On June 29, 2023, the Federal Communications Commission circulated a Further Notice of Proposed Rulemaking (FNPRM) seeking comment on a wide range of potential E-rate rule changes. During the initial comment period, applicants, service providers, and industry groups shared agreement with many proposed changes, while offering alternate suggestions or sharing disagreement with others.
The list of potential changes to the program suggested by the FNPRM was comprehensive. While most comments did not seek to address every change suggested by the FCC, there were several areas of potential changes which drew comments – and generally, agreement – from numerous commenters:
- Allowing multi-year Basic Maintenance services to be funded as a non-recurring charge
- Allowing E-rate discounts for bandwidth services from multiple providers
- Allowing applicants to request bandwidth increases mid-year without a competitive bidding violation
- Allowing a 15 day “grace period” to request invoice deadline exensions
- Eliminating, or establishing a “rolling” Category Two application deadline
- Allowing applications to be placed on hold (rather than denied) when an applicant has a Red Light issue
Although comments on most changes were favorable, the proposal to change rules regarding discounted billing drew several opposing comments from service providers and garnered no support from other commenters.
Comments submitted in response to the FNPRM are as follows:
Reply comments are due on Monday, October 23.
