Fund Verification Reviews

The Connect America Fund (CAF) aims to close the digital divide by requiring carriers to meet defined broadband build-out obligations across rural America. The program provides support to eligible telecommunications carriers (ETCs) to deliver service in rural, insular and other high cost areas at rates reasonably comparable to those in urban communities.

USAC and the FCC are committed to ensuring Connect America Fund support is being spent as intended. USAC’s compliance reviews are designed to confirm that participating carriers are meeting broadband deployment obligations in accordance with FCC rules through a two-step process: validation and verification.


Carriers with deployment obligations must report regular progress toward their milestones by filing broadband deployment data and related certifications with USAC’s High Cost Universal Broadband (HUBB) portal showing where they are building out high-speed Internet service by latitude and longitude.

The HUBB performs real-time validation of this geolocated deployment data by conducting a series of automated checks of the information. Among other things, the system validates that the latitude/longitude of a reported location falls within an area eligible for funding and that the location is not a duplicate of one that has already been filed.


The HUBB also acts as a platform for in-depth verification reviews to substantiate broadband deployment and confirm that carriers are in fact building out service that meets the FCC’s minimum performance standards to the locations reported in the system. All carriers participating in CAF programs with deployment obligations are subject to this verification process, starting with carriers participating in the CAF Phase II model-based support and Rural Broadband Experiments (RBE) programs.

Document Retention

USAC reminds all carriers to retain all records and analysis needed to demonstrate that universal service support is being used in accordance with High Cost Program rules. This includes sufficient documentation to prove that a carrier built out broadband service meeting the FCC’s minimum performance requirements to a qualifying number of locations by the applicable deployment milestone deadlines (see 47 CFR § 54.320(b)).

Verification Review Process

The goal of the verification review is to verify that a carrier deployed broadband service meeting the FCC’s requirements to a qualifying number of locations by the applicable deployment milestone deadlines.

Step One: Announcement and Data Collection

Following deployment milestone deadlines, USAC will select certain carriers for verification of deployed locations. For each carrier it selects, USAC will sample a statistically valid number of locations from those certified in the HUBB. USAC will send an announcement letter to the selected carrier identifying the sampled locations. USAC will then schedule an entrance conference with the carrier to discuss the verification process, provide examples of acceptable supporting documentation, and answer any questions.

Step Two: Testing

After receiving supporting documentation, USAC will begin the verification testing process. USAC encourages carriers to send documentation to the verification team as it becomes available, rather than waiting to provide everything at once. This will expedite the review process.

USAC’s verification team will contact carriers if it has questions or requires further documentation.

Step Three: Conclusion

At the conclusion of the verification process, USAC will hold an exit conference with the carrier. At this time, USAC will provide details of the findings. After the exit conference, USAC will send a closure letter summarizing any findings, and the carrier will have an opportunity to respond.

If the verification process indicates that a carrier failed to meet a milestone, the carrier may be subject to increased reporting obligations and support reductions, as outlined in 47 CFR § 54.320(d).