This is dependent on the cell you're in. I've been on Starlink since Feb 2021 and dipping below 100 down is very rare. It' averages about 140 down and 20 up with about 30ms latency.
For this grant the 100/20 needed to be consistently available in specific geographic areas. So if the cells bring down the performance averages are concentrated in those grant areas, it makes sense for them to fail to meet the program criteria while still having a product that hits those metrics elsewhere.