FCC Seeks Comment on Variable Pricing for Services, Elimination or Changes to MIBS as Part of Proposed FY 2027 E-Rate Eligible Services List

The Federal Communications Commission’s Wireline Competition Bureau (Bureau) released the proposed Funding Year 2027 E-Rate Eligible Services List (ESL) on June 30, 2026. 

The Bureau is asking stakeholders to provide input on two specific issues:

Managed Internal Broadband Services (MIBS).  The Commission sought comment on MIBS in its recently adopted Further Notice of Proposed Rulemaking.  The Bureau seeks comment on many of the same issues, as well as additional questions:

• How to define and ensure cost-effective purchasing for MIBS.
• Whether reimbursement for MIBS services should be limited to the number of hours worked with the requirement that tickets for work requested/performed and hours worked be included with requests for reimbursement.
• What information should applicants include in an FCC Form 470 or request for proposal document when requesting MIBS to ensure bidders have sufficient information to submit a responsive bid and applicants can effectively compare bids to select the most cost-effective service offering?
• Would requiring applicants to compare bids on internal connections directly with those of a MIBS bid help safeguard applicants and the E-Rate program from MIBS providers offering contracts at rates that exceed the value of the network itself?
• Should eligibility of MIBS be limited to schools and libraries of a certain size instead of eliminating it as a supported service?
• How to prevent MIBS from being used to augment a school’s or library’s information technology department or team when a school’s or library’s staffing costs are ineligible for E-Rate support.
• How to ensure ineligible services and equipment are not being bundled with a MIBS service.
• How to determine what services are being provided through a MIBS contract and how to limit support to eligible services and equipment.
• If an applicant owns the internal connections, should the applicant be limited to seeking only basic maintenance of internal connections (BMIC) instead of MIBS for its owned equipment? 
• Given concerns about the cost-effectiveness of MIBS and ensuring only eligible services and equipment are funded, should MIBS be made ineligible for E-Rate support or otherwise limit support to certain sized schools and libraries?

Network-as-a-Service (NaaS) and Variable Pricing.  The Bureau is also seeking comment on NaaS offerings that charge based on actual monthly usage rather than a fixed monthly amount.  Current E-Rate application forms assume fixed pricing, creating administrative challenges.  The Bureau seeks comment on:

• How the FCC Forms 470 and 471 could be modified to account for monthly variable services and pricing.
• What information should applicants include in an FCC Form 470 or request for proposal when requesting monthly variable services to ensure bidders have sufficient information to submit a responsive bid and applicants can effectively compare the costs of bids for monthly variable services to fixed monthly services? 
• What information should be collected on the FCC forms to allow USAC to accurately commit funding for services that will vary each month in amount and cost? 
• How would demand be calculated for the program for services with variable costs? 
• What safeguards and limits should be imposed on NaaS and other services with variable pricing and are such variable pricing services likely to lower or raise costs to the Fund? 
• What equipment is needed to provide NasS and other services with variable costs? 
• Should services with variable costs, like NaaS, remain ineligible given the heavy administrative burdens associated with funding this type of services? 
• To what extent do service providers offer and applicants seek such services?