Summary

  • Carriers covered by the FCC’s performance-measures framework must certify Q3 speed and latency results in USAC’s Performance Measures Module by October 15, after the testing week ended September 30.
  • A missing result requires a reasoned PMM attestation; it is not the same as a failed speed or latency measurement, and the selected sample does not describe every supported household.

The test week is over. The compliance record is not. On October 15, carriers receiving several forms of Connect America Fund support must submit and certify third-quarter speed and latency results through the Universal Service Administrative Company’s Performance Measures Module (PMM), or explain why required testing produced no data. The deadline covers the reporting stage; it is not an extra two weeks to run the test.

USAC’s October 6 reminder applies to Original ACAM, Revised ACAM, Rural Broadband Experiments, the Alaska Plan, ACAM II, CAF Broadband Loop Support and the CAF II Auction, as well as Alaska Communications System. Separate notices set the same deadline for Rural Digital Opportunity Fund and Puerto Rico and US Virgin Islands fixed-support carriers, and for Enhanced ACAM participants conducting pre-tests. The groups share a date but not an identical testing stage.

The underlying measurement is narrower than the phrase “rural broadband performance” can suggest. During one week each quarter, USAC selects a random sample of subscriber locations built with CAF support and reported in the High Cost Universal Broadband portal. Carriers test the locations for each obligated speed tier, then submit the complete sample’s results for each Study Area Code (SAC) and tier. The FCC’s benchmarks require at least 80 per cent of speed measurements to reach 80 per cent of the required speed, and 95 per cent of latency measurements to be at or below 100 milliseconds round-trip time. These are tests of sampled, supported fixed connections, not a census of every home or a promise about each customer’s daily experience. USAC describes the method and benchmarks here.

The important change is what happens when a test result does not exist. In March, the FCC’s Wireline Competition Bureau said the PMM had been updated to accept “nothing to report” certifications. A carrier can identify that there were no active subscribers for a speed tier; that it had active subscribers and obtained a sample but lacked time to arrange testing; or that it had subscribers but did not test. Since the April 15 filing, email to the FCC or USAC is no longer an accepted substitute for those quarterly certifications. The reason and explanation belong in PMM. FCC Public Notice DA 26-277 sets out the choices.

USAC’s current instructions add an operational distinction. A carrier with no locations in the deployment portal, or no active subscribers to test for a particular SAC and speed tier, must attest and explain; the agency may verify that subscribers were unavailable. Other reasons for not testing, including receiving a sample but not having time to set up measurements, must also be reported. Those cases may affect compliance calculations or future support. The language is conditional: a missing test does not establish that a carrier failed its speed target, and the October reminder does not say that any named carrier will lose funding.

But silence is no longer a complete filing.

The deadline also lands differently across programs. RDOF and the Puerto Rico and USVI fixed-support funds did not have to test in the first two quarters of 2026 while their deployment records moved from addresses and coordinates to identifiers from the FCC’s Broadband Serviceable Location Fabric. Because those location records are the starting point for selecting subscribers, USAC required new random samples for Q3. The funds resumed testing in July–September, and USAC will calculate their 2026 annual compliance using the two quarters available this year. That is a transition-specific waiver, not a general suspension of performance testing.

Enhanced ACAM is different again. Its participants are in pre-testing in 2026, with official testing scheduled to begin in 2027. During pre-testing, timely submission or an allowed no-subscriber attestation has a different support consequence from an official performance failure. Treating every October 15 filing as the same kind of test would erase a distinction that the funding rules preserve.

PMM’s dashboard makes the record legible by showing, for each required SAC and speed tier, whether a sample was generated, test data were uploaded, and the data were certified—or a no-subscriber or no-testing reason was entered. Operators can filter by quarter, fund and state. That view helps find an incomplete chain, but it is not independent proof that every supported location works. The chain still depends on a correct deployment record in the portal, a valid selected sample, measurements at the selected premises and a carrier’s certification. USAC says results remain subject to verification and audit.

That is why “no result” needs its own category. A low speed reading is evidence about a measurement; an absent reading is evidence that the measurement or its reporting did not occur. The second state can be acceptable for a narrowly explained reason, or expose a process failure with funding consequences. Neither can be interpreted correctly from an empty dashboard cell alone.

As October 15 approaches, the useful question is therefore not simply whether a carrier has uploaded a graph. It is whether each required sample has a result or a specific, timely and reviewable explanation—and whether that record points back to the same supported location and speed obligation. The rule sharpens accountability around the evidence chain. It does not turn a sample into a map of every rural customer’s service.

Sources