Off-Premises Wi-Fi Hotspots Overview 

Starting in Funding Year (FY) 2025, Wi-Fi hotspots and mobile wireless Internet services that can be used off-premises will be eligible. This will allow eligible schools and libraries to start Wi-Fi hotspot lending programs so that their students, school staff, and library patrons with need can check out E-Rate-supported Wi-Fi hotspots and services to engage in remote learning.

Eligible Services

Commercially available mobile wireless Internet services that can be supported by and delivered with Wi-Fi hotspots are eligible.

The Wi-Fi hotspots to make the service functional must:

• Be portable.
• Be a single device (i.e., not a set of linked devices).
• Be for use with a commercially available mobile wireless Internet service.

Ineligible Services

The following services are ineligible:

• Multi-functional devices (e.g., smartphones, PCs, notebooks, tablets, customer premises equipment, routers or switches, and wireless access points, etc.).
• Wireless services delivered to any broadband-enabled end user devices (e.g., laptops, tablets), fixed wireless connections and the related equipment, private 5G/LTE networks, fiber, and network expansion or construction.
• 1:1 Wi-Fi hotspot initiatives (i.e., where every student receives a Wi-Fi hotspot) are not allowed, and each Wi-Fi hotspot must have an associated line of service to be eligible for E-Rate funding.
• Wi-Fi hotspots may not be warehoused/stored for future use or as replacements for lost, damaged, or stolen Wi-Fi hotspot devices.
• Lines of service that have no data usage. Service providers are required to notify applicants of each line that goes unused for 60 days and to provide applicants 30 days for the Wi-Fi hotspot to be used before terminating the line of service.

Wi-Fi Hotspot Budgets

There are three constraints of the Wi-Fi hotspot initiative to limit funding and allow for the equitable distribution of Wi-Fi hotspots and services to students, school staff, and library patrons, and to ensure cost effectiveness. These constraints are (1) a set three-year budget, (2) funding caps on services and Wi-Fi hotspot devices, and (3) an annual request limit (the applicant must not request more than 45% of their budget in one year).

The budget for Wi-Fi hotspots will be on a fixed three-year cycle, beginning with Funding Years 2025 through 2027. After three years, the budgets will reset in Funding Year 2028.

The Wi-Fi hotspot budget represents the maximum pre-discount amount an applicant may request across the three Funding Years, rather than an allocation of funding for Wi-Fi hotspots and service lines for which an applicant is entitled reimbursement.

Calculating Wi-Fi Hotspot Budget

For independent schools and school districts:

Calculate Wi-Fi hotspot and service budgets by multiplying student count by 20% (i.e., 20 hotspots per 100 students) and the Category One (C1) discount rate. This number is rounded up to the nearest ten. The applicant then multiplies that rounded number by $630 to determine the three-year pre-discount budget.

• Independent School or District Budget = [student count x (20 hotspots/100 students) x C1 discount rate] x $630
  • Remember to round the bracketed value up to the nearest 10.

For independent libraries or library systems:

Calculate Wi-Fi hotspots and service budgets multiplying square footage by 0.0055 (i.e. 5.5 devices per 1,000 square feet) and the C1 discount rate. This number is rounded up to the nearest ten. The applicant then multiplies that rounded number by $630 to determine the three-year pre-discount budget.

• Library or Library System Budget = [square feet x (5.5 hotspots/1000 sq ft) x C1 discount rate] x $630
  • Remember to round the bracketed value up to the nearest 10.

Funding Caps

Funding caps are the maximum pre-discount costs permitted to be reimbursed for Wi-Fi hotspot devices and mobile wireless Internet access plans purchased through E-Rate.

The pre-discount funding caps are:

• Recurring wireless Internet service: $15 per month
• Wi-Fi hotspot: $90 per device

Taxes and state electronic waste fees are not included in the capped amounts. Other reasonable costs, such as delivery fees, activation and configuration costs are included in the capped amounts. When filling out your FCC Form 471, all taxes and fees should be requested on separate funding request line items and separately identified on invoices.

When making bid selections, applicants are permitted to select a Wi-Fi hotspot or service that costs more than the funding caps, but E-Rate commitment amounts will not exceed the funding caps. As with all other E-Rate services, billed rates must not exceed the actual contracted rates, and USAC will only pay up to the committed and contracted rate.

Annual Request Limits

Applicants may not request more than 45% of its three-year budget in any one year.

Instead, entities can spread out their requests for Wi-Fi hotspots and services over the three-year timeframe, not to exceed the budget over the three funding years.

Seeking Bids

For FY 2025, the FCC Form 470 has been updated to include requests for Wi-Fi hotspots and service. Applicants seeking bids should use the following:

Adding “I seek bids for wireless Internet services that can be delivered with a Wi-Fi hotspot for off-premises use.”

• Can be found under: “I seek bids for internet access and/or data transmission service.”

Adding ”I seek bids for Wi-Fi hotspots for off-premises use.”

• Can be found under: “I seek bids for Category One network equipment or maintenance and operations.”

To learn how to file the FCC Form 470 to request Wi-Fi hotspots, visit our FCC Form 470 Filing page.

Acceptable Use Policies

FCC requires applicants to maintain/update their acceptable use policies (AUPs) to clearly state that off-premises use must be primarily for an educational purpose.

• For schools: AUP must state that the use must be “integral, immediate, and proximate to the education of students.”
• For libraries: AUP must state that the use must be “integral, immediate, and proximate to the provision of library services to library patrons.”

Applicants must publicly post the updated AUP. Additionally, applicants will be required to certify on the FCC Form 486 that the requirements have been met, and to be able to provide documentation demonstrating compliance, if requested. Applicants are not required to collect signed documentation of user compliance with these policies.

Schools and libraries are also expected to implement content and user network restrictions consistent with the restrictions that they place on their building-based networks and to adopt/update AUPs and other policies to limit access.

Asset & Service Inventories

For each Wi-Fi hotspot, applicants are required to maintain an asset and service inventory that identifies:

1. The equipment make/model;
2. The equipment serial number;
3. The full name of the person to whom the equipment was provided (for schools only);
   Note: Entities may anonymize or deidentify any personally identifiable information when producing asset and service inventories.
4. The dates the equipment was loaned out and returned, or the date the school was notified that the equipment was missing, lost, or damaged; and
5. The service detail (i.e., a phone number or unique identifier for the line of service).

These records must be kept for at least 10 years.

Usage Requirements

Applicants and service providers are required to take certain steps to ensure the off-premises Wi-Fi hotspots and services are in use.

Applicants are required to certify on their FCC Form 486 that:

1. The E-Rate-funded Wi-Fi hotspot and service have been activated,
2. They have made the Wi-Fi hotspot available for loan,
3. They have publicized the availability of the Wi-Fi hotspot device and service to students, teachers, and library patrons via public notice or other means, and
4. Reimbursement is not being sought for Wi-Fi hotspots and/or services that have not been made available for distribution.

To prevent warehousing of devices, applicants are prohibited from requesting Wi-Fi hotspots as part of a 1:1 initiative (i.e., where every student gets a hotspot) or for future use, emergency use, or use in the case of theft, loss, or breakage.

Service providers are required to notify applicants of each line that goes unused for 60 days and to provide applicants 30 days for the hotspot to be used before terminating the line of service. Service providers may not charge early termination fees for lines of service associated with Wi-Fi hotspots that are lost, broken, or unused. Service providers are also not permitted to bill applicants for unused lines of service that are discontinued.

Additionally, service providers must provide applicants with reports regarding Wi-Fi hotspot data usage for off-premises use in machine-readable digital format so that information lines can be read and sorted, clearly identifying the lines that are not being used across billing periods and the lines that have been terminated pursuant to the non-usage rules.