On October 13, 2026, Defending Education filed a public comment with the Federal Communications Commission in support of its Notice of Proposed Rulemaking, “Ensuring Children’s Safe Use of Screens and E-Rate-Funded Services.” The E-Rate program disburses roughly $3 billion a year to connect schools and libraries to the internet, but it now underwrites all-day, one-to-one device use beginning in kindergarten. Nearly 100 percent of public schools provide devices to students, and a quarter of children spend more than four hours of the school day in front of a screen. Notably, reading and math scores have fallen over the same period that classroom screen use has roughly doubled. The NPRM asks whether E-Rate support should be conditioned on screen-time limits and whether parents should be able to opt their children out of screen-based instruction. It also asks whether schools’ Children’s Internet Protection Act safety policies should be made public.
Our comment commends the Commission for returning the program to Congress’s original “educational purposes” mandate and for centering the program’s administration on parental involvement. The comment emphasizes that a parent’s right to direct a child’s upbringing and education is fundamental and constitutionally protected, and that every safeguard in the NPRM, from screen-time caps to network-level filtering to a parental opt-out, depends on parents being able to see what schools are doing on federally subsidized networks. We also answered the partisan objections to transparency raised against the Commission’s related media inquiry, noting that recent Supreme Court decisions in Mahmoud v. Taylor and Mirabelli v. Bonta confirm that a school’s administrative convenience does not outrank a parent’s role.
We also offered recommendations to make the final rule effective at the lowest regulatory cost. These included requiring every E-Rate recipient to post its CIPA Internet safety policy online and file it with USAC; requiring a plain-English annual disclosure to parents of expected screen time by grade, the software in use, the filtering and monitoring safeguards in place, and whether student data is shared with vendors or used to train AI systems; adopting a meaningful parental opt-out from screen-based instruction with a non-screen alternative; revisiting the Commission’s 2011 conclusion that social media is not “harmful to minors” in light of this year’s jury verdicts and the $17.1 billion Meta settlement; and requiring schools to state their own screen-time limits by grade and identify the independent research on which they relied.
