CSM SUBMITS COMMENTS TO THE FCC 2026 DRAFT E-RATE ELIGIBLE SERVICES LIST

On October 15, 2025, CSM submitted comments to the FCC FY 2026 Draft E-Rate Eligible Services List. Due to the federal government shutdown these comments are not yet published on the FCC website under docket 13-184.

Our goal is to help simplify the program and align it with how schools and libraries actually purchase and manage technology today.

Here’s a quick summary of our key points:

• We support the FCC’s proposal to move all software licenses under Category Two – Internal Connections (IC).

• We’ve recommended eliminating the Basic Maintenance of Internal Connections (BMIC) category, which originated back when USAC implemented the ‘Two In Five Rule’, where applicants could only request Priority 2 funding in two out of every five years.

• We propose simplifying Category Two into just two categories:

  • Internal Connections (IC): for purchased equipment and licenses.

  • Managed Internal Broadband Services (MIBS): for leased or third-party managed network services.

• The services currently under BMIC (repairs, cable maintenance, on-site configuration) already fit naturally under IC or MIBS.

• We emphasized that MIBS remains an important option for applicants who do not have a dedicated technical person on staff.

• Overall, these changes would streamline the program, reduce confusion and appeals, and better reflect current technology and funding practices.

You can review the full text of our submitted comments in this document.

Special thanks goes out to three of our Senior Consultants who collaborated to prepare CSM’s comments.

• Paul Stankus in one of our California Offices

• Jessica Olsen in our South Carolina Office

• Al Arauz in our Florida Office

CSM regularly participates in Advocacy efforts on behalf of our clients and the E-Rate Program as a whole, always in an effort to simplify and streamline the myriad of ever-changing policies and procedures associated with successful E-Rate funding.

As always, if you have any questions, comments or concerns, please reach out to your dedicated CSM team.