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FCC Rural Broadband Accountability Plan

FCC Rural Broadband Accountability Plan

Connect America Fund:
Closing the Digital Divide in Rural America

The Connect America Fund (CAF) brings advanced communications networks and reliable, high-speed Internet access to unserved and underserved communities to help close the digital divide in rural America. A centerpiece of the Federal Communications Commission (FCC) Universal Service Fund (USF) High Cost program, the Connect America Fund provides support to telecommunications carriers to deliver affordable voice and broadband service in rural areas where the market alone cannot support the high cost of deploying network infrastructure and providing connectivity. Carriers participating in the program must offer service at rates reasonably comparable to those available in urban areas.

As part of the Rural Broadband Accountability Plan – an FCC initiative launched in early 2022 to expand oversight of carrier compliance with CAF broadband deployment obligations, ensure public funds are properly invested and enhance program transparency – USAC is publishing a series of reports detailing the results of CAF compliance monitoring. USAC compiled these reports using data collected in a three-part compliance process that checks to ensure that carriers that receive CAF support are bringing broadband to rural America as required.

Please send RBAP questions or comments to RBAP@USAC.org

Three-Part Framework: Monitoring CAF Compliance

The Connect America Fund consists of a nearly a dozen modernized funds that rely on incentive-based models and competitive bidding to allocate set monthly payments to carriers to deploy and maintain robust communications networks – which provide voice service and broadband at required speeds – in eligible areas over a defined timeline, with interim and final deployment milestone deadlines. Carriers participating in modernized funds that subsidize fixed broadband must connect a specific number of locations in eligible areas over the fund’s deployment timeline. Modernized funds include the Rural Digital Opportunity Fund (RDOF), CAF Phase II Auction, CAF Phase II Model, ACAM I, Revised ACAM I and ACAM II, among others.

Find detailed information about the different programs that make up the Connect America Fund on the High Cost funds page. Use the High Cost disbursements search tool to look up support amounts paid to participating carriers.

USAC monitors compliance with broadband build-out obligations to ensure that carriers are using this funding to deploy high-speed Internet access that meets minimum speed and latency standards to required location counts by relevant deployment milestone deadlines in rural areas eligible for support. This compliance framework, which starts with broadband deployment data reported by carriers, is critical to safeguarding the accountability, transparency and integrity of the Connect America Fund program. It consists of three steps:

See below for detailed explanations of each part of this process.

Compliance Gap Measures: Addressing Deployment Shortfalls

Carriers that miss interim deployment milestones and are found to be out of compliance with deployment obligations face increased reporting requirements and potential withholding/recovery of support. The FCC has established four compliance gap tiers, with penalties tied to the percent of the deployment shortfall (as measured against total deployment obligations):

Non-Compliance Tier Compliance Gap Non-Compliance Measure
1 5 percent to less than 15 percent Require quarterly reporting
2 15 percent to less than 25 percent Require quarterly reporting and withhold 15 percent of monthly support
3 25 percent to less than 50 percent Require quarterly reporting and withhold 25 percent of monthly support
4 50 percent or more Require quarterly reporting and withhold 50 percent of monthly support; after six months, withhold 100 percent of monthly support and recover percent of support equal to compliance gap + 10 percent of support disbursed to date

USAC will recover support from carriers that miss their final deployment milestone.

HUBB Portal: Tracking Broadband Deployment

Carriers with defined fixed broadband deployment obligations – which require them to provide voice and broadband service to a specific number of fixed locations in areas eligible for funding – must file data annually with the High Cost Universal Broadband (HUBB) portal showing where they are building out mass-market, high-speed Internet service using CAF support. This information includes latitude and longitude coordinates, minimum speeds offered and date of deployment for every location where service is available. Carriers have until March 1 to report location data for broadband deployed with CAF support in the previous calendar year or certify that they have “no locations to upload” (no deployment).

Carriers with deployment milestones must also complete milestone certifications as part of the HUBB filing process – including separate milestone certifications for separate deployment obligations by speed tier – and may face verification reviews tied to those milestones. A carrier must notify the FCC and USAC, and relevant state, U.S. Territory or Tribal governments if applicable, within 10 business days of the deadline if it fails to meet a deployment milestone.

The HUBB performs automated, real-time validation checks of the deployment data submitted by the carriers. The system validates, for instance, that a location’s latitude and longitude coordinates fall within an area eligible for funding and that the location is not a duplicate of one already filed. The HUBB also checks that the deployment date falls within the timeline of the fund in which the carrier participates and calculates carrier progress toward meeting the fund’s broadband build-out obligations and deployment milestones. The HUBB will not accept locations that do not pass these automated validation checks and carriers will not receive credit for those deployments.

The HUBB is the foundation for the Connect America Fund (CAF) Map, which is an interactive online map that shows the impact of CAF support on broadband expansion in rural America. The CAF Map displays the geographic areas that are eligible for CAF support, as well as the specific fixed locations where carriers participating in the program have built out broadband service. The dataset reflected in the map includes address, latitude and longitude coordinates, carrier name, deployment year and minimum speeds available. USAC independently verifies deployment to a sample of locations reported in the HUBB each year to monitor carrier compliance with CAF build-out obligations.

For more information about the annual HUBB filing, please visit the HUBB resource page.

Fixed Location Annual Milestone Reports: These reports show annual fixed broadband deployment milestone obligations by fund, and the compliance status of the individual carriers in each fund in meeting those milestones based on data certified in the HUBB. Note that these reports have multiple viewing options. Click on the “+, -, 1, 2, 3” icons in the upper left-hand corner to adjust viewing settings. The HUBB Milestone History report displays annual fund-level compliance with deployment milestone obligations across all carriers participating in the fund.

Fixed Locations Quarterly Compliance Reports: These reports show carriers that must report quarterly in the HUBB because they missed deployment milestones and are out of compliance with deployment obligations, as well as their progress in closing compliance gaps on a quarterly basis.

Verification Reviews: Confirming Broadband Deployment

The HUBB serves as a starting point for verification reviews to confirm deployment to a random sample of locations reported by carriers. All carriers participating in CAF programs with defined fixed broadband build-out obligations are subject to this verification process, with verification reviews tied to annual deployment milestones. Under Rural Broadband Accountability Plan, USAC also conducts some verification reviews before required deployment milestones and subjects carriers receiving the largest dollar amounts and carriers considered higher risk to additional reviews and audits. In addition, USAC performs verification reviews at the request of carriers that complete deployment ahead of required milestones and are seeking to reduce their Letters of Credit (LOC) values.

The goal of the verification review process is to confirm that:

  • The structure at the reported location is eligible for CAF support. (Examples of eligible structures include housing units, apartment buildings and small businesses that would subscribe to consumer-grade broadband. Examples of ineligible structures include community anchor institutions, buildings that are under construction or abandoned, condemned properties or shelters open to the elements.)
  • The reported service address accurately corresponds with the reported latitude and longitude coordinates for the location record.
  • The upload and download speeds available at the location are at or above the speeds the carrier is required to deliver.
  • The carrier deployed broadband service at the required speeds at the location in time to meet the relevant deployment milestone date.
  • The actual number of units or dwellings at the location accurately ties back to the reported number of units or dwellings for the location record.

Carriers must supply documentation that can serve as evidence of deployment to all locations selected for verification review. Examples of acceptable documentation include:

  • Subscriber bills
  • Screen shots from a public-facing service availability tool showing upload/download speeds available at a particular address
  • Letters of certification certified by an outside engineer licensed by the state (including Professional Engineer number) where service was deployed
  • Screen shots from an internal provisioning system showing the broadband speeds available at a particular service address (and associated geo-coordinates if available)
  • DSLAM construction project completion acceptance test and sign-off sheets that release all locations tied to this DSLAM to sales for marketing
  • Engineering team emails showing that all locations tied to a particular DSLAM are released to sales for marketing

For more information about the USAC verification process, please visit the verification resource page.

Fixed Location Annual Verifications Reports: These reports show the results of annual verification reviews of carriers in funds with fixed broadband deployment milestones, including compliance gap findings. Note that these reports have multiple viewing options. Click on the “+, -, 1, 2, 3” icons in the upper left-hand corner to adjust viewing settings. The Verifications History report displays annual verification status at the fund level, based on results of verification reviews of all carriers in the fund that are selected for review.

Network Performance Testing: Measuring Speed and Latency

The HUBB also serves as a starting point for the Performance Measures testing framework, which ensures that broadband service subsidized by the Connect America Fund meets speed and latency performance standards so that people living in rural communities have access to the same high-quality networks as those living in urban areas.

Established by FCC orders in 2018 and 2019, this framework requires carriers with defined fixed broadband deployment obligations to conduct speed and latency testing at a USAC-generated random sample of CAF-supported locations with active subscribers for one week of each quarter of the calendar year and submit the results to USAC as part of the annual compliance process. The FCC mandates that at least 80 percent of network speed measurements be at 80 percent of required speeds and 95 percent of latency measurements be at or below 100 milliseconds round-trip time for low-latency connections, or 750 milliseconds round-trip time for high-latency connections. The FCC will consider failure to meet a fund’s speed and latency requirements as a failure to deploy and may withhold and/or recover support from carriers that do not comply.

Before official testing begins, carriers are subject to a year of quarterly “pre-testing.” During pre-testing, carriers must conduct performance measures testing at a USAC-generated random sample of CAF-supported broadband locations with active subscribers for one week of each quarter of calendar year and submit the results to USAC within one week of the end of the quarter. Carriers do not face withholding of support for failing to meet speed and latency standards during pre-testing as long as they submit the required test data.

USAC calculates carrier compliance with applicable performance standards separately for each state and speed tier – as well as each fund in which a carrier participates – based on certified test results submitted through a USAC system called the Performance Measures Module (PMM). This system: (1) lets carriers identify locations deployed with CAF support and reported in the HUBB that have active subscribers; (2) generates a random sample of those locations for speed and latency testing and provides the obligated speed tiers to be tested (based on the speed tiers reported for those locations in the HUBB compared with the speeds carriers are required to deliver); (3) collects the speed and latency test results from carriers; and (4) calculates compliance with performance measures standards based on certified test results.

For more information about Performance Measures testing, please visit the PMM resource page. For a detailed explanation of how USAC calculates compliance results, please see PMM Compliance Calculations.

Performance Measures Quarterly and Annual Testing Results: These reports show the results of quarterly speed and latency testing for carriers in funds that conducted official testing in 2021 or 2022, as well as annual results based on testing data from all four quarters of those years. USAC did not recover support from CAF II Model carriers whose annual testing results did not meet FCC performance measures standards if those carriers came into compliance with the required standards during the fourth quarter of 2021 (which was the end of CAF II Model support term) (See paragraph 73 of DA 19-104 and 47 CFR §54-320(d)(2))

Performance Measures Quarterly and Annual Pre-testing Results:

These reports show the results of quarterly speed and latency pre-testing for carriers in funds that conducted pre-testing in 2020, 2021 or 2022, as well as annual results based on pre-testing data from all four quarters of those years. The carriers in these reports are not listed by name because they were still in the pre-testing phase of performance measure testing.

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