FCC Issues January 2026 Streamlined Decisions Impacting Universal Service Programs
January 2, 2026, | DA 26-1
The FCC’s Wireline Competition Bureau released its January 2026 Streamlined Public Notice (DA 26-1) resolving numerous appeals, waiver requests, and petitions for reconsideration across the E-Rate (Schools and Libraries), Cybersecurity Pilot, Emergency Connectivity Fund (ECF), Rural Health Care, and Lifeline programs. The Bureau granted limited relief where applicants demonstrated good cause, dismissed procedurally defective or moot filings, and denied the remainder consistent with long-standing FCC precedent. Parties have 30 days to seek further Commission review.
Key Takeaways
- Deadlines remain critical: The FCC continues to strictly enforce filing deadlines for Forms 471 and 486, invoicing, and appeals/waiver requests.
- Relief is narrow: Waivers are generally limited to clerical or ministerial errors, short filing delays, USAC timing issues, or documented good-faith compliance efforts.
- Statutory deadlines cannot be waived: Late petitions for reconsideration filed beyond the 30-day statutory window are dismissed.
- Clarifications provided: The order offers guidance on special construction deadline waivers, evergreen rural rates, and invoicing when USAC decisions are issued after deadlines.
E-Rate Highlights (Schools & Libraries)
Relief Granted
- Waivers where the lowest-cost bid was selected and no waste, fraud, or abuse was shown.
- Discount rate corrections for libraries whose rates did not align with the applicable school district NSLP rate.
- Invoicing relief where applicants missed USAC information requests or where USAC decisions were issued after the invoice deadline.
- Waivers for minor late filings and ministerial errors on Forms 471, Form 500, and invoice deadline extensions.
- Limited special construction deadline extensions where applicants demonstrated good-faith efforts and circumstances beyond their control.
Requests Denied
- Applications with no Form 470, 28-day rule violations, or incomplete competitive bidding.
- Late Form 471, Form 486, and invoice filings without special circumstances.
- Untimely appeals or waiver requests that failed to meet the 60-day deadline.
Cybersecurity Pilot Program
- Appeals and waivers were dismissed or denied where filings missed the 30-day deadline.
- Waivers for late Cybersecurity Form 471 filings were denied despite the program’s extended application window.
- Claims of reliance on incorrect USAC guidance were rejected; applicants remain responsible for compliance.
Emergency Connectivity Fund (ECF)
Granted
- Waivers for early equipment delivery.
- Invoice deadline extensions on reconsideration where additional documentation time was justified.
Denied
- Requests from ineligible entities.
- Late appeals and waiver requests filed beyond the ECF-specific 30-day deadline.
- Violations of ECF “no warehousing” and failure to invoice after prior extensions.
Rural Health Care & Lifeline
- Rural Health Care: The Bureau rescinded certain commitment adjustments and clarified that rural rate approvals under evergreen contracts apply across the contract term, including for bandwidth upgrades.
- Lifeline: Petitions were dismissed as moot due to debarment or voluntary withdrawal.
Bottom Line
The FCC’s January 2026 decisions reinforce the importance of timely filings and strict compliance with program rules. While limited relief remains available for good-faith errors, applicants should closely monitor deadlines and documentation requirements to avoid denial of funding.
This summary reflects the FCC’s January 2, 2026, streamlined Public Notice, DA 26-1. Click Here
