Draft FY 2026 E-Rate Eligible Services List Seeks Comment on MIBS, BMIC

On September 30, the Wireline Competition Bureau released a public notice seeking comment on its proposed eligible services list (ESL) for funding year (FY) 2026.

The Bureau is requesting comment on two aspects of the ESL. Comments on the proposed ESL are due October 15, and reply comments are due October 30.

1) Categorization of software- and remote-based services. First, the Bureau proposes changes to the internal connections and the basic maintenance of internal connections (BMIC) sections of the ESL. The public notice explains that the proposed changes are designed to standardize the treatment of software- and remote-based services, including bug fixes, security patches, software-based technical assistance, and configuration changes. Currently, these types of services are treated differently depending on whether they are categorized as BMIC (in which case they must be requested each funding year, requiring proration of multiyear contracts) or as internal connections (in which case software and licenses may be requested in the first year of a multiyear contract, along with the associated equipment).

To alleviate confusion, the Bureau proposes to revise the FY 2026 ESL to treat all currently eligible software- or remote-based services the same and have applicants request all software-and remote-based services with the internal connections equipment that they support. To achieve this, the Bureau proposes the following specific changes to the ESL for FY 2026:

• Revise the internal connections section of the ESL to include “bug fixes, security patches, software-based technical assistance, and configuration changes”;
• Delete from the BMIC section of the ESL “Basic technical support including online and telephone-based technical support” and “Software upgrades and patches including bug fixes and security patches”; and
• Amend the “eligibility limitations for basic maintenance” to delete language related to bug fixes, security patches, and technical support.

2) Managed internal broadband services. Second, the Bureau requests comment on whether changes should be made to the ESL regarding managed internal broadband services (MIBS). The public notice states that applicants have been confused about the eligibility of MIBS and how MIBS differs from BMIC services. When MIBS were first made eligible in 2014, the Commission noted that MIBS could provide “substantial benefits and cost savings to many schools and libraries.” The Bureau is now seeking comment on whether funding MIBS does provide any substantial benefits or cost savings. The Bureau asks whether it should define MIBS more narrowly so that there is no overlap with BMIC services, and on how the Commission can provide greater clarity in differentiating between MIBS and BMIC services in the ESL. Lastly, the Bureau asks whether changes to MIBS should be made for the current funding year or for future funding years.