E-Rate and CIPA for Tribal Libraries

How Tribal libraries became eligible for E-Rate

The barrier sat in a cross-reference. Section 254(h)(4) of the Communications Act gives E-Rate discounts only to a library that is eligible for assistance from a state library administrative agency under the Library Services and Technology Act (LSTA). The FCC's 1997 rules used the LSTA definition of library in force at the time, which did not name Tribal libraries. Some Tribal libraries were not eligible for LSTA funds from their state library agency, so they could not take part in E-Rate either. The FCC's 2022 order cites a 2006 GAO report finding that Tribal libraries in at least two states were precluded from those state funds under state law.

Congress changed the definition in the Museum and Library Services Act of 2018, which added Tribal libraries to the LSTA definition of library in 20 U.S.C. 9122. The FCC then brought the E-Rate rules in line.

What the 2022 order says

• Tribal libraries are by statute eligible for support from state library administrative agencies under the LSTA, and are therefore eligible for E-Rate. Receiving LSTA funds is not required.
• A Tribal Council can designate a Tribal library.
• The FCC said it understands that what makes a library reflects the cultural, educational and social needs of each Tribe. It found three basic characteristics appropriate for Tribal libraries, the same ones the Institute of Museum and Library Services asks of applicants for its Native American Library Services Enhancement Grants: regularly scheduled hours, staff, and materials available for library users.
• Libraries that were part of a Tribal college or university stayed ineligible at that time. The 2023 order changed that for those that also serve as public libraries.
• The FCC directed outreach and training for Tribal libraries, and new measures of Tribal library participation in E-Rate.

The FCC said it moved quickly so that the change would take effect before the funding year 2022 application window closed. The rule took effect 30 days after the order was published in the Federal Register.

What eligibility requires

USAC's Tribal Libraries page and its Tribal Applicants FAQ set out what a Tribal library needs to show.

The library itself

• Three basic characteristics: regularly scheduled hours, staff, and materials available for library users. USAC adds that a Tribal library must have physical materials. A library with only a digital collection is not eligible.
• LSTA eligibility: the library must be eligible for assistance from a state library administrative agency under the LSTA. This can be shown through a Tribal designation or through a letter from the state library agency.
• A separate budget: the library's budget must be completely separate from any schools, colleges and universities. The exception is a Tribal college or university library that serves as a public library.
• Not for profit: libraries operated as for-profit businesses are not eligible.

Tribal status

The higher Tribal discount and floor described below depend on Tribal status, which the FCC defined in 2023. Under 47 CFR 54.500, an entity is Tribal for E-Rate if it is a school operated by or receiving funding from the Bureau of Indian Education, or a school or library operated by any Tribe, Band, Nation or other organized group or community, including any Alaska Native village, regional corporation or village corporation, that is recognized as eligible for the special programs and services provided by the United States to Indians because of their status as Indians.

• A library off Tribal lands can be Tribal if a federally recognized Tribe or Alaska Native entity operates it.
• A library is not Tribal just because it is located on Tribal lands.

Tribal college and university libraries

Since the 2023 order, a library affiliated with a Tribal college or university is eligible if it also serves as a public library, with dedicated library staff, regular hours and a collection available for public use in its community. E-Rate supports the library's needs, not the wider campus network, and costs shared with other college buildings have to be split out. USAC's T-LEAP FAQ notes that these are the only libraries not required to have a budget separate from any school.

Getting set up

USAC's tips for new Tribal applicants list three first steps:

1. Get an FCC Registration Number.
2. Get a Billed Entity Number and create a user profile in the E-Rate Productivity Center (EPC).
3. Mark your entity as Tribal and give your Tribal affiliation in EPC.

Discounts, budgets and the Tribal rules

How the discount is set

USAC's discount page sets out one method for libraries and does not list a separate method for Tribal libraries. The discount depends on the share of students eligible for the National School Lunch Program in the public school district where the library, or the main branch of a library system, is located, and on whether the library is urban or rural. The top discount for Category One, which covers the connection to the library, is 90 percent.

The Category Two discount cap

Category Two covers the network inside the library, such as Wi-Fi equipment, cabling, managed internal broadband and basic maintenance. For Tribal libraries, the highest Category Two discount rose from 85 to 90 percent starting with funding year 2024. Other libraries remain capped at 85 percent for Category Two.

The Category Two budget

Each library has a five-year Category Two budget, set before the discount. For funding years 2026 to 2030 the library multiplier is $5.43 per square foot. The minimum budget, called the funding floor, is $30,175 for most libraries and $66,385 for Tribal libraries. A Tribal library under 12,226 square feet receives the $66,385 floor.

At a 90 percent discount, a $66,385 budget means E-Rate could pay up to $59,746.50 of eligible Category Two costs over the five years, with the library paying the remaining $6,638.50.

Square footage is the total area of all floors inside the library's outer walls that the library occupies, including areas closed to the public, such as server and storage rooms. Outdoor program space does not count. A bookmobile counts the area inside its outer walls. USAC gives this example of a Tribal library system with a bookmobile, a 4,000 square foot branch and a 17,500 square foot branch for funding years 2026 to 2030: $66,385 + $66,385 + $95,025 = $227,795.

Other rules that help small Tribal libraries

• Small purchases without Form 470. Since funding year 2024, a library asking for Category Two equipment and services of $3,600 or less before discount in one funding year does not have to post FCC Form 470 and wait 28 days for bids. A commercially available business-class internet service costing $3,600 or less a year, with at least 100 Mbps down and 10 Mbps up, is also exempt. The FCC still expects purchases to be cost-effective.
• A match for special construction. For Tribal schools and libraries, E-Rate matches special construction funding from states, Tribal governments or other federal agencies one to one, up to an additional 10 percentage points on top of the discount, and never above the total cost. Special construction means building facilities beyond normal installation charges.
• Other funds for your share. Funding from states, Tribal governments or federal agencies can pay the library's non-discounted share, as long as total support does not exceed 100 percent.

Is there a Tribal priority for funding?

The Tribal-specific rules we found in the FCC orders and on USAC's pages are the ones above: the higher Category Two discount, the higher Category Two floor and the special construction match. USAC's T-LEAP FAQ adds that applicants are not competing with each other for funding. While the program has a cap, it has been able to fund all eligible requests since funding year 2015.

Help with the application: T-LEAP and USAC

In its 2023 order the FCC noted that many Tribal libraries lack full-time, permanent library staff, let alone a dedicated IT person, and often rely on the IT staff of the wider Tribal government. USAC's help for Tribal libraries is built around that.

• T-LEAP. The Tribal Library E-Rate Advocacy Program pairs a participating Tribal or Tribal college library with a Tribal Library Advocate for one-on-one help: working out IT needs and eligible services, competitive bidding, the application, starting services, invoicing and later steps, including the CIPA certification. USAC says it reaches out within seven business days after a library signs up. Taking part does not guarantee funding, and the library still has to follow all program rules.
• USAC contacts. USAC has a Tribal Liaison for questions about E-Rate and T-LEAP. The E-Rate Customer Service Center is at (888) 203-8100, Monday to Friday, 8 a.m. to 8 p.m. Eastern.
• A free toolkit. USAC points small, rural and Tribal libraries with limited IT support to the Toward Gigabit Libraries Toolkit, a free tool funded through a grant from the Institute of Museum and Library Services, for understanding your broadband connection and IT needs.
• Your state library agency. It can provide the signed letter that establishes library status, and may offer E-Rate training for libraries in the state.

CIPA once E-Rate is received

E-Rate support for internet access brings the Children's Internet Protection Act (CIPA) with it. The rules are the same for Tribal libraries as for any other library.

When CIPA applies

USAC says applicants must certify CIPA compliance to receive discounts on Category One internet access and all Category Two services. A library that receives discounts only for telecommunications services certifies that CIPA does not apply.

The three requirements

1. A technology protection measure, meaning a specific technology that blocks or filters internet access. On the library's computers with internet access it must protect against visual depictions that are obscene or child pornography for all users, and harmful to minors for users under 17. An administrator, supervisor or other authorized person may disable it during use by an adult, for bona fide research or other lawful purpose.
2. An internet safety policy that addresses five topics: minors' access to inappropriate matter online; minors' safety and security in email, chat and other direct communication; hacking and other unlawful activities by minors online; unauthorized disclosure, use and dissemination of minors' personal information; and measures to restrict minors' access to materials harmful to minors.
3. Reasonable public notice and at least one public hearing or meeting on the proposed policy.

Two further duties, monitoring minors' online activities and educating them about appropriate online behavior, are written into the rules for schools. 47 CFR 54.520 does not list them for libraries.

Certification and timing

• Through funding year 2027, the library certifies on FCC Form 486, or on Form 479 to its consortium lead if a consortium applies for it. From funding year 2028 the FCC has moved the CIPA certification to FCC Form 471 and eliminated Form 486, under FCC 26-30, adopted April 30, 2026.
• In its first funding year, a library can certify that it is undertaking actions to comply. USAC's examples include a board agenda with CIPA compliance as a topic, a quote for a filter, or minutes of a public meeting where an internet safety policy was discussed. From the next funding year it must comply, with a waiver only in narrow cases.
• Under 47 CFR 54.520(e), a library that knowingly fails to ensure its computers are used in line with its certification must repay the funds and discounts received for the period of noncompliance.

Records

USAC does not ask for CIPA documents with the certification, but the library must keep them for audits and reviews: the policy and the record of its adoption; proof of the public notice and of the hearing or meeting; a description of the filter and a report showing it was in place and working during the funding year; and copies of the forms. Keep them for at least 10 years after the later of the last day of the funding year or the service delivery deadline.

The internet safety policy and public meeting in a Tribal setting

CIPA leaves most of the substance to the community. The decisions sit with the people who govern the library.

Who adopts the policy

The FCC rule speaks of the "library, library board or authority responsible for administration of a library." Depending on how the Tribe set up its library, that may be a library board, a Tribal department such as education or culture, or the Tribal council itself. Use the body that already governs the library's budget and rules, and make sure the same body, or someone it authorizes, signs the CIPA certification.

The community decides what is inappropriate for minors

Under 47 U.S.C. 254(l)(2), a determination regarding what matter is inappropriate for minors is made by the school board, local educational agency, library or other authority responsible for making it. No federal agency may establish criteria for that determination, review it, or consider the criteria used. Anything blocked beyond the CIPA floor is a local choice, made in the policy and on the record. A short list keeps lawful information open for adults and for students doing research.

Giving reasonable public notice

The rules do not define reasonable notice. Use the channels people in your community already rely on, and keep a dated copy of each:

• the Tribal newspaper or newsletter, and community radio;
• the Tribal government's website and social media pages, and the library's own;
• postings at the library, the community center and government offices;
• announcements at community gatherings, if that is how news usually travels.

Say what the meeting is about, when and where it is, and where people can read the draft policy. If the community uses more than one language, consider offering the notice and a short summary in each.

Holding the hearing or meeting

The rules ask for at least one public hearing or meeting to address the proposed policy. That can be a regular meeting of the governing body with the policy on the agenda and time for public comment, or a separate community meeting at the library. Follow your Tribe's own law and custom for public meetings. If the governing body's meetings are not open to the public, hold a separate meeting that is. Keep the agenda, the minutes with the date, and a short note of what people said.

Changing the policy later

USAC says additional meetings are not necessary when the policy is amended, unless state or local rules or the policy itself require them. Tribal law and custom may set their own expectations. Bringing significant changes back to the community also keeps the record clear.

Privacy and community data

A DNS filter sees which websites devices look up, not who is using them. Decide in the policy who may see filter records, how long they are kept, and whether they may leave the library. Follow Tribal law and policies on community data as well. Reports to the council or board should show totals, never what a person read. Policy wording you can adapt is in our public library internet filtering policy template and the guide to the CIPA internet safety policy.

A practical filtering setup for a Tribal library

The technical side is small. With a hosted DNS filter, the library sets two DNS addresses on its router and every device on that network is filtered, with nothing installed on computers. A few situations deserve planning.

A network shared with Tribal offices

When the library shares an internet line with government offices, the filter sees one public address for all of them, so they all get the same rules. If the offices need different rules, give the library its own line, use a firewall that sends each internal network to its own encrypted link, or set the encrypted link on the library's PCs. Shared lines also matter for E-Rate: support covers eligible library use, and costs shared with other users have to be split out.

Limited or costly connections

The FCC's 2023 order records how costly connectivity can be in remote Tribal communities. A DNS filter answers only the lookup at the start of each website visit, so it adds very little traffic. If your policy calls for it, blocking streaming or game downloads on public networks can also leave more bandwidth for everyone else.

Provider equipment you cannot change

Some provider-managed equipment does not let you change the DNS setting. Put a router you control behind it and set the DNS there, or use the private encrypted link on the library's PCs as a stopgap. The hosted filter setup guide walks through the steps.

The children's area and youth programs

A children's profile adds categories, forces SafeSearch and turns on YouTube Restricted Mode. Set it on the children's PCs with an encrypted link. Those PCs keep their own settings, so a staff bypass for an adult on the main network does not open them. See children's area internet filtering.

Adults who need a blocked site

Staff open the staff page, enter the PIN and choose 15, 30 or 60 minutes. Adult content opens for that network, then the filter switches back on by itself. VPN and proxy sites stay blocked. The log records the time and length, not what the adult read. Make sure every person who opens the library alone knows how to do it. The legal background is in CIPA adult unblocking in libraries.

Several library sites

If the library runs more than one outlet, each site gets its own settings, allow and block lists and staff PIN in one console. One library is $99 a month, or $990 a year. A library system gets a written quote within one business day.

Staff changes and shared IT

Write the setup on one page, name a second person with a dashboard login, and keep the records folder where the next director can find it. The filter's printable activity report, policy record and staff bypass log cover the filter part of the CIPA file. Our guide for small and rural libraries has a setup plan you can finish in one afternoon.

Sources

Every rule, date and figure on this page comes from these official sources, checked in November 2026. E-Rate rules change from year to year, so confirm them with USAC or your Tribal Library Advocate before you apply.

• FCC: Report and Order, FCC 22-8 (Tribal Library Order), CC Docket No. 02-6, adopted January 27, 2022, released January 28, 2022.
• FCC: Report and Order and Further Notice of Proposed Rulemaking, FCC 23-56 (Tribal Order), adopted July 20, 2023, released July 21, 2023.
• FCC Wireline Competition Bureau: Public Notice DA 25-471, released June 4, 2025, Category Two multipliers and funding floors for funding years 2026 to 2030.
• FCC: Report and Order, FCC 26-30, adopted April 30, 2026, paragraphs 57 to 60, on moving the CIPA certification to Form 471 from funding year 2028.
• USAC: Tribal Libraries and Tribal Applicants FAQ.
• USAC: Tribal Library E-Rate Advocacy Program (T-LEAP), Participant Process and T-LEAP FAQs.
• USAC: The E-Rate Program: Tips for New Tribal Applicants.
• USAC: Category Two Budgets, Discount Matrix (revised January 2024), Calculating Discounts and Competitive Bidding Exemptions.
• USAC: Children's Internet Protection Act (CIPA).
• Electronic Code of Federal Regulations: 47 CFR 54.520.
• United States Code: 47 U.S.C. 254 and 20 U.S.C. 9122.