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:  https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=1080.

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.