Frequently Asked Questions on the FCC’s Recent Reversal of E-Rate’s Hotspot Lending Program
Q. I’m hearing hotspots are no longer eligible for E-Rate funding. Is this true?
A. Yes, it is true. During its monthly open meeting on September 30, the Federal Communications Commission (FCC) voted to end the Hotspot Lending Program in a 2-1 vote. The Commission also ended the School Bus Wi-Fi program in the same meeting with the same 2-1 vote. The Commissioners who voted to end these two programs generally believed that the statutory language establishing the E-Rate program did not allow its funding to be used beyond library and school property. ALA, along with other organizations, does not agree with this interpretation and spent considerable time and effort advocating for the hotspots program.
Q. When does this take effect?
A. The Commission’s September 30 action was incorporated in an Order for Reconsideration. The Order rescinds the Hotspot Lending Program rules thus making hotspots and related services no longer eligible for E-Rate funding. This Order becomes official 30 days after it is published in the Federal Register. The Order also directs FCC staff to revise the FY 2025 Eligible Services List (ESL) to remove from the list equipment and services related to hotspots. The revised ESL can be found on the USAC website.
Q. I requested funding for hotspots in my July 1, 2025, E-Rate application. Will I get this funding?
A. Unfortunately, the bottom line is that you will not receive funding. In the same Reconsideration Order, the FCC also instructed USAC to deny any FY 2025 funding requests for hotspots and related services. This means that no libraries or schools nationwide will receive funding for hotspot devices and service lines.
Q. I have a contract for hotspots already. What does this decision mean for my current contract?
A. You should review closely the terms of your contract. If it does not include a clause stating that enforcement of the contract is dependent upon receiving E-Rate funding, you are likely responsible for paying the entire amount of the contract. Seek legal advice if you have any questions about the language in your contract. Contact the service provider to see if you can negotiate different terms given the abrupt cancellation of the program.
Q. What does this mean for the future of E-Rate funding for hotspots?
A. There is no denying that the decision by the FCC to rescind the Hotspot Lending Program is a major disappointment for libraries and schools. Because the reversal happened through the regulatory process at the FCC, it is possible that a future FCC could revisit its decision and come to a different conclusion. Earlier this year there had been a Congressional effort, led by Senator Ted Cruz, to overturn the program using the Congressional Review Act (CRA). If this had been successful there would have been no possibility of any future hotspot program funded through E-Rate. ALA has also recommended the inclusion of hotspots in the E-Rate program in comments to the Universal Service Fund Working Group in Congress.
Q. Will the decision to end the school bus Wi-Fi program impact funding I get for Wi-Fi on our bookmobile?
A. No. Bookmobiles are considered a branch of the library and are fully eligible for services the same way a branch with a physical location is.
Q. I still have questions, where can I go for help?
A. Reach out to your state E-Rate coordinator. You can find out who that is and their contact information on the ALA E-Rate State Coordinators webpage.
Background on Hotspot Lending through E-Rate
Hotspot lending became part of the E-Rate program in July 2024. It was part of then FCC Chairwoman Jessica Rosenworcel’s Learn Without Limits initiative which she announced during the 2023 ALA Annual conference. It built on the success of the Emergency Connectivity Fund program (ECF). This was a COVID-era program designed to help keep students, teachers, and library patrons connected during the pandemic when most libraries and schools were closed to the public. The ECF program ended in June 2024 but because hotspots continue to be an important tool for those individuals who still do not have reliable or affordable home internet, the Commission voted to allow hotspot lending beginning with the July 2025 E-Rate funding year. Hotspots were added to the FY25 Eligible Services List, and over 800 libraries and schools requested $34.2 million in E-Rate funds for hotspots and hotspot services during the first year.
Additional Resources
For more background information on the decision by the FCC to end the Hotspot Lending Program, see the following resources.
