Top to Bottom
E-RATE POLICY ALERT · AES E-RATE ADVISORY · JUNE 5, 2026
The FCC’s “Top to Bottom” Erate Review:
What It Means for Schools and Libraries
A sweeping reassessment of the 30-year-old program could reshape broadband funding for K–12 and public libraries nationwide.
On June 3, 2026, FCC Chairman Brendan Carr announced that the Federal Communications Commission would undertake a comprehensive, “top-to-bottom” review of E-Rate — the nearly three-decade-old federal program that subsidizes broadband internet access for schools and libraries across the United States. The announcement has sent ripples through the education technology and E-Rate communities, raising serious questions about the program’s future scope, structure, and funding.
For the thousands of schools, libraries, and service providers who depend on E-Rate’s roughly $3 billion in annual funding, understanding what’s driving this review — and what could change — has never been more urgent.
What Is the FCC Proposing?
The FCC is scheduled to vote on June 25, 2026, on whether to formally open a rulemaking proceeding — known as a Notice of Proposed Rulemaking (NPRM) — to solicit public comment on potential reforms to the E-Rate program. While the vote is procedural, it signals the start of a process that could lead to significant policy changes.
“It is time to review the FCC’s program to ensure great educational outcomes — not distractions or declining performance.”
— FCC Chairman Brendan Carr, June 3, 2026
Chairman Carr has framed the review around a central concern: that increased screen time in classrooms, much of it enabled by E-Rate-funded connectivity, is contributing to worsening academic performance and negative health outcomes for children. He pointed to a 2026 advisory from the U.S. Surgeon General and the Department of Health and Human Services linking excessive screen use among children to weaker reading comprehension and declining mental health.
According to reporting by K-12 Dive and Reuters, the FCC is considering reforms ranging from modest new guardrails to ending the program altogether — though senior FCC officials have since clarified that eliminating the program’s funding cap is not among the proposals currently under consideration.
KEY QUESTIONS IN THE FCC’S REVIEW
• How can E-Rate ensure funds advance student learning outcomes while protecting children’s online safety?
• Are existing Children’s Internet Protection Act (CIPA) requirements sufficient to protect children from harmful online content?
• How can the FCC ensure program funds are being spent in accordance with congressional intent?
• What are the legal and policy considerations for addressing children’s screen time in the context of E-Rate?
• Should the program’s scope be narrowed or redefined from its current form?
The Backdrop: A Program Under Pressure
The E-Rate program was created by Congress in 1996 under the Telecommunications Act with a clear mission: to ensure that schools and libraries have access to affordable broadband. When it launched, only 14% of U.S. classrooms had internet connectivity. Today, the program is the primary federal mechanism for closing the digital divide in education.
But the program has evolved significantly — especially during the COVID-19 pandemic. In 2023 and 2024, the Biden-era FCC voted to expand E-Rate coverage to include Wi-Fi on school buses and off-campus Wi-Fi hotspots provided by schools and libraries, citing remote learning as exposing stark inequities in home broadband access.
Chairman Carr strongly opposed those expansions. In September 2025, he circulated proposals to roll them back, calling them “illegal” violations of the program’s congressional scope. By September 30, 2025, the FCC voted to remove school bus Wi-Fi and library hotspots from E-Rate eligibility — a decision that drew fierce pushback from education organizations and Democratic lawmakers alike.
The June 2026 review goes further, examining not just what E-Rate funds, but also whether the program's underlying purpose still aligns with how schools use technology today.
A Timeline of Recent Changes
● 2023–2024: Biden FCC expands E-Rate to cover school bus Wi-Fi and off-campus hotspot lending programs.
● September 2025: Chairman Carr circulates proposals to reverse the pandemic-era expansions, calling them unlawful.
● September 30, 2025: FCC votes to remove school bus Wi-Fi and off-campus hotspots from E-Rate eligibility. USAC directed to deny pending FY2025 requests for off-premises services.
● June 3, 2026: Chairman Carr announces a full “top-to-bottom” review of the E-Rate program, citing screen time concerns and declining student test scores.
● June 25, 2026: FCC scheduled to vote on opening the formal NPRM review proceeding and soliciting public comment.
What Could Actually Change?
Based on what FCC officials and reporting have indicated, the review could lead to several types of reform:
Strengthened CIPA enforcement. The FCC has signaled that a primary focus is reinterpreting or strengthening Children’s Internet Protection Act (CIPA) requirements. CIPA already requires E-Rate recipients to certify they filter obscene and harmful content — but the FCC may consider whether these requirements go far enough in limiting access to distracting or educationally counterproductive content during school hours.
New transparency and accountability requirements. Chairman Carr has indicated he wants to give parents greater visibility into how technology is being used in classrooms. New requirements could mandate that schools and libraries report more granularly on how E-Rate-funded connectivity is used and whether that use supports educational outcomes.
Potential scope limitations. The FCC may seek to more narrowly define which services and equipment qualify for E-Rate funding, potentially excluding technologies deemed to facilitate non-educational screen time.
Funding structure adjustments. While senior FCC officials have said reducing the program’s cap is not on the table, any structural shift in eligibility definitions would have practical effects on the funding available to applicants — even without a direct budget cut.
Reactions from the Field
The E-Rate and education technology community has responded with a mix of caution and concern. The Consortium for School Networking (CoSN), a leading nonprofit for K-12 ed-tech leaders, issued a statement emphasizing both the importance of the E-Rate program and the critical need to preserve local control over technology decision-making, given the diverse connectivity needs of districts nationwide.
Many E-Rate practitioners share the underlying concern about how technology is used in schools — but caution against conflating infrastructure funding with content policy. E-Rate pays for the pipes, not the content flowing through them. Restricting connectivity funding based on how devices are used in classrooms raises complex questions about federal overreach into local curriculum and technology decisions.
“While parents have the ability to supervise screen use and monitor internet access at home, that parental control does not extend the same way into their kids’ classrooms and libraries.”
— FCC Chairman Brendan Carr
Critics also point out that many districts — particularly rural and low-income communities — still lack adequate connectivity even today. With 74% of school districts meeting the FCC’s 1 Mbps-per-student bandwidth target, roughly 3,330 districts and millions of students remain underserved. Any program narrowing that reduces funding or eligibility could deepen that divide at precisely the wrong moment.
What E-Rate Applicants Should Do Now
For schools, libraries, and E-Rate service providers, the most important thing to understand right now is that the June 25 vote is the start of a process, not the end. An NPRM opens a public comment period — meaning stakeholders will have formal opportunities to submit input to the FCC before any rules change. That comment window is critically important, and E-Rate participants should plan to engage.
In the meantime, current program operations continue. The FY2026 application cycle is proceeding normally. USAC’s processes, eligible services, and funding mechanisms remain in place, and applicants should continue to comply with existing program rules.
ACTION ITEMS FOR E-RATE STAKEHOLDERS
• Monitor the FCC’s June 25 open meeting and the release of the formal NPRM text.
• Prepare to participate in the public comment process — your district’s or library’s real-world experience matters.
• Document and communicate the concrete impact of E-Rate funding on student outcomes and connectivity equity in your community.
• Stay current with USAC guidance — program operations remain normal for FY2026.
• Engage your congressional representatives, especially if your district serves high-need populations.
The Bigger Picture
The FCC’s review of E-Rate is unfolding against a broader national conversation about technology in schools. Dozens of states have enacted or are considering screen time limits and device restrictions for younger students. Several school districts have moved to ban smartphones during the school day. The question of whether federal broadband subsidies are inadvertently enabling harm — rather than opportunity — deserves serious examination.
But a thoughtful review is very different from a hasty restructuring. E-Rate is, by most measures, one of the most successful federal education technology programs ever created. It has connected millions of students who would otherwise be left behind. Getting the balance right — between protecting children, maintaining accountability, and preserving the program’s foundational equity mission — will require careful deliberation, not just a political pivot.
The E-Rate community has navigated major policy shifts before. As this review unfolds, an informed, engaged response from schools, libraries, and practitioners will be essential to ensuring the program emerges stronger — not diminished.
This article was prepared by AES for informational purposes. For guidance specific to your E-Rate applications or compliance obligations, contact your AES program advisor. Public comments on the FCC’s review can be submitted at fcc.gov once the NPRM is formally released following the June 25 vote.