Annual Requirements

To participate in the High Cost program, a carrier must be certified as an eligible telecommunications carrier (ETC) on an annual basis. State utility commissions must certify that carriers under their jurisdiction are eligible to receive High Cost support in their states and used all support received in the proceeding calendar year only to provide, maintain, and upgrade the facilities for which the support was intended and will do the same in the coming calendar year.

Carriers that self-certify (i.e., ETCs not subject to state jurisdiction) must certify that they used all High Cost support received in the proceeding calendar year only to provide, maintain, and upgrade the facilities for which the support was intended and will do the same in the coming calendar year.

State utility commissions and carriers that self-certify must submit this certification to USAC and the FCC by October 1 every year through USAC’s E-File/One Portal system.

Learn more about obtaining ETC certification.

Eligible telecommunications carriers (ETCs) participating in the High Cost and/or Lifeline programs must file FCC Form 481 on an annual basis. This form collects financial and operations information used to validate carrier support, as well as details about carrier engagement with Tribal governments, among other data. Carriers must complete and submit FCC Form 481 online through USAC’s E-File/One Portal system. This form is typically due by July 1.

Learn more about filing FCC Form 481.

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 support – 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.

The HUBB conducts 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 that has already been filed. The HUBB also checks to be sure that the date of deployment 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, including interim 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.

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.” Carriers with annual deployment milestone deadlines must also complete milestone certifications as part of the HUBB filing process and will 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. Carriers that miss milestones face increased reporting obligations, including quarterly HUBB reporting and potential loss of support.

The HUBB dataset is the foundation for the Connect America Fund (CAF) Map and the Connect America Fund (CAF) State Map, interactive online maps that show 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 participating carriers report offering mass-market, high speed Internet service funded by the program. The CAF State Map provides a big-picture, state-level view of CAF-supported deployment.

See the HUBB Dashboard for a high-level snapshot of deployment totals based on data certified in the system as of March 6, 2024, to reflect broadband deployment through Dec. 31, 2023, including deployment numbers by fund, speed tier and state. The HUBB Dashboard shows that as of Dec. 31, 2023, carriers had reported deployment to nearly 9.1 million fixed locations, including nearly 2.2 million fixed locations with speeds of a gigabit or faster.

Learn more about filing data in the HUBB.

Carriers with defined broadband deployment obligations are subject to in-depth verification reviews to substantiate reported deployment and confirm that they are in fact building out service that meets the FCC’s performance standards at a statistically valid, randomly selected sample of eligible locations submitted to the HUBB. Verification reviews are tied to deployment milestones, although USAC also conducts some verification reviews before milestones and subjects carriers receiving the largest dollar amounts and carriers considered higher risk to additional reviews and audits.

During verification, carriers must supply documentation that serves as evidence of deployment at the required upload and download speeds by the relevant deployment deadline to all locations selected for review. Examples of acceptable documentation include: customer bills, screen shots from external service availability and internal provisioning tools, letters of certification by outside engineers, engineering emails releasing locations for sale, and project completion acceptance tests and sign-off sheets. If a review concludes that a carrier failed to meet a deployment milestone, the carrier may be subject to increased reporting obligations, including quarterly HUBB reporting, and support reductions.

Learn more about participating in verification reviews.

Carriers with defined fixed broadband deployment obligations are subject to FCC performance measures testing requirements, which ensure that CAF-supported broadband service meets basic speed and latency standards so that people living in rural communities have access to the same high-quality networks as those living in urban areas.

Under this framework, carriers must conduct network speed and latency pre-testing or testing at a USAC-generated random sample of CAF-supported broadband 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. The FCC considers failure to meet a fund’s speed and latency requirements as a failure to deploy and may withhold support from carriers that do not comply.

USAC has built a system called the Performance Measures Module (PMM) to support this compliance process. The PMM lets carriers identify which locations that have been deployed with CAF support and reported in the HUBB have active subscribers; 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 that carriers are required to deliver); collects the speed and latency test results from carriers; and calculates compliance with performance measures standards based on certified test results.

Learn more about conducting network testing.

Carriers that have been part of a “mixed merger” since May of 2018 are subject to a Federal Communications Commission (FCC) requirement called the “Hargray condition.” A mixed merger is a transaction in which a carrier receiving legacy, cost-based support acquires or is acquired by a carrier receiving fixed monthly support, such as model-based funding.

The “Hargray condition” caps the operating expenses of the carriers of the combined entity that receive cost-based support in order to prevent potential cost shifting, and requires carriers to certify compliance annually and submit financial statements to USAC.

Learn more about meeting mixed merger requirements.