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.
Verification Review Process
The goal of the verification review is to confirm that a carrier deployed broadband service meeting the FCC’s minimum performance standards to a qualifying number of locations by the relevant deployment milestone deadlines. Carriers will be required to submit documentation that can serve as proof of deployment for each location reported in the HUBB that is selected for verification review. This documentation must include evidence that:
- the service address or location ties back to the latitude and longitude coordinates reported for that record in the HUBB (i.e. location)
- the upload and download speeds available at that location are at or above the speeds that the carrier is required to deliver (i.e. broadband speed)
- the carrier deployed broadband at the required speeds in time to meet the relevant deployment milestone date (i.e. date of service availability)
Examples of acceptable documentation (see samples below) 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 sign-off sheet that releases all locations tied to this DSLAM to sales for marketing
- Engineering team email showing that all locations tied to a particular DSLAM are released to sales for marketing
Note that carriers may need to submit more than just one piece of evidence to prove location, speed and date of service availability for a particular record in the HUBB. 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 (see 47 CFR Section 54.320(b)).
Verification of Multi-Unit Locations
Verification reviews of multi-unit locations – i.e. locations with more than one living unit, such as apartment buildings or duplexes – will also confirm that the number of actual units at the location selected for review ties back to the number of units reported for that location in the HUBB. Carriers will be required to submit documentation to prove the existence of each individual unit at that location. Examples of acceptable documentation (see samples below) include:
- Subscriber bills for each individual unit at the location
- Screen shots from a public-facing service availability tool showing upload/download speeds available for each individual unit at the location
- Screen shots from an internal provisioning system showing upload/download speeds available for each individual unit at the location
- Screen shots of a mapping software street view or satellite view of the location that provide evidence of the number of units at that location, such images showing two separate front entrances or two separate driveways
- Screen shots from an apartment complex website, property tax website or real estate website (such as Realtor.com, Xome, Trulia, Redfin, etc.) showing the number of units at the location
- Geotagged photos or video clips (taken using a mobile phone or camera with geotagging turned on) that provide evidence of the number of units at the location, such as images of separate electric meters or separate mailboxes, along with a screenshot of the file properties page for each picture or video that displays the associated latitude/longitude coordinates
Carriers that cannot provide acceptable documentation proving the number of units at a multi-unit location reported in the HUBB may see a reduction in the number of units counting toward their deployment obligations.
Carriers should also be sure not to group separate single-unit locations together – using the same latitude/longitude coordinates, but labeled as multiple units at one location – when reporting deployment in the HUBB. This can occur when a geocoding application cannot find addresses in rural areas and selects the latitude/longitude coordinates for the centroid of the ZIP Code area or census block for those locations instead – in effect assigning the same erroneous coordinates to multiple locations in the same ZIP code or census block. These locations will not pass verification review. Please see the FCC 2016 Guidance on Location Reporting, as well as the USAC Guide to Geolocation Methods, for information on how to collect accurate latitude and longitude coordinates for individual locations.
Step 1: 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.
Step 2: 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 3: 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 Section 54.320(d).