SUMMARY

On April 29, 2026, the Federal Communications Commission (FCC) released a draft Notice of Proposed Rulemaking (NPRM) titled “Reforming the High‑Cost Program for an All‑IP Future,” initiating a broad review of the High‑Cost Universal Service Fund (USF) program. The NPRM seeks comment on potential reforms to legacy cost‑based support mechanisms and on the future of several model‑based mechanisms that are scheduled to sunset beginning in 2026.

The proceeding examines how the High‑Cost Program should evolve in light of the transition to IP‑based networks, changes in broadband deployment, the availability of other federal funding programs, and the increasing presence of satellite broadband services.

Key Topics on Which the FCC Seeks Comment

Future of Legacy High‑Cost Support Mechanisms

Whether and how to modernize CAF Broadband Loop Support (CAF BLS) and High Cost Loop Support (HCLS), including whether these mechanisms should be retained, updated, or replaced.

Next Steps for Sunsetting A‑CAM Mechanisms

What actions, if any, should be taken regarding A‑CAM I, Revised A‑CAM I, and A‑CAM II, including a proposed short‑term extension of A‑CAM I through the end of 2028.

Deployment Obligations and Support Scope

Whether ongoing high‑cost support should include new or modified deployment obligations, including broadband performance standards consistent with current federal benchmarks.

Competitive Overlap and Enforceable Commitments

How the Commission should evaluate high‑cost support in areas already served by competitors or subject to enforceable federal or state broadband funding commitments.

Role of Satellite Broadband

How the increasing availability of low‑Earth‑orbit satellite broadband service should affect eligibility for high‑cost support and deployment obligations.

USF and the Transition to All‑IP Networks

What role, if any, the High‑Cost Program should play in facilitating the transition from legacy time‑division multiplexed networks to all‑IP environments.

PROCEDURAL NOTES

• The proceeding is designated permit‑but‑disclose under the FCC’s ex parte rules.
• Comments will be due 60 days after Federal Register publication.
• Reply comments will be due 90 days after Federal Register publication.
• Filings will be made in WC Docket Nos. 26‑96 and 10‑90 via the FCC’s Electronic Comment Filing System (ECFS).

THIS MAY APPLY TO YOU IF YOU ARE A…

• Rate‑of‑return incumbent local exchange carrier (ILEC)
• Recipient of CAF Broadband Loop Support (CAF BLS) or High Cost Loop Support (HCLS)
• Carrier receiving A‑CAM I, Revised A‑CAM I, or A‑CAM II support
• Carrier operating in rural or high‑cost areas subject to USF support obligations
• Provider with existing or planned broadband deployments affected by BEAD or other federal funding commitments