicants would be responsible for any costs over the existing commitment amount. The applicant would need to file a new FCC Form 470 and seek competitive bids for the increased bandwidth service to continue receiving the service for the next funding year.
The FCC also removed the requirement that applicants file the FCC Form 486 for future funding years, beginning in FY2028, and directed USAC to transfer the CIPA compliance certifications to the FCC Form 471. The FCC noted that applicants with open commitments or approved appeals from prior funding years will continue to use the FCC Form 486 to certify CIPA compliance. Note: You will be required to file the FCC Form 486 in FY2026 and FY2027.
The FCC eased certain restrictions around the invoice filing deadline including allowing applicants and service providers to request a single 120-day extension of the original invoice filing deadline from USAC if the request is made within 15 days of the original invoice filing deadline and providing for a one-time, 60-day grace period for applicants and service providers to resubmit corrected versions of invoices that were timely filed before the invoice filing deadline but rejected by USAC.
I know this is a lot of information to take in. Stay tuned for more information to come, and we will certainly be doing a deep dive during training this upcoming fall.
Take care, and I wish you well during the Memorial Day weekend.
Lorrie
Lorrie Germann
Pennsylvania E-Rate Coordinator
717-576-2737 – o
lgermann@e-ratepa.org
www.e-ratepa.org