Cybersecurity Considerations for Universal Service Fund Reform

As the speed, scope, and impact of cyber threats to K-12 schools continues to increase, Congress has expressed a clear desire to reinvigorate the Universal Service Fund (USF) through legislation. IST SVP for Policy Nicholas Leiserson explores how USF funding, through the FCC's E-Rate Program, could bolster cybersecurity resources for K-12 schools.

On June 27, the U.S. Supreme Court ruled that the Federal Communication Commission’s Universal Service Fund (USF) was constitutional. Within hours, leaders on the House Energy and Commerce Committee announced plans to reauthorize the USF. For those of us attuned to the challenges facing K-12 schools when it comes to cybersecurity, these two events raised an immediate question: what’s to become of the FCC’s cybersecurity pilot?

Last year, the FCC finalized a pilot program intended to help E-Rate-eligible schools3 improve their cybersecurity by giving them access to a broader array of subsidized tools and services. The cyber pilot program was wildly oversubscribed: schools and libraries submitted over $3.7 billion in requests for assistance, more than 18 times the program budget of $200 million. Since launching in January 2025, funding has been approved for more than 700 schools and libraries to help them mitigate threats from cyber criminals.

Historically, USF funding has had only limited applicability to cybersecurity tools and services, but the education community has demonstrated a clear demand for broadband access that brings opportunity without also leaving schools more vulnerable.

Should policymakers wish to take action to address cybersecurity gaps at “target rich, cyber poor” educational institutions, there are several means they could use to do so. This primer reviews these opportunities, including codifying a cybersecurity program similar to the pilot, expanding the list of eligible services under the E-Rate program to include modern cybersecurity technologies, or creating a cross-sector cybersecurity set-aside.

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