Enhanced A-CAM Obligations

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The FCC’s recent Enhanced ACAM (EA-CAM) Order (7/24/23) put forth an offer to all ILECS that included significant changes to the current Universal Service Support mechanisms as well as the related broadband deployment obligations. This offer was extended to ACAM/ACAM II companies and Legacy support companies. Participation in the EA-CAM program was voluntary and those companies electing to accept the EA-CAM offer had to do so by September 29, 2023. Those companies that elected to participate in EA-CAM accepted a commitment to provide broadband service to all unserved locations at speeds of 100/20 by the end of 2028 in exchange for predictable model based support for the period 2024-2038.

In addition to the broadband deployment obligations mentioned above, EA-CAM electors must also comply with the following requirements:

* EA-CAM carriers must participate in the FCC’s Affordable Connectivity Program.

* EA-CAM carriers are required to implement operational Cybersecurity and Supply Chain Risk Management plans by 1/1/24, the start of EA-CAM support. These plans must be submitted to USAC and carriers must certify that they have done so by 1/1/24 or within 30 days of approval of the requirements under the Paperwork Reduction Act, whichever is later. Failure to comply with these requirements will result in 25% of EA-CAM monthly support being withheld until the carrier comes into compliance. In addition, going forward, carriers must notify USAC within 30 days of any substantive changes to their plans and must file an updated plan. Also, in their annual FCC Form 481 filings, carriers must certify that they have maintained their plans, whether they have submitted modifications in the prior year, and the date the modifications were submitted.

The requirements discussed above may be new to many carriers that elected EA-CAM support. ICORE can assist EA-CAM companies in navigating through these new requirements and in developing and filing the required Cybersecurity and Supply Chain Risk Management Plans with USAC. If we can be of assistance to your Company in meeting these new obligations, please contact Chris Ulmer at culmer@icorellc.com or on 610-928-3903.

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