As part of the American Rescue Plan Act, Congress allocated $350 billion to state, territorial, local, and Tribal governments across the country to support their response to and recovery from the COVID-19 public health emergency. Through the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program, over 30,000 recipient governments across the country invested funds to address their unique needs, including broadband infrastructure. The U.S. Treasury, which administers the SLFRF program, requires state and local governments to submit quarterly and annual Project and Expenditure Reports. Those reports are due on April 30, 2026. The deadline to obligate all SLFRF funds was December 31, 2024. The deadline to expend all SLFRF funds is December 31, 2026.¹ Treasury's Project and Expenditure Report User Guide outlines the information that state and local governments must provide for broadband projects that use SLFRF program support. The data on these projects will help stakeholders assess whether—and how effectively—public funds were translated into real broadband access.

I. SLFRF Reporting Requirements

Every project funded with SLFRF support must be reported, including its name, unique ID, completion status, a 50–1,000-word description, and expenditure category (one of 123 categories across public health, economic impacts, premium pay, revenue replacement, infrastructure, and others). Broadband falls under Expenditure Category 5 (Infrastructure), with three specific sub-categories: "Last Mile" projects, Infrastructure Investment and Jobs Act Match, and "Other projects." Larger governments (Tier 1: states, territories, and cities/counties over 250,000 people) must also report their adopted budget per project.

Broadband projects require especially detailed reporting requirements: location-by-location data using Federal Communications Commission Broadband Serviceable Location Fabric (Fabric)² IDs, GPS coordinates, technology type, pre- and post-investment internet access speeds, latency, pricing tiers, and affordability program participation. Projects over $10 million must address Davis-Bacon Act wage compliance and labor agreement certifications.

Davis-Bacon Act of 1931

The Davis-Bacon Act of 1931 requires contractors and subcontractors working on federally funded or assisted construction contracts to pay their laborers and mechanics no less than the locally prevailing wages and fringe benefits for corresponding work on similar projects in the area. The act prevents contractors from underbidding local wages and ensures that federal spending does not drive down local labor standards. The U.S. Department of Labor is charged with determining prevailing wages, which are often based on union wage rates in the locality. These regulations were significantly updated in 2023 to improve wage determinations and increase compliance effectiveness.

Treasury has asked SLFRF recipients to provide specific information regarding broadband projects, including:

1. A complete list of counties where households, businesses, and community anchor institutions that are to be served by the broadband project are located. 
2. Projected/actual construction start date.
3. Projected/actual initiation of operations date.
4. Whether or not the project is designed to, upon completion, reliably meet or exceed symmetrical 100 Mbps download and upload speeds.
   • If it is not designed to reliably meet or exceed symmetrical 100 Mbps download and upload speeds, the government must explain why not, or
   • Confirm that the project is designed to, upon completion, reliably meet or exceed 100 Mbps download speed and between at least 20 Mbps and 100 Mbps upload speed, and be scalable to a minimum of 100 Mbps download speed and 100 Mbps upload speed. 
5. Whether the project is designed to provide service to households.
   • If yes, the government must confirm that the service provider will either participate in the FCC's (now ended) Affordable Connectivity Program (ACP) or otherwise provide access to a broad-based affordability program that provides benefits to households commensurate with those provided under the ACP to low-income consumers in the proposed service area of the broadband infrastructure. 

A. Broadband Project Design Details

For each broadband project, governments will provide information related to the design of the project.  

1. Broadband Project Technology Type: Fiber, Coaxial Cable, Terrestrial Fixed Wireless, or Other. If Technology Type is “Other,” the report will include the other technologies used in the buildout to locations covered by the project.
2. Total Miles of Fiber Deployed: the total miles of fiber the project is designed to deploy or has deployed.
3. Total Number of Funded Locations Served by Speed (pre-SLFRF investment): Treasury is asking for both the number of funded locations served receiving below 25/3 Mbps (pre-SLFRF Investment) and locations served receiving 25/3 Mbps or greater but less than 100/20 Mbps (pre-SLFRF Investment). [A location is defined as a business or residential location at which fixed mass market broadband Internet access service is, or can be, installed.]
4. Project Design Buildout Speeds: information related to the planned buildout standards for speeds that will be provided as a result of the project receiving SLFRF investment. Treasury is asking for both the number of funded locations receiving minimum 100/100 Mbps service and locations receiving minimum 100/20 Mbps and scalable to minimum 100/100 Mbps.
5. Total Number of Funded Locations by Type: information about the locations the project is designed to serve, including the following location types:

a. Residential (Total Housing Units): defined by the FCC as a location that is or contains “housing units” or “group quarters” based on the U.S. Census Bureau’s definition of these terms. A housing unit is defined by the Census Bureau as a house, an apartment, a mobile home, a group of rooms, or a single room that is occupied (or if vacant, is intended for occupancy) as separate living quarters. Separate living quarters are those in which the occupants live and eat separately from any other persons in the building and which have direct access from the outside of the building or through a common hall. Multiple housing units in a single structure at a single street address or latitude/longitude point, such as apartment buildings, are reported in a single record.

b. Business: defined as a non-residential structure on a property without residential locations that would expect to demand internet access services. Governments will only report the locations of businesses that are expected to demand mass market broadband Internet access service, which typically are small businesses. Larger businesses are expected to purchase dedicated high-capacity transmission services, such as business data services (also known as special access).

c. Community Anchor Institution: an entity—such as a school, library, health clinic, health center, hospital, or other medical provider, public safety entity, institution of higher education, public housing organization,³ or community support organization—that facilitates greater use of broadband service by vulnerable populations, including, but not limited to, low-income individuals, unemployed individuals, children, the incarcerated, and aged individuals.   

B. FCC-Required Information

Governments are also required to complete FCC-required information, including: 

• The corresponding Fabric ID from the FCC Broadband Serviceable Location Fabric for the location
• Latitude/longitude at the structure where service will be installed  
• FCC Issued Provider ID #
• Technology used to offer service at the location: Fiber, Coaxial Cable, Fixed Wireless, and Other. If “Other”, the government will provide additional detail on the technology used to offer service at the location  
• Location Type: Residential (If Residential, Number of Housing Units.), Business, Community Anchor Institution
• Speed tier at the location pre-SLFRF investment
  • Below 25/3 Mbps or
  • 25/3 Mbps or greater but less than 100/20 Mbps
• Speed and latency at the location post-SLFRF investment  
  • Maximum download speed offered/advertised  
  • Maximum download speed delivered
  • Maximum upload speed offered/advertised
  • Maximum upload speed delivered
  • Latency

Speed and Latency

To ensure broadband infrastructure investments meet current and future use cases and to promote consistency across federal agencies, Treasury adopted the compliance standards and testing protocols for speed and latency established and used by the FCC for both the Connect America Fund and the Rural Digital Opportunity Fund.⁴ In order to demonstrate continued compliance with these standards, subgrantees must perform speed and latency tests from the customer premises of an active subscriber to a remote test server at an end-point consistent with the requirements for an FCC-designated internet exchange point.⁵ Ninety-five percent of latency measurements during testing windows must fall at or below 100 milliseconds round-trip time.⁶ This approach ensures a connection that supports reasonably foreseeable real-time applications. In limited circumstances where even fiber deployment cannot meet this latency threshold (for example, in a remote territory), Treasury may expand the latency threshold for specific broadband infrastructure investments at the request of a government. 

Governments must also report pricing information for each speed tier offered, including:

• Speed tiers offered—each speed tier of broadband service offered by the project
• Type of service—whether the service is a residential, business, or other package
• Base price—the corresponding non-promotional price for each tier of service
• Associated fees—one-time and monthly recurring fees associated with each tier of service. 

II. Publicly-Available Data

Treasury will make the data submitted by government recipients publicly available; however, the content and timing of release are still under development. Treasury encourages—but does not require—recipients to make their data directly available through their own websites. The reporting discussed above is completely separate from the Capital Projects Fund, another COVID-era program run by Treasury.

The Capital Projects Fund provided $10 billion to states, territories, freely associated states, and Tribal governments to fund critical capital projects that enable work, education, and health monitoring in response to the public health emergency. Unlike SLFRF, which supported a broad range of pandemic recovery needs, the Capital Projects Fund was specifically targeted at capital infrastructure investments, including broadband. For information on Capital Projects Fund awards, see Capital Projects Fund Awards Made to States, Territories, and Freely Associated States, to date.

Notes

1. Recipients are required to return to Treasury any SLFRF funds that have not been expended by the expenditure deadline.
2. Information on the Fabric, including how to access the location data in it, is available at:  FCC.gov/BroadbandData 
3. This term is used broadly and includes any public housing agency, HUD-assisted housing organizations, or Tribal housing organizations.  
4. See, e.g., Connect America Fund, WC Docket No. 10-90, Order, 33 FCC Rcd 6509 (WCB/WTB/OET 2018) (Performance Measures Order); Connect America Fund, Order on Reconsideration, WC Docket No. 10-90, 34 FCC Rcd 10109 (2019) (Performance Measures Reconsideration Order).
5. See Performance Measures Reconsideration Order, 34 FCC Rcd at 10114-16, paras. 17-19. 
6. See id., 34 FCC Rcd at 6527-28, para. 50.

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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