USACHigh CostAnnual Requirements
Performance Measures Testing

Performance Measures Testing

The FCC performance measures testing requirements aim to maximize the impact of Connect America Fund (CAF) investments to close the digital divide in rural America and ensure that people living in rural communities have access to the same high-quality networks as those living in urban areas.

Established by FCC orders in 2018 and 2019, this testing framework confirms that broadband service subsidized by the Connect America Fund meets basic performance standards by requiring carriers to conduct quarterly speed and latency testing of CAF-supported networks that provide fixed-location connections and submit the test results to USAC as part of the 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. Carriers that fail to meet the performance measures standards required of their funds may face potential withholding of support.

Testing Requirements

The performance measures testing framework requires carriers to conduct one week of speed and latency testing using a random sample of CAF-supported broadband locations with active subscribers selected by USAC in each quarter of the calendar year and to submit the test results to USAC on a quarterly basis. Testing mandates apply to carriers participating in the following funds:

The windows to start testing vary by fund and began in 2020 with CAF Phase II Model carriers. Testing continues throughout a carrier’s support term. Carriers that participate in multiple funds must meet the separate testing requirements of each of those funds.

Carriers must test speed and latency from the premises of active subscribers to a remote test server located at, or reached by passing through, an FCC-designated Internet exchange point (IXP), which is any building, facility or location housing a public Internet gateway that has an active interface to a qualifying Internet Autonomous System (ASN). More information about acceptable test paths and remote server locations is available here. Carriers serving areas greater than 500 air miles from an FCC-designated IXP may conduct all required speed and latency testing between the customer premises and the point at which traffic is aggregated for transport to the continental U.S.

A speed test is a single measurement of download or upload speed of 10 to 15 seconds duration between a specific consumer location and specific remote server location that meets the FCC designated IXP requirements. Speed requirements vary by fund. Carriers must conduct at least one download test and one upload test during each testing hour at each testing location. (See FCC 19-104 at paras. 24-26)

A carrier may report that no test was successfully completed due to “crosstalk” caused by consumer activity if the consumer traffic meets thresholds of 64 Kbps for download tests or 32 Kbps for upload tests, and if the carrier begins attempting speed tests within the first 15 minutes of a testing hour and repeatedly retries and defers tests at one-minute intervals. (See FCC 19-104 at para. 26)

A latency test is a single measurement of latency, often performed using a single User Datagram Protocol (UDP) packet or a group of three Internet Control Message Protocol (ICMP) or UDP packets sent at essentially the same time. Carriers must offer broadband service with latency suitable for real-time applications, including voice over IP (VoIP) calling. Carriers must conduct one discrete latency measurement or observation per minute (60 per hour) for each testing hour at each subscriber test location. (See FCC 19-104 at paras. 27-38)

A carrier may postpone a latency test because of crosstalk if the consumer traffic load exceeds 64Kbps downstream.

To perform the required testing, carriers can use existing performance measurement tools, ping tests and other commonly available network management systems. This is a list of vendors that provide services to help carriers conduct testing and report the results to USAC. Carriers can also develop their own self-testing configuration using software installed on subscriber gateways or in equipment attached to subscriber gateways.

Testing Schedule

Deployment obligations for each fund determine when carriers participating in that fund must begin quarterly network performance testing, and carriers must continue testing throughout the fund’s support term – even if a carrier completes deployment before the end of the support term. (See FCC DA 20-1510). Carriers must submit and certify all test results for the full sample of selected subscriber locations within two weeks of the end of each quarter (Note that this quarterly filing requirement is new. Starting in 2025, carriers no longer have until the following July 1 to file and certify results for all four quarters of testing conducted during the previous calendar year. See FCC 23-87, para. 136-140).

Before the start of official testing, carriers are subject to a “pre-testing” mandate. During pre-testing, carriers must conduct performance measures testing at a random sample of CAF-supported subscriber locations selected by USAC for one week of each quarter of the calendar year, and must submit and certify all test results for the full sample of locations within two weeks of the end of the quarter. Carriers do not face withholding of support for failing to meet speed and latency standards during pre-testing as long as they submit and certify the required test results on a quarterly basis.

USAC encourages carriers to submit and certify results as soon as testing is complete each quarter, and provides quarterly compliance reports to help carriers track their progress in meeting FCC speed and latency metrics, address any shortfalls and submit any missing data. These compliance reports include details at the Study Area Code (SAC) level about the percent of upload and download speed tests and latency tests conducted in the quarter that met the network performance standards established by the FCC. For a detailed explanation of how the PMM calculates compliance, please see PMM Compliance Calculations.

Any carrier found to be out of compliance with FCC speed and latency metrics for its final year of testing (which is the final year of the carrier’s support term) can continue testing with a new and statistically valid sample of subscriber locations for one additional year to come back into compliance and avoid permanent withholding of support. (See FCC DA 20-1510)

Pre-Testing and Official Testing Years by Fund

Note that USAC and the FCC encourage ACAM and CAF BLS carriers moving to the new Enhanced ACAM fund to continue quarterly testing with their current funds in 2024 if they are at risk of being out of compliance for 2023 testing since passing quarterly results for 2024 can bring them back into compliance. (See FCC DA 23-1131)

Also note that the FCC has waived performance measures testing requirements for the fourth quarter of 2024 for carriers located in areas impacted by Hurricane Milton, which has caused widespread destruction across Florida, and Hurricane Helene, which has caused widespread damage in Alabama, Florida, Georgia, North Carolina, South Carolina, Tennessee and Virginia. The FCC defines the “Affected Disaster Areas” as the areas covered by the Milton Weather Event Declarations and the Helene Weather Event Declarations and any other emergency declarations or major disaster declarations related to these weather events. Impacted carriers must still provide broadband service that meets required speed and latency standards, but testing is optional for these carriers in the fourth quarter of 2024.

How Testing Works

USAC has built a system called the Performance Measures Module (PMM) to support this testing framework. The PMM:

  • Lets carriers identify which locations that have been deployed with CAF support and reported in the High Cost Universal Broadband (HUBB) portal 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)
    • Carriers must obtain a new random sample after two years of pre-testing/testing
  • Collects the speed and latency test results from carriers
  • Calculates compliance with performance measures standards based on certified test results
    • The PMM allows carriers to download compliance reports that provide details at the SAC level about the percent of upload and download speed tests and latency tests that met FCC network performance standards
    • For a detailed explanation of how the PMM calculates compliance, please see PMM Compliance Calculations

In order to identify locations with active subscribers for testing purposes, beginning with the testing start dates and biannually thereafter, carriers must download certified locations that they have already filed in the HUBB using a comma separated variable (CSV) file and add a carrier-generated, alpha-numeric subscriber ID – such as an account number – that serves as a unique identifier for each location with an active subscriber. Carriers should not use any personally identifiable information – such as a customer phone number or social security number – in a subscriber ID. Carriers must then upload this new file into the PMM system, which selects a random sample of those locations for speed and latency testing and provides the obligated speed tiers to be tested.

For funds with multiple speed tiers, the obligated speed tier to be tested for some locations may not be the same as the speed tier reported for that location in the HUBB. That is because the system uses a cascading logic that may select locations with higher speeds to fill a sample for testing at slower speeds if there are not enough locations with slower speeds reported in the HUBB.

USAC encourages carriers to be sure that their broadband deployment information in the HUBB is as up-to-date, accurate and complete as possible before obtaining their random samples from the PMM. Carriers should first submit any new locations that have not yet been reported to the HUBB and make any necessary edits to latitude and longitude coordinates, address information and speed tier data to reflect network upgrades if they want those updates reflected in their random samples. Note that because some carriers participate in funds that start pre-testing before the fund’s first deployment milestone, there may be some carriers that are supposed to begin pre-testing but have no locations yet in the HUBB. These carriers are not required to conduct pre-testing until they have deployment data in the HUBB, but should plan to begin pre-testing within one quarter after they do.

Carriers must test up to 50 locations for each speed tier they are required to deploy to in each state where they receive support (with sample sizes determined based on the number of active subscribers submitted to the PMM), must conduct testing at all selected locations (unless subject to FCC waiver stating otherwise) and must meet separate testing requirements for each fund in which they participate. Carriers must obtain a new random sample after two years, and cannot delete HUBB records or edit or modify the number of units for HUBB records for subscriber locations that have been randomly selected for speed and latency testing during the two years when those locations are part of the testing sample.

Carriers can only request a random sample one time, and cannot alter uploaded subscriber location data or request a new sample once a sample has been generated.

Required Test Locations

Number of Subscribers at CAF-Supported Locations per State and Service Tier Combination Number of Test Locations
50 or fewer 5
51-500 10 percent of total subscribers
Over 500 50

Carriers should use the same subscriber locations selected for both speed and latency testing, and must provide subscribers at these locations with the modem, router or other customer premises equipment needed to conduct testing at no extra cost to the customer. Consumers can find more information about the FCC performance testing program here. The FCC does not require carriers to inform subscribers at locations selected for speed and latency testing because carriers already conduct routine performance measures testing of their networks.

All speed tests for the sample must occur in the same week and all latency tests for the sample must occur in the same week, but speed and latency tests may take place in different weeks. Carriers must conduct testing between 6 p.m. and 12 a.m. local time.

Carriers can request a replacement location if the subscriber at a location selected for testing refuses to participate or allow installation of testing equipment, drops service or subscribes to a slower speed tier than the one being tested – leaving the carrier with fewer testing locations than required. Carriers should also request a replacement location if the subscriber at a location selected for testing does not use the service for a month or more but continues to subscribe (this would be considered “dropped service” in the PMM), or if the subscriber accepted but does not use or stopped using the modem provided for testing (this would be considered “subscriber demands removal of testing equipment” in the PMM).

If a carrier runs out of replacement locations with active subscribers at the required speed tiers, the carrier would need to upgrade service at the locations selected by USAC in order to conduct testing. Carriers that serve 50 or fewer subscribers in a state and particular service tier and cannot find five active subscribers for the required testing will be subject to verification that more subscribers are not available.

Conversely, the FCC allows carriers to request a larger random sample of subscriber locations that will produce test results with a margin of error of 5 percent or less at the conclusion of a carrier’s build-out term if a carrier believes it is not meeting FCC performance measures standards because its sample size is too small.

USAC developed this quick tips guide to the Performance Measures Module (PMM) to address frequently asked questions about how the system works and help troubleshoot common issues users may encounter.

Filing Test Results

Carriers must submit and certify all test results for the full sample of selected subscriber locations for each state and speed tier combination (unless subject to FCC waiver stating otherwise) within two weeks of the end of each quarter during both pre-testing and official testing. (Note that this quarterly filing requirement during official testing is new. Starting in 2025, carriers no longer have until the following July 1 to file and certify results for all four quarters of official testing conducted during the previous calendar year. See FCC 23-87, para. 136-140).

Carriers upload results in the PMM using one CSV file for speed test results and one CSV file for latency test results.

USAC encourages carriers to file and certify results as soon as testing is complete each quarter, and provides quarterly compliance reports to help carriers track their progress in meeting FCC speed and latency metrics, address any shortfalls and submit any missing data. These compliance reports include details at the Study Area Code (SAC) level about the percent of upload and download speed tests and latency tests conducted in the quarter that met the network performance standards established by the FCC. For a detailed explanation of how the PMM calculates compliance, please see PMM Compliance Calculations. Note that the PMM calculates compliance using only certified data.

As long as carriers submit and certify the required data each quarter, USAC will not withhold support from carriers that fail to meet speed and latency metrics for one or more quarters during official testing before evaluating certified data for the full year. USAC will only calculate final annual performance compliance – and withhold support from carriers that fail meet speed and latency requirements – after carriers submit and certify test data for all four quarters of the year.

Non-compliance

Carriers that receive CAF support to deploy broadband may face withholding of support, after the pre-test period, for failure to meet performance measures standards. The FCC considers failure to meet speed and latency requirements as a failure to deploy.

In order to demonstrate compliance with the performance measures standards, at least 80 percent of network speed measurements must be at 80 percent of required speeds and 95 percent of latency measurements must be at or below 100 milliseconds round-trip time.

USAC calculates carrier compliance with applicable performance standards separately for each state and speed tier – as well as each fund in which a carrier participates – and may withhold support in the event of non-compliance based on FCC guidance. Results from speed and latency testing are subject to USAC verification and audit.

For a detailed explanation of how USAC calculates compliance results, please see PMM Compliance Calculations.

Additional Resources

Performance Subscriber Upload Template
Latency Testing Template
Speed Testing Template
Performance Data Formatting Guide
PMM User Guide
Performance Test Paths and Remote Server Locations
FCC Performance Measures Webpage
Vendor Information
PMM Quick Tips Guide
New Sample Generation Webinar (2023)
New Sample Generation Webinar (2023) Slides
Performance Measures Testing Webinar (2021)
Performance Measures Testing Webinar (2021) Slides
PMM Compliance Calculations
RBAP: Performance Measures Quarterly and Annual Testing Results
RBAP: Performance Measures Quarterly and Annual Pre-testing Results