Insights: Broadband Legal Strategies Blog

On December 20, 2025, the Federal Communications Commission directed USAC not to apply the Kalamazoo Reconsideration Order precedent to requests for Wi-Fi hotspots and/or the services and to find a competitive bidding violation if the applicant relies on a previously signed contract.

On December 19, 2024, the Commission released a public notice reminding broadband internet service providers to display accurate broadband consumer labels for both wireless and wired retail standalone broadband services, at all points of sale in compliance with the Broadband Label Order.

On December 16, 2023, the Universal Service Administrative Company (USAC) announced that the application filing window for Funding Year 2024 FCC Form 471 will open January 15, 2025, at noon ET and will close on March 26, 2025, at 11:59 p.m. ET.

President-elect Trump has selected Commissioner Brendan Carr to serve as the next FCC chairman. On November 21, 2024, FCC Chairwoman Jessica Rosenworcel announced that she will leave the FCC on January 20, 2025.

On October 15, 2024, the Bureau announced that it released a new invoicing form for the Rural Healthcare Telecommunications Program:  the FCC Form 469, Description of Invoice and Request for Disbursement.  Service providers will initiate the invoice process by submitting the Form 469 in RHC Connect, after each month of service or at the end of the funding year for all services provided during the funding year.  USAC is offering trainings on how to use the new form and process. 

In its September News Brief, USAC announced that the E-Rate Administrative Window opened in EPC on October 15, 2024. 

On October 25, 2024, the FCC’s Wireline Competition Bureau (the Bureau) issued the Eligible Services List (ESL) for Funding Year 2025. 

Two petitions for reconsideration of the E-Rate Hotspot Report and Order were separately filed by the Los Angeles Unified School District and the Schools and the Health & Libraries Broadband (SHLB) Coalition et al. 

 On September 10, 2024, the Commission released a public notice reminding service providers with 100,000 or fewer subscribers to begin displaying broadband consumer labels in compliance with the Broadband Label Order on October 10, 2024.

On July 18, 2024, the Federal Communications Commission (Commission) adopted a report and order and further notice of proposed rulemaking (Order and Further NPRM) allowing schools and libraries to receive E-Rate support for Wi-Fi hotspots and services that can be used off-premises by students, school staff, and library patrons.

On August 26, 2024, the U.S. Court of Appeals for the Fifth Circuit granted the FCC’s motion to stay its decision granting Consumer’s Research, et al.’s petition for review of the FCC’s first quarter 2022 universal service contribution factor.

The Federal Communications Commission’s Wireline Competition Bureau (Bureau) released the Funding Year 2025 E-rate Eligible Services List (ESL) on July 31, 2024.  Comments are due August 30, 2024; reply comments are due September 16, 2024. 

The Rural Health Care Program Funding Year (FY) 2025 filing window will open on December 1, 2024, and close on April 1, 2025. 

On May 31, 2024, the FCC announced that it was directing USAC to stop making any new commitments from ECF funding until it has returned $1.768 billion to the U.S. Treasury (see page 42). 

The FCC initiated a pilot program that would pay for some cybersecurity services for schools and libraries at its open meeting today.  The pilot program would operate outside of the E-rate program. 

In its April RHC newsletter, the Universal Service Administrative Company (USAC) reminded Telecom program participants that the Federal Communications Commission (FCC or Commission) established a deadline of July 1, 2024, to submit invoices for FY2019 and earlier. 

On June 14, 2024, the Wireline Competition Bureau (Bureau) announced that there is sufficient funding available to fully meet the Universal Service Administrative Company’s (USAC) estimated demand for the Rural Healthcare program’s year (FY) 2024.

On March 14, 2024, the Federal Communications Commission voted to raise the national fixed broadband standard from 25 Mbps download/3 Mbps upload, which was set in 2015, to 100 Mbps upload/20 Mbps download. 

In a Public Notice released March 14, 2024, the FCC announced that the proposed Universal Service Fund (USF) contribution factor for the second quarter of 2024 will be 32.8 percent. 

In its March news brief, USAC announced it will hold in-person trainings this year. 

In its April RHC newsletter, USAC reminded Telecom program participants that the Commission established a deadline of July 1, 2024, to submit invoices for FY2019 and earlier.

The Rural Health Care Program Funding Year (FY) 2024 filing window opened on December 1, 2023 and was extended until May 1, 2025.

In the Rural Health Care (RHC) Program, the Commission aligned the invoice filing deadline for the Healthcare Connect Fund (HCF) and the Telecommunications (Telecom) Programs to October 28, 2023 in FCC Order 19-78. 

The E-rate application filing window for Funding Year 2024 FCC Form 471 opened on January 17, 2024, at noon ET and will close on March 27, 2024, at 11:59 p.m. ET.