“Good governance requires, from time to time, stopping to ask how to keep a program aligned with goals set out by Congress,” FCC Wireline Competition Bureau Chief Joseph Calascione argued in a July 29 blog post previewing the agency’s new E-Rate proceeding. The Federal Register published the Notice of Proposed Rulemaking (NPRM) on August 14, reopening questions about the future of the federal program that helps schools and libraries afford internet connectivity and the internal networks needed to distribute it. Calascione framed the proceeding as asking the “tough questions” necessary to protect children online and steward the program responsibly.

Any meaningful policy review, like this NPRM, depends on the quality of the question guiding it. The FCC places this one at the center of its E-Rate review: Does greater E-Rate support correspond with greater reliance on “1:1 device initiatives, digital curricula, or other forms of screen-based instruction,” and are those activities associated with better or worse student outcomes?

But this is a question that E-Rate was not designed to answer. It folds broader debates about screen time, distraction, social media, and technology’s role in young people’s lives into a review of what is fundamentally an infrastructure-access program. It then makes instructional practice, student experience, and student outcomes part of the test for future connectivity support.

However, E-Rate cannot be evaluated by answering that question because infrastructure is not instruction, and a screen is not a pedagogy.

Infrastructure is not instruction

The infrastructure E-Rate supports underpins teaching and learning alongside assessment, communications, administrative systems, cybersecurity, and the growing number of Wi-Fi-dependent safety and operations systems that help schools function. Its discount structure directs the greatest support toward communities with fewer resources and recognizes the higher costs many rural applicants face.

E-Rate funds infrastructure. Policymakers should judge the program accordingly. Questions about affordability, capacity, and access are appropriate: Can schools and libraries afford reliable connectivity? Can their networks meet evolving demands? Would access remain available regardless of geography or local resources?

The FCC cites the prevalence of broadband and Wi-Fi in schools as a reason to ask whether E-Rate has fulfilled its mission. That prevalence demonstrates the program’s success. It does not establish that schools and libraries can absorb the full cost of remaining connected if E-Rate support declines or ends.

The NPRM now makes what happens over the network core to its approach, making the infrastructure responsible for the value of every activity it carries. The same network can connect a rural student to a course their school cannot otherwise offer, let classmates collaborate in real time, deliver timely information to families, and support communications and security systems. It can also carry a poorly designed digital lesson or recreational content that distracts from learning. These uses differ in purpose and value, yet the infrastructure enabling them remains the same.

We do not evaluate other forms of public infrastructure this way. Roads carry the people and goods on which communities depend. They also carry reckless drivers. We address reckless driving through safety standards, requirements, and enforcement. Reckless driving does not lead us to stop investing in roads.

Concerns about what happens over a school network may warrant action on a particular application, instructional practice, or behavior. Those concerns do not establish whether schools and libraries need affordable connectivity.

A screen is not pedagogy

Questions about instructional quality belong in the policies and decision-making processes that address curriculum, educator capacity, procurement, and student experience. The NPRM folds those questions into the broad and ill-defined category of “screen-based instruction,” then uses that category to determine E-Rate’s effectiveness.

“Screen-based” identifies a medium. It tells us little about an activity’s purpose, the instructional practice surrounding it, or the learning students experience. Students can use screens to passively scroll social media, investigate a problem, create something new, or learn with peers and experts across time and distance. These activities differ in purpose, design, interaction, and educational value.

Good instructional questions identify the specific technology, what students do with it, and the relevant outcome. Those details also point toward the appropriate policy response. If students access social media during school, leaders can strengthen use policies and filtering. If educators need support to design stronger learning experiences, leaders can invest in professional learning and coaching. If a product performs poorly, schools can improve its implementation or discontinue its use.

As with roads, leaders can develop policies to address these challenges while preserving the infrastructure communities need. Broad changes to E-Rate would weaken the connectivity on which schools and libraries depend, while leaving important questions about the selection, implementation, and evaluation of edtech unresolved.

Help shape what happens next

Leaders now need to bring these distinctions into the public record. Technology, school, and library leaders can explain what E-Rate infrastructure supports. Educators, families, and community partners can document what connectivity makes possible and what their communities would face without it. Three actions matter now:

1. Shape the formal record. States, districts, schools, libraries, professional associations, and community organizations can submit comments or organize collective responses to the NPRM. Comments are due October 13, 2026, with reply comments due November 12. Useful responses should document what E-Rate supports locally, what reducing that support would mean, and which separate policies communities use to address concerns about instruction, distraction, social media, and online safety. Review the NPRM and submit comments.
2. Join collective advocacy. Authorized representatives of school districts and nonprofit organizations can sign CoSN’s Petition to Protect E-Rate and America’s Digital Learning Connectivity, which asks Congress to encourage the FCC to preserve E-Rate’s core mission and reject efforts that would weaken or narrow the program.
3. Help document what E-Rate makes possible. Through our Share Your E-Rate Story form, readers can document what E-Rate supports in their context, who relies on it, and what would change if funding declined. We will synthesize those submissions, elevate examples with contributors’ permission, and use what we learn to inform public comments and future resources.

Together, these actions can help the FCC evaluate E-Rate for what it funds: affordable connectivity. Policymakers can then direct concerns about particular uses toward the evidence and policy responses capable of addressing them.