Open Recommendations

FCC and USAC should implement a process to verify or validate the speed and latency data submitted by the carrier within the PMM system. This can include sampling and/or analytics and targeted audits over carrier submissions.

FCC should ensure that USAC complies with the requirements of the PMM order and/or issue an amendment to the current orders clarifying how deferred latency tests should be addressed when they make up a significant portion of the sample testing results. This should include defining the maximum tests allowed to be deferred when determining compliance. The amendment should also include other procedures performed by the carrier or USAC to determine that the carrier’s network is compliant with the conditions set forth within the applicable program.

FCC should enforce the minimum speed test duration to ensure the results obtained are accurate and representative of the carriers’ network and in compliance with minimum speed requirements.

FCC should direct USAC to develop and implement procedures to determine if the issues noted in the condition warrant adjustments to the carrier’s withholdings and/or payments previously made. Further, USAC should determine if any of the payments made to these carriers would be considered an improper payment requiring recovery.

FCC should improve and continue to perform cost benefit analyses to determine a proper level of effort to monitor the HCMF; specifically, identifying higher-risk areas and implementing additional sampling, analytics, and other methods to ensure the carrier
compliance status for the enrolled program is reasonably supported.

Direct USAC to modify testing procedures for verification reviews to ensure that the deployment date tested by the Verification Team is reflective of the date entered and certified in HUBB by the carrier and supported by appropriate evidence.

Direct USAC to develop and implement procedures that identify possible erroneous deployment dates and document whether a change to past-compliance statuses is warranted. Further, USAC should determine if any of the payments made to these
carriers would be considered an improper payment.

Direct USAC to modify testing procedures for verification reviews to ensure that carriers are offering the speeds per the corresponding program requirements for minimum speeds. Examples of testing procedures include reviewing stronger evidence, such as an engineer certification or actual network speed testing results performed by a third party or through collaboration with USAC’s engineers.

Create and implement a plan to automate the oversight and review process of missing 091 transactions and completion of Postal Service Form 1017-B before the pay week closes.

Provide training to ISSPOs, ISOs, and Information Owners on their roles and responsibilities to follow the PBGC RMF and POA&M processes.

Confirm the requirement that deficiencies identified by SPA&A reviews that are not remediated within 30 days after identification are tracked via POA&Ms with accountable personnel.

Periodically monitor the satisfaction of the system risk assessment and POA&M creation requirements to help ensure ongoing compliance associated with the timely completion of and updates to system risk assessments and documentation and tracking of POA&Ms.

We recommend PBGC management to coordinate with its CSP to update its service agreement and shared responsibility matrix to address ambiguities regarding accountable parties for key controls and develop and implement a contingency plan for the system.

Update and track IASA program milestones to improve timeliness and mitigate risk from civil aviation authorities under assessment.

Establish and implement processes to ensure routine upkeep of program documents, including checklists.

Create and implement a process to document when exceptions to the normal IASA in-country assessment process are appropriate and how they should be handled.

Develop and implement a policy to maintain a historical record of all interim and completed Risk Assessment Tools for future trend analyses.

Establish a formal prioritization methodology for new assessments, reassessments, technical assistance, and other duties.

Formalize process of how and when Operations Specifications for foreign air carriers are limited when a risk is identified.

Finalize the proposed changes and related updates to FAA Order 8900.1, Volume 12.

Continue to monitor First Solar’s impact, including through the June 30, 2026 annual Development Outcomes Survey and midpoint performance assessments, to have relevant information for assessing the project’s core impacts and metrics.

Adjust the ESOC Award Fee Plan to include clear, objective criteria for the Management and Technical Performance, Business Management, Compliance with Safety and Health Requirements evaluation category

Align definitions in the ESOC Award Fee Plan with Federal Acquisition Regulation guidance

Coordinate with an existing NASA supply chain group (e.g., Supply Chain Risk Management Program) to investigate alternative supply chain management strategies, such as evaluating the feasibility of incorporating the Supply Chain Visibility Data Requirement Deliverable into ESOC to increase visibility into spacesuit supply chains.

This recommendation is Sensitive But Unclassified.