July 12, 2023 – Federal Communications Commission (FCC) Chairwoman Jessica Rosenworcel has announced a proposal to create a pilot program that would provide E-Rate support for cybersecurity and advanced firewall-related services for eligible K-12 schools and libraries.[1]

Chairwoman Jessica Rosenworcel shared high-level details of the proposal in a speech before the School Superintendents Association and the Association of School Business officers. She said the proposed pilot program would work in tandem with federal agency partners to invest up to $200 million over three years to harden the cyber defenses and determine the most effective methods to protect schools and libraries. According to the FCC news release announcement, the pilot program would be established “within the Universal Service Fund, but separate from the E-Rate program, to ensure gains in enhanced cybersecurity don’t come at a cost of undermining E-Rate’s success in promoting digital equity.”

December 2022 Public Notice

In a December 2022 Public Notice,[2] the FCC sought comment on using E-Rate funds to support next-generation firewalls and services, as well as numerous related issues.

• Definition of Advanced or Next-Generation Firewalls and Services.  The E-Rate program currently defines firewall as “a hardware and software combination that sits at the boundary between an organization’s network and the outside world, and protects the network against unauthorized access or intrusions.” Comment is requested on this definition and whether any modifications may be appropriate.

• Eligible Equipment and Services and their Costs.  Comment is requested on the specific equipment and services that E-Rate should support to fund as advanced or next-generation firewalls and services, as well as the costs associated with funding these services.

• Categorization of Firewall Services and Components.  Under current E-Rate rules, basic firewall service provided as part of a vendor’s Internet access service is eligible as a Category One service. Separately priced basic firewall services and components are eligible as a Category Two service. Comment is sought on whether advanced or next-generation firewall services and components should be eligible as a Category One and/or Category Two service.

• Cost-Effective Purchases.  If the FCC makes advanced or next-generation firewall services eligible as only Category Two service, comment is sought on whether this would be an effective way to ensure applicants are making cost-effective choices when requesting these services and equipment.

• Legal Authority Issues.  Comment is sought on the FCC’s legal authority to add advanced or next-generation firewalls and services as an eligible service for the E-Rate program.

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[1] FCC Chairwoman Rosenworcel Takes Steps To Protect Schools Against Cyber Attacks, Would Build On Learn Without Limits Initiative By Launching Pilot Program, FCC News Release (July 12, 2023), https://docs.fcc.gov/public/attachments/DOC-395069A1.pdf.

[2] Wireline Competition Bureau Seeks Comment On Requests To Allow The Use Of E-Rate Funds For Advanced Or Next-Generation Firewalls And Other Network Security Services, WC Docket No. 13-184, Public Notice, DA 22-1315 (Dec. 14, 2022), https://docs.fcc.gov/public/attachments/DA-22-1315A1.pdf.