The FCC is considering changes to its E-Rate program that could affect Technology Advisors. TCSP has taken a stand to protect our industry. Now we need your help.
Technology Advisors play an important role in helping schools, libraries, businesses, and other organizations navigate an increasingly complex technology marketplace. Yet the value we bring to customers isn't always understood by regulators. That lack of understanding can have serious consequences.
The Federal Communications Commission (FCC) is currently considering changes to its E-Rate program, which helps eligible schools and libraries obtain affordable telecommunications and internet services. Among the questions raised in its Notice of Proposed Rulemaking (NPRM) is whether Technology Advisors should be included in—or excluded from—the regulatory definition of a "consultant."
That distinction matters. A great deal.
On October 13, 2026, Technology Channel Sales Professionals (TCSP) filed formal comments with the FCC, strongly advocating that Technology Advisors acting as provider-compensated sales agents be excluded from the definition of consultant.
But filing comments is only the beginning. We need Technology Advisors who participate in the E-Rate marketplace to help us make the case.
We've Seen What Can Happen When Our Industry Doesn't Have a Voice
This isn't the first time the FCC has considered regulations affecting Technology Advisors.
In 2019, the FCC adopted changes to its Rural Health Care (RHC) program that restricted the use of program funds for certain sales commissions and related compensation. The regulatory approach reflected a troubling lack of recognition of the value that Technology Advisors bring to the procurement process.
The consequences for advisors serving that market were significant.
At the time, our industry lacked a unified association dedicated to representing Technology Advisors before regulators and policymakers. There was no organized voice specifically focused on ensuring the FCC understood our business model and the value we provide.
That's one of the reasons TCSP exists today.
We cannot assume regulators understand how Technology Advisors operate, how we are compensated, or why customers choose to work with us.
And we cannot afford to wait until regulations are finalized before making our voices heard.
What TCSP Told the FCC
In its formal comments, TCSP urged the Commission to recognize the important distinctions between independent procurement consultants and Technology Advisors who serve as provider-compensated sales professionals.
Our filing emphasized several key points:
Technology Advisors provide real value. Advisors help customers evaluate complex technologies, understand available solutions, navigate provider offerings, and make informed purchasing decisions. Their expertise can be particularly valuable to schools and libraries that lack extensive internal technology resources.
Provider-paid commissions are not consultant fees. Technology Advisors are typically compensated by service providers through commissions associated with the sale of services. That compensation model is fundamentally different from arrangements in which a consultant is hired and paid by an E-Rate applicant to manage its procurement process.
Technology Advisors should not automatically be treated as procurement consultants. The regulatory definition should distinguish between individuals who control or manage an applicant's competitive bidding process and sales professionals who help customers understand and purchase available services.
Regulations should protect program integrity without unnecessarily restricting legitimate sales activities. TCSP supports appropriate safeguards, transparency, and accountability in the E-Rate program. But those protections should recognize the legitimate role of Technology Advisors rather than inadvertently discouraging their participation.
TCSP also highlighted opportunities for Technology Advisors to help schools and families address emerging technology challenges, including online safety and tools that help manage children's screen time.
Our position is straightforward:
Technology Advisors are part of the solution, not a problem that needs to be regulated out of the marketplace.
TCSP Is Not Fighting This Battle Alone
Other organizations representing segments of the telecommunications industry have also expressed support for distinguishing legitimate provider-side sales activities from the role of procurement consultants. That is encouraging.
But there is an important difference between telecommunications providers advocating for their interests and Technology Advisors advocating for ours.
Our business model, our compensation structure, and our relationships with customers deserve direct representation. That's TCSP's job.
We are working to ensure that policymakers hear from the people who actually work in the Technology Advisor channel—not simply from those who provide the services we sell.
And while our formal filing is an important step, the most compelling arguments may come from the Technology Advisors who participate in E-Rate transactions every day.
Now We Need Your Help
If your firm sells telecommunications, internet, or other technology services to schools or libraries through the E-Rate program, we want to hear from you.
We are organizing a grassroots advocacy effort to supplement TCSP's formal comments with input from Technology Advisors who have firsthand experience in the E-Rate marketplace.
Your perspective can help the FCC better understand how our industry operates and what could be at stake.
We are particularly interested in hearing from advisors who can explain:
How you help schools and libraries identify, evaluate, and purchase technology services.
How your compensation arrangements work and how they differ from applicant-paid consulting relationships.
What role you play—and do not play—in customers' competitive bidding and procurement decisions.
How an overly broad definition of consultant could affect your business and the customers you serve.
Why your participation benefits schools, libraries, service providers, and ultimately the E-Rate program.
You do not need to be a TCSP member to participate.
This issue affects our entire industry, and we welcome the involvement of every Technology Advisor with relevant experience.
TCSP will provide guidance and suggested comment templates to make participation as straightforward as possible. We want your comments to reflect your actual experience, in your own voice.
The FCC's current deadline for reply comments is November 12, 2026, so time is limited.
This Is Why TCSP Matters
For too long, Technology Advisors have operated without a strong, coordinated voice representing their interests in Washington. That's changing.
TCSP was established to advocate for, educate, elevate, and curate resources for the Technology Advisor community. Advocacy isn't simply something we talk about. It's something we do. Our work on the E-Rate NPRM is a concrete example of that commitment.
We are monitoring regulatory developments, engaging policymakers, submitting formal comments, and working to ensure our industry's perspective is represented when decisions are being made.
We hope the FCC ultimately adopts regulations that appropriately distinguish Technology Advisors from procurement consultants. But whatever the outcome, one thing should be clear:
The Technology Advisor community is no longer without a voice. And that voice becomes stronger when more of us participate.
Get Involved Today
If you are a Technology Advisor involved in the E-Rate program, please contact TCSP now. Tell us you're involved in E-Rate and want to participate in our advocacy effort.
We'll follow up with information about how you can help, including guidance and templates for submitting your perspective to the FCC.
Whether you're a TCSP member or not, we want you involved.
TCSP is fighting for the Technology Advisor industry. Now is the time to stand together and make sure Washington hears us.