Reminder on PMM Filing Requirements & Updates on Pre-May 25, 2016, Locations for Legacy (CAF BLS) Companies

Thoughtware Alert Published: Jan 31, 2022

All Connect America Fund (CAF) carriers have an upcoming filing deadline in USAC’s Performance Measures Module (PMM) to test one week for the randomly assigned locations in the first quarter of 2022 by March 31, 2022. 

For this requirement, CAF includes all of the following funds:

  • CAF Phase II Model (Price Cap carrier support)
  • A-CAM I
  • A-CAM I Revised
  • A-CAM II
  • CAF Broadband Loop Support (CAF BLS, also known as Legacy carriers) 
  • Rural Broadband Experiment (RBE)
  • AK Plan, CAF Phase II Auction winners 
  • RDOF Phase I Auction winners

For companies that have already undergone pre-testing in 2020 or 2021—CAF Phase II, RBE, A-CAM I, and A-CAM I Revised—this is a live/actual test year. Live/actual test companies report on an annual basis by July 7 of the following year. While not required, they are “strongly encouraged” by USAC to report quarterly. If you elect to voluntarily report quarterly, results must be uploaded, certified, and submitted to USAC no later than April 7, 2022.

For A-CAM II, Legacy/CAF BLS, and CAF Phase II Auction companies, this is the pre-test year. 

  • Pre-testing companies MUST report the results of pre-testing on a quarterly basis within seven days of the end of the quarter
  • First quarter 2022 pre-testing results must be uploaded, certified, and submitted to USAC no later than April 7, 2022 
  • Companies that currently do not have any 25/3 Mbps or greater locations and/or customers will not start pre-testing in the first quarter 2022
  • Instead, companies without any 25/3 Mbps locations and/or customers are to postpone pre-testing until such time as there are enough to start pre-testing

We strongly recommend you print out the pages that confirm your certification and submission, in case there are any glitches with USAC’s system, to prove your timely submission.

For companies that pre-test this year, failure to upload results, certify, and submit to USAC no later than April 7, 2022, may result in USAC placing the company in level 1 non-compliance, which triggers a 5 percent withholding of USF funds. Withheld USF funds are returned as soon as the company fulfills a subsequent quarter’s obligations.  

USAC has finally announced the process for including pre-May 25, 2016, deployed locations in PMM. USAC also announced the process for companies with less than 150 locations currently in the High Cost Universal Broadband portal (HUBB). 

  • Companies impacted by either issue will log into the PMM and download a “Performance Subscriber Data Upload Template.csv” file created by USAC, which is unique to each company
  • This template will include any locations currently in the HUBB as well as partially completed rows to input 25/3 Mbps or greater customers deployed prior to May 25, 2016 
  • In the partially completed rows, add the latitude, longitude, and address 
  • Also, companies should verify or update the speed tier assigned and the number of units and update as needed
  • Once that is done, in the existing HUBB locations, as well as any partially completed rows, add the Subscriber Identification Number (SIN)
  • For existing HUBB locations, remove any locations if there is not currently a 25/3 Mbps or greater customer at that location or leave them on the file but do NOT assign a SIN
  • Once the file is completed, it is uploaded to the PMM and the PMM process continues with the “normal” steps that all companies take

Please reach out your BKD Trusted Advisor™ or submit the Contact Us form below if you have any questions. 

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