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FCC Gets Questions and Support on Proposed E-rate Changes

The Schools, Health & Libraries Broadband Coalition urged the FCC to support managed internal broadband services (MIBS) in comments on a Wireline Bureau public notice asking about the proposed eligible services list for FY 2026. Filings from SHLB and others were posted last week in docket 13-184 after the federal government reopened.

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The commission “previously concluded that funding MIBS could substantially benefit E-Rate applicants, especially small school districts and libraries,” SHLB said. E-rate support for the services can provide “efficient, cost-effective network management solutions for school and library applicants, especially for those that serve small to mid-size or rural communities.” The group noted that “of the 2,415 schools/school districts that applied for MIBS funding in FY25, 2,248 serve less than 5,000 students.”

Kellogg & Sovereign Consulting urged the FCC to simplify the application process. “For years, applicants have struggled to determine whether software licenses, firmware updates, or remote configurations” should be classified as MIBS, internal connections or basic maintenance of internal connections. “This uncertainty has led to mistakes on [FCC] Forms 470 and 471, delayed/denied funding decisions, and inconsistent results,” Kellogg said. The current distinction between right-to-use licenses and manufacturer support licenses has also “consistently complicated the entire application lifecycle.”

Networking company Meter said it “wholeheartedly supports” the bureau's proposal to require that software, remote-based services, security patches and remote configuration “be requested with the internal connections equipment they support.” A unified approach “recognizes a fundamental truth of modern technology: network hardware is inseparable from the software and services that make it functional, secure, and reliable.” The company also urged continuing support for MIBS because the MIBS model “transforms an unpredictable capital expense into a stable, predictable operating expense, eliminating budgetary crises and lowering” the total cost of ownership.

Funds for Learning, which advises E-rate applicants, said the proposed updates to the eligible services list “address several issues” it has “highlighted for over a decade: outdated definitions of network security, inconsistent treatment of maintenance agreements, and the need for clarity around core network functions.” The proposed changes are “important steps toward modernizing the E-rate program so that it remains technologically neutral, transparent, and aligned with the realities of school and library networks,” the company said.