What's Eligible and Ineligible in the FCC's E-Rate Ruling on Hotspots

The E-Rate program, established by the Federal Communications Commission (FCC) in 1996, plays a crucial role in ensuring that schools and libraries across the United States can obtain affordable, high-speed broadband services and equipment. This program is vital in bridging the digital divide and enabling students, school staff, and library patrons to participate in next-generation learning opportunities. The FCC has approved significant changes to the E-Rate program rules, aimed at modernizing the program to better address the evolving educational landscape, especially in the wake of the COVID-19 pandemic. The ruling order pertains in particular to hotspot devices and related services; this blog post will delve into what items and services are eligible and ineligible for E-Rate funding based on the FCC ruling.

Eligible Items and Services for E-Rate Funding

The ruling by the FCC introduces several updates to the E-Rate program, expanding the scope of eligible items and services to better meet the needs of today's educational environments.

Wi-Fi Hotspots and Wireless Internet Services for Off-Premises Use are Eligible

  • The FCC adopts definitions similar to those in the Emergency Connectivity Fund (ECF) program to permit the off-premises use of these technologies. Specifically, the definitions for "Wi-Fi" and "Wi-Fi hotspot" are established, with a Wi-Fi hotspot defined as a device capable of receiving advanced telecommunications and information services and sharing them through Wi-Fi. The FCC confirms that Wi-Fi hotspots and associated wireless Internet services are eligible for E-Rate support for off-premises use
  • The ruling permits schools and libraries to purchase Wi-Fi hotspots and wireless Internet services for use off-campus. This means that students, school staff, and library patrons can benefit from Internet connectivity beyond the school or library premises, addressing the persistent issue of the Homework Gap. The off-premises use of these services is now recognized as serving an educational purpose, which is a significant shift from the previous restrictions.

Other Important Provisions on Hotspots

  • There's a Three-Year Budget Mechanism
    To ensure equitable distribution of resources, the FCC ruling puts in place a three-year budget mechanism. This will limit the amount of funding schools and libraries can request for Wi-Fi hotspots and services, ensuring that these resources are distributed fairly among those with the greatest need.

  • The Priority for E-Rate Funding Remains On-Premises Equipment and Services
    In cases where the demand for E-Rate support exceeds available funding, priority will be given to requests for on-premises equipment and services. This ensures that the fundamental infrastructure needs within school and library buildings are met before extending support to off-premises connectivity.

  • Educational Purposes and Compliance for E-Rate Hotspots
    The ruling emphasizes that the off-premises use of Wi-Fi hotspots and associated wireless Internet services must serve an educational purpose. Schools and libraries must ensure that these services are used for educational activities and comply with the Children’s Internet Protection Act (CIPA) requirements.

Ineligible Items and Services for E-Rate Funding

While the ruling expands the scope of eligible items and services, it also outlines specific exclusions to maintain the integrity and focus of the E-Rate program.

  • Laptops and Devices
    The ruling explicitly states that the FCC does not extend eligibility to other multi-functional devices like smartphones, PCs, notebooks, tablets, customer premises equipment, routers, or switches.The focus remains on providing connectivity rather than the end-user devices themselves, other than hotspots. This exclusion ensures that E-Rate funds are used primarily for expanding access to high-speed Internet services. Devices like Chromebooks with embedded connectivity may still be covered by other programs, however.

  • Non-Educational Use
    Any use of Wi-Fi hotspots and wireless Internet services that does not directly serve an educational purpose is ineligible for E-Rate funding. The primary goal of the E-Rate program is to support educational activities, and any deviation from this objective disqualifies the services from funding.

  • Duplicate Funding
    The ruling includes measures to prevent duplicate funding. Schools and libraries must ensure that the Wi-Fi hotspots and services funded through the E-Rate program are not already covered by other funding sources. This safeguard is designed to promote efficient use of resources and avoid financial redundancies.

  • Improper Equipment Disposal
    Improper disposal of E-Rate-funded equipment renders further funding ineligible. Schools and libraries must adhere to strict recordkeeping and disposal guidelines to ensure continued eligibility for E-Rate support.

Safeguards to Ensure Integrity and Compliance of E-Rate Hotspots

The FCC's ruling includes several safeguards to maintain the integrity of the E-Rate program and ensure that funds are used appropriately.

  • Usage Monitoring
    Any hotspots provided for under E-Rate must adhere to CIPA requirements on content filtering, including auditing capabilities. Furthermore, schools and libraries must monitor the usage of Wi-Fi hotspots and wireless Internet services to ensure they are being used for their intended educational purposes. As mentioned, this includes regular audits and compliance checks.

  • Recordkeeping
    Detailed records must be maintained to document the use and distribution of E-Rate-funded equipment and services. This is crucial for auditing purposes and to demonstrate compliance with program requirements.


The FCC's updates to the E-Rate program represent a significant step towards modernizing the program to better meet the needs of today's educational environments. By expanding the scope of eligible items and services to include Wi-Fi hotspots and wireless Internet services for off-premises use, the ruling aims to bridge the digital divide and provide equitable access to educational resources. However, strict guidelines and safeguards are also put in place to ensure that the funds are used appropriately and effectively. Schools and libraries must adhere to these guidelines to maintain their eligibility for E-Rate funding and continue to support their students, staff, and patrons in accessing essential educational opportunities.

These updates underscore the importance of focusing on connectivity solutions that enable educational access while maintaining a clear distinction between connectivity infrastructure and end-user devices. By prioritizing educational purposes and adhering to compliance measures, the E-Rate program can continue to play a pivotal role in connecting communities and fostering educational equity.

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Tag(s): Blog Posts , Education