FAQs

Yes. Beginning in FY2016, costs related to applicant-owned WANs will be eligible for Category One support. In the Second E-Rate Modernization Order, the Commission established a mechanism for applicants to seek Category One support for self-provisioned networks when self-provisioning is the most cost-effective option to meet their connectivity needs. Consistent with that decision, the Commission eliminated a prior rule that prohibited E-Rate support for applicant-owned WANs. As a reminder, lease arrangements for non-exclusive access to service provider WANs have long been eligible for Priority One/Category One support through the Schools and Libraries (E-Rate) program.

For broadband, connections forming a data network between multiple eligible schools or libraries are WAN connections for the purposes of the E-Rate program. WAN connections do not include connections between or among multiple buildings of a single school campus or single library branch. Such connections are Category Two internal connections under the E-Rate program rules.

The classification of connections between multiple buildings of a single school is determined by whether the buildings are located on the same campus. A “campus” is defined as the geographically contiguous grounds where the instructional buildings of a single eligible school are located. A single school may have multiple campuses if it has instructional buildings located on grounds that are not geographically contiguous. Different schools located on the same grounds do not comprise a single campus. The portion of the grounds occupied by the instructional buildings for each school is a campus for that school.

Category One Classifications:

• Connections between buildings on different campuses of a single school are considered to be Category One digital transmission services.
• Connections between different schools with campuses located on the same property (e.g., an elementary school and middle school located on the same property) are considered to be Category One digital transmission services, unless they share the same building.

Category Two Classification:

Connections between buildings of a single school on the same campus are considered to be Category Two internal connections.

Yes. Under the rules adopted by the Second E-Rate Modernization Order, connections installed between two or more schools or libraries are eligible for Category One support, irrespective of whether the schools are located on the same campus.

Take, for example, a high-rise building with three different schools located on three different floors. As one option for meeting their connectivity needs, the three schools consider constructing a network that connects their facilities on different floors of the building, with a single connection running out to a service provider’s point-of-presence (PoP). That configuration would be a WAN for the purposes of the E-Rate program. The costs associated with installing the connection running out to the PoP and between the three schools within the building would be eligible for Category One support. Similarly, a connection between a middle school and high school located on the same campus would be eligible for Category One support.

No. Before the Modernization Orders, the E-Rate program’s definition of “internal connections” included a rebuttable presumption that a connection that crossed a public right-of-way was not an internal connection. The purpose of that rebuttable presumption was to distinguish between connections that may be eligible for what was formerly called Priority Two support as part of an applicant’s LAN from those that would not be eligible for E-Rate support at all because they were part of an applicant-owned WAN.

Now that applicant-owned WANs are eligible for Category One support, there is no need for that distinction. In fact, the E-Rate Modernization Order removed the rebuttable presumption and the reference to a public right-of-way from the definition of internal connections altogether.

The Commission now defines internal connections as services “necessary to transport or distribute broadband within one or more instructional buildings of a single school campus or within one or more non-administrative buildings that comprise a single library branch.” (47 C.F.R Section 54.500)

In short, the classification of a connection as a Category One or Category Two service turns on the function of the connection, i.e., whether it is part of a WAN connecting multiple eligible schools or libraries, or whether it distributes broadband within a single school campus.

Correct. The connections between the instructional facilities located on different floors of the high-rise building would distribute broadband within a single school campus. They would, therefore, be internal connections eligible for Category Two support.

Yes. The connections installed between the buildings on either side of the public right-of-way would distribute broadband to the instructional buildings of a single school campus, and would be internal connections eligible for Category Two support as opposed to WAN connections eligible for Category One support.

No. Internal connections distribute broadband within one or more instructional buildings of a single school campus, or within one or more non-administrative buildings that comprise a single library branch. Connections that distribute broadband to buildings of a single school located on multiple campuses located miles apart would not be internal connections, and may be eligible for Category One support.

There will no longer be support for any voice services.

Data plans and air cards for mobile devices, whether requested separately or as part of a cellular bundle, will continue to be eligible for E-Rate program support only in instances when the school or library seeking support demonstrates that individual data plans are the most cost-effective option for providing internal broadband access for mobile devices at schools and libraries, such as for library bookmobiles or for some schools or libraries serving very small numbers of students or patrons.

No, you cannot receive E-Rate program support for fully phased out or ineligible services even if they are still under contract.

Mobile broadband connectivity for school buses is eligible as a Category One service starting in FY2024.

The Wireless bullet on the ESL was modified to clarify this new eligibility.

From: “Wireless (e.g. fixed wireless, microwave)”

To: “Wireless (e.g., fixed wireless; microwave; or mobile service for use on school buses)”

Installation Fees and Equipment needed to make this wireless service for school buses functional are also eligible under Category One.

Separate maintenance and operations services related to mobile broadband connectivity for school buses are not eligible.

School bus Wi-Fi services are eligible for buses that are school-owned, as well as leased or contracted school buses, provided that the school buses are used primarily to transport students to and from school or school-related activities for educational purposes as defined by FCC rules. Occasionally used chartered buses (e.g., used for school field trips), municipal, or city buses are ineligible. Other types of school-owned vehicles (e.g., cars and vans) are also ineligible, even if a school replaced all school buses with vans and now only uses vans to transport students.

Equipment and services must primarily be utilized for educational purposes as defined by E-Rate rules. Content and network restrictions should be implemented consistent with those placed on building-based broadband networks. This includes, but is not limited to, Acceptable Use Policies (AUPs) and other school policies that limit network access and Children’s Internet Protection Act (CIPA)-required content filtering capabilities. Wi-Fi should only be active during school bus normal operating hours (i.e., when students are being transported to and from school or school-related activities) or when there is a clear educational purpose for enabling school bus Wi-Fi connections outside of these hours. Bus Wi-Fi service must be disabled outside of these hours and cannot be utilized for community use purposes. 

Bus security cameras are ineligible for E-Rate support. Similarly, service dedicated to a security camera’s use is ineligible.  Regarding the incidental service use by a security camera, in FCC 23-56, paragraph 26 provided clarification and the FCC adopted a presumption that if at least 90% of an applicant’s requested Internet service is being used for eligible purposes (here, school bus Wi-Fi used for educational purposes), the remaining ineligible use of the Internet service will be presumed to be ancillary and cost allocation would not be required.

Schools may situationally enter into agreements with multiple providers such as when to the extent that some buses are served by one provider, and other buses by a different provider. Buses in rural areas may be more likely to cross between service areas of multiple service providers along the same bus route. Rural applicants may select a solution that allows a bus to be served by multiple providers. However, such schools still must select the most cost-effective service offering(s) using price of the eligible equipment and services as the primary factor consistent with program rules. Schools and school districts can check their urban/rural status here.

School bus Wi-Fi is subject to all existing E-Rate rules and requirements, including those related to competitive bidding, cost allocation, and discounting rules. Applicants who entered into multi-year agreements for Bus Wi-Fi in the Emergency Connectivity Fund (ECF) program are not exempt from competitive bidding requirements. Service provider selection must be consistent with E-Rate program rules including selecting the most cost-effective service offering(s), and using price of the eligible equipment and services as the primary factor in the evaluation matrix.

USAC released an article on how to seek bids for Wi-Fi on school buses in FY2024, available here.

Because the FY2024 FCC Form 470 has not changed since USAC posted it in July 2023, applicants seeking bids for Wi-Fi on buses should use the following drop-downs:

• Select “Category 1 -– Data Transmission and/or Internet Access” in the Service Requests section under Category(s) of Service.  
• You will be required by EPC to upload a Request for Proposal (RFP) document, so select YES under RFPs for Service Requests.  
• Add a narrative (e.g., “Applicant seeks bids for wireless school bus service and (if applicable) associated equipment to make the service functional to provide Wi-Fi.  Reference the associated “RFP” document for additional information.”).
• Add a new service request, selecting the following EPC guiding statements in sequential order:
  • I seek bids for internet access and/or data transmission service.
  • I seek bids for Internet access and data transmission service (provided over any combination of transmission medium, e.g., fiber-only networks, fiber/non-fiber hybrid networks, or non-fiber networks such as cable, DSL, copper, satellite, or microwave).
  • I seek bids for data plans or wireless adapters (Air Cards) for mobile devices for commercial wireless service for a school or library that does not have an existing broadband internal connections.
• Provide remaining details like quantity and entities.

Footnote 55 in the FY 2024 ESL Order notes that portable school bus Wi-Fi equipment is only eligible when used on a school bus for educational purposes (e.g., transporting students to and from school and school-related activities).  Portable school bus Wi-Fi equipment includes portable routers, but excludes Wi-Fi hotspots.

Paragraph 12 in the FY 2024 ESL Order explains that the school bus Wi-Fi may be used for educational purposes.  “[W]e permit applicants to enable E-Rate-funded school bus Wi-Fi connections during a school bus’s normal operating hours (i.e., when students are being transported to and from school or school-related activities) or when there is a clear educational purpose for enabling school bus Wi-Fi connections outside of these hours.”  Two examples of parked school buses being used for educational purposes are when a school uses the Wi-Fi connections to allow parents to participate in virtual parent-teacher conferences or when a school bus is used to provide Internet service to students in the face of an unexpected network outage that would impact students’ ability to complete school homework assignments.

The installation costs for school-owned bus Wi-Fi equipment to be moved from the existing bus transportation company’s school buses and installed on new bus transportation company’s school buses are eligible.  The FCC will be monitoring these costs and may make modifications in the future regarding these types of costs associated with changing school bus transportation companies.

Eligible schools and libraries are able to receive support for Wi-Fi hotspot equipment and services for off-premises use by students or library patrons.

Schools may not distribute Wi-Fi hotspots to ineligible Head Start, pre-kindergarten, and kindergarten populations. 
 

Consistent with Category Two budgets, virtual students are eligible for Wi-Fi hotspots and can be included in the budget count if they are enrolled at a brick-and-mortar school.

No.

No. According to paragraph 32 of FCC Order 24-76, the E-Rate program prohibits using Wi-Fi hotspots as part of a one to one (1:1) hotspot initiative, where every student receives a Wi-Fi hotspot. Generally, applicants are prohibited from seeking E-Rate support for a 1:1 hotspot initiative and will be required to certify on the FCC Form 471 application that the hotspots and service will not be used for a 1:1 hotspot initiative. If E-Rate-funded Wi-Fi hotspots are effectively used as part of a 1:1 initiative – either in practice by providing all of the devices to a single school in the district or in conjunction with Wi-Fi hotspots funded via other sources, applicants must document clearly (i.e., individual survey results or attestations) that each individual student needed a Wi-Fi hotspot, in accordance with the applicants’ AUPs, and may not rely on general or estimated findings about income levels. Funding disbursements for applicants without specific documentation to support a 1:1 Wi-Fi hotspot initiative will be subject to denial and/or recovery.

ECF or other federally funded Wi-Fi hotspot contracts are not grandfathered, but applicants may seek competitive bids for services to be delivered via ECF or other separately funded Wi-Fi hotspot devices. If an applicant has a preexisting service contract, they are required to seek competitive bids, wait at least 28 days, use price of the eligible services as the primary factor, and enter into a new contract with the selected provider (which can be the existing provider). See Q57 and DA 24-1287 for more details about considering an existing service contract as a bid when competitively bidding for the Wi-Fi hotspot service. 

The hotspot budget is the maximum amount of pre-discount funding permitted for Wi-Fi hotspots and/or service over three funding years. This is a fixed budget, meaning that once it’s been established, it will not change over the course of the three-year cycle, regardless of if the input changes (students, square footage, Category One discount). Please see our Wi-Fi Hotspots Infographic.

Your discount rate is the Category One discount percentage for the funding year when an applicant first applies for Wi-Fi hotspots and services. For more information on how to calculate your discount percentage, see the Calculating Discounts FAQs.

Your most recently verified Category Two data (full-time student count or square footage) during the funding year that an applicant first applies for Wi-Fi hotspot equipment and services is used to calculate the Wi-Fi hotspots budget.

Yes. If the Category Two budget student enrollment includes kindergarten students (or pre-k/Head Start in eligible states), they are counted for determining the hotspot budget. However, those students are ineligible to receive a Wi-Fi hotspot funded through E-Rate.

This means that the applicant is limited to requesting a maximum of 45% of their three-year budget in any particular funding year. For example, an applicant that has a budget of $63,000 would only be able to request discounts on costs up to $28,350 in any single funding year. Even if the applicant first applies in the third year of its budget, they are still restricted to requesting 45% of their budget.

There is no funding floor for the Wi-Fi hotspot program. However, each entity will be eligible for at least 10 Wi-Fi hotspots and service lines (i.e., $6,300 pre-discount hotspot budget). 

In the hotspot budget calculation, the value in the brackets [product of A. student count/square footage, B. multiplier, and C. discount rate] always rounds up to the nearest ten before it is multiplied by $630.  

Below are some examples of hotspot budget calculations, broken down into each factor of the calculation and step of the equation.  

There are three constraints of the Wi-Fi hotspot initiative to limit funding and allow for the equitable distribution of Wi-Fi hotspots and services to students, school staff, and library patrons, and to ensure cost effectiveness. These constraints are (1) a set budget, (2) annual request limits (the applicant must not request more than 45% of their budget in one year), and (3) funding caps on equipment and services ($15 per month for the wireless service and $90 per Wi-Fi hotspot). Applicants can use their budget at their own discretion as long as it does not exceed the capped amounts and subject to the annual request limit. In other words, the budget calculation is not contingent upon what you purchase.

Applicants are free to purchase equipment and services that cost more than the funding caps, but applicants are responsible for the amount that exceeds the funding caps. For example, if you purchase an Internet access line for $20 per month for your Wi-Fi hotspot, and you have a 90% discount rate, USAC will cover the capped amount, and you are responsible for 100% of that difference. In this case, that means USAC would pay $13.50 ($15 x 90% = $13.50), and you would pay the non-discounted share ($1.50) plus anything over the $15 cap (i.e. $5.00) for a total of $6.50 per month.

For E-Rate purposes, the remaining applicant costs can come from another funding source, federal or otherwise, provided the funding is not coming from the service provider. 

Applicants that select lower-cost Wi-Fi hotspots and/or services, or that find ways to maintain Wi-Fi hotspots for longer, will be able to request a larger quantity of E-Rate supported hotspots or lines of service depending on their individual needs and budget.

Entities must request E-Rate support based on actual, commercial-based costs. Service providers will be required to certify that the costs of the Wi-Fi hotspots do not exceed commercial value. Note: USAC may modify, reduce, and/or recover funding requests that are determined to be higher than the actual, market-based price of commercially available Wi-Fi hotspots. 

Yes, applicants must certify that E-Rate-funded hotspots will be used primarily for education purposes. Additionally, applicants are required to maintain/update their acceptable use policies (AUPs) to clearly state that off-premises use must be primarily for an educational purpose. Applicants are also required to certify on the FCC Form 486 that these requirements have been met and must be able to demonstrate compliance, if asked.   
 

No, applicants cannot purchase hotspots in anticipation of future use, loss, or breakage. Applicants must certify to their compliance with this limitation on the FCC Form 471 application. In the event of loss or breakage, applicants may purchase extra devices with other sources of funding to use with the E-Rate-supported service, or they can request devices in the next funding year within their budgets, if devices need to be replaced. 
 

Wi-Fi hotspots will not be considered warehoused so long as the school or library activates the Wi-Fi hotspot device, makes it available for loan, and publicizes the availability of the Wi-Fi hotspots and service to students, school staff, and library patrons via public notice or other means. Wi-Fi hotspots that have not been made available for distribution per these requirements (e.g., if they are never turned on, never publicized, stored in an office, still in the box) will be considered to have been warehoused, and the entity may be subject to a financial recovery. See FCC Order 24-76, paras. 55, 58. 
 

The details of such a hotspot lending program—such as length of lending periods and how to target the appropriate students and library patrons—will be left to the applicant to determine and tailor the hotspot lending program to their local needs. Entities should structure a lending program in a way that maximizes use of Wi-Fi hotspots and services following the requirements adopted in the Order (FCC 24-76). Such measures to encourage use may include limited lending periods (e.g., 21 days or less). 
 

Applicants that know that Wi-Fi hotspots will not be used are encouraged to work with their service providers to pause service. The FCC prohibits E-Rate support for lines of service that have not been used for approximately three consecutive months (90 days). Specifically, after 60 days of non-usage, service providers are required to provide 30 days’ notice to the applicant before terminating the unused line of service. This approach appropriately accounts for limited, legitimate instances of non-usage, such as a school’s summer break, while also providing sufficient time to allow schools and libraries to work with their service provider, as well as their student, school staff, and library patron users to remedy the non-usage without being unnecessarily penalized. Service providers may not bill the applicant during this non-usage period. 
 

Applicants may work with their service provider to restart services that have been terminated (e.g., where a hotspot is redistributed) once per funding year. However, applicants that take such action to restart service after termination will be subject to program integrity reviews and therefore, applicants should take steps to ensure that they have the associated need prior to restarting services terminated for non-usage. 
 

In the event of a terminated line of service resulting from the non-usage requirement, service providers are prohibited from billing the applicant for the balance that was not paid for by the E-Rate program. Service providers will be required to certify on their FCC Form 473 (Service Provider Annual Certification (SPAC) Form) that they will comply with this non-usage notice and termination requirement and will not charge applicants the balance for the terminated services. 

For each Wi-Fi hotspot, applicants are required to maintain an asset and service inventory that identifies:  1) the equipment make/model;  2) the equipment serial number;  3) the full name of the person to whom the equipment was provided (for schools only) (Note: Entities may anonymize or deidentify any personally identifiable information when producing asset and service inventories); 4) the dates the equipment was loaned out and returned, or the date the school was notified that the equipment was missing, lost, or damaged; and 5) the service detail (i.e., a phone number or unique identifier for the line of service).   
 

No. However, both schools and libraries are required to adopt and provide notice to the Wi-Fi hotspot recipients of an acceptable use policy (AUP) that highlights that the goal of the hotspot lending program is to provide broadband access to students and library patrons who need it. Per FCC Order 24-76, it is up to the schools and libraries themselves to determine who should be getting hotspots and how people should request them. This approach will not require applicants to document whether a particular student, school staff member, or library patron has unmet need. However, there is an exception for one-to-one initiatives (see Question 26). 

A) For recurring mobile wireless Internet services, select “I seek bids for wireless Internet services that can be delivered with a Wi-Fi hotspot for off-premises use.” This can be found under: “I seek bids for internet access and/or data transmission service.”  

B) For Wi-Fi hotspot devices, select “I seek bids for Wi-Fi hotspots for off-premises use.” This can be found under: “I seek bids for Category One network equipment or maintenance and operations.”

No, off-premises Wi-Fi hotspot devices and associated service lines may be requested on the same FCC Form 471. However, for ease of administration and to streamline review of funding requests, Wi-Fi hotspots, services, as well as any eligible components or fees should be requested on separate funding line items when seeking support for these equipment and services, and applicants and service providers should itemize eligible components when invoicing. Additionally, off-premises Wi-Fi hotspots and services should be requested on a separate FCC Form 471 from requests for on-premises Category One and Category Two equipment and services. 
 

No, but applicants should ensure they provide sufficient information for potential service providers to bid, such as the anticipated service area. 

CIPA applies to school- or library-owned computers if the school or library receives E-Rate (or ECF) support for Internet access, Internet service, internal connections, and/or the related network equipment. Wi-Fi hotspots qualify as eligible “Network Equipment” for Internet access, Internet service, or internal connections and therefore triggers the need for CIPA compliance. Specifically, CIPA requires schools and libraries that have computers with Internet access to certify that they are enforcing a policy of Internet safety that includes the operation of a technology protection measure (e.g., a filter). Schools and libraries are required to block or filter visual depictions that are obscene, child pornography, or harmful to minors across all sites, including social media. CIPA also requires monitoring the online activities of minors and providing education about appropriate online behavior, including warnings against cyberbullying. 

All Wi-Fi hotspot equipment requests must have an associated line of service on the application. However, applicants who purchased Wi-Fi hotspot devices through ECF, or another funding source, can receive E-Rate funding for the Internet access service plans to use these previously purchased devices.

No. Applicants cannot request more devices than lines in anticipation of potential loss/breakage. Replacement devices for the same line may be purchased using non-E-Rate funding sources or replacement devices can be requested in the next funding year.

No. The purchase of devices receiving services through a private network or other funding sources is ineligible for E-Rate support. Only Wi-Fi hotspots to be used with commercially available mobile wireless Internet access services are eligible.

Applicants can stagger delivery of devices and/or lines approved on the FCC Form 471 throughout the year. Applicants do not have to take receipt of all lines and devices purchased through the E-Rate program at the same time. However, applicants are reminded that the funding year ends on June 30 and FY 2025 recurring services cannot be delivered after the funding year has ended. 

No. An applicant must seek competitive bids, waits at least 28 days, use price of the eligible equipment or services as the primary factor, and enter into a new contract with the selected provider. See DA 24-1287 for more information on this competitive bidding guidance.