Building a Better Broadband Program

The National Telecommunications and Information Administration (“NTIA”) Broadband Equity Access and Deployment (“BEAD”) Program, funded through the Infrastructure Investment and Jobs Act, aims to expand and improve broadband access in unserved and underserved areas across the U.S. BEAD provides more than $42 billion to expand high-speed internet access by funding planning, infrastructure deployment, and adoption programs in all 50 states, Washington D.C., Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands. 

The program focuses on projects that enhance internet connectivity, closing the digital divide in rural and economically disadvantaged communities. The NTIA BEAD Program is a critical component of the government's commitment to ensuring that all Americans have equitable access to high-speed internet, which can facilitate economic growth and opportunity for those historically underserved by broadband services. 

States, territories and internet service providers (“ISPs”) are central to the NTIA BEAD Program’s success, especially concerning compliance and grants management. Effective compliance ensures that the program's objectives are met, and meticulous grants management provides some assurance that funds are used efficiently and transparently.   

Here are key considerations when planning for and implementing a successful BEAD Program: 

Understand Federal Guidelines and Requirements 

To ensure compliance, recipients, subrecipients and staff should understand the program guidelines and the underlying federal requirements. As with any federal program, the list of guidelines is extensive. Training and education for grant recipients, subrecipients, staff, contractors, and consultants within the BEAD Program are critical and should cover all applicable guidelines and encompass a wide range of topics related to effective grant management. This includes instruction on budgeting and financial reporting in compliance with specific award conditions; adherence to regulatory guidelines, such as 2 CFR 200; time and effort reporting; procurement, monitoring and tracking of grant funds; maintaining accurate record-keeping for audit purposes; and training on specific federal regulations, such as Environmental Historic Preservation and the Build America, Buy America Act. 

Establish a Robust Compliance Framework 

An effective program is dependent upon setting policy on the front-end of the program; designing and implementing systems, processes, and reporting to align with policy decisions; and using policies to drive efficient decision-making throughout the life of the program. Creating detailed policies and procedures for all aspects of the program is essential. Policies and procedures should include application processes, eligibility and scoring criteria, award terms and conditions, monitoring expectations, and closeout requirements. All policies and procedures should incorporate subrecipients where appropriate.  

Regular training sessions on program policies should be held to ensure that everyone is aware of compliance obligations and best practices. BEAD guidance will inevitably change, and staying abreast of new policies and adopting and communicating changes to program stakeholders is key to a successful program. 

Leverage Technology Solutions for Efficient Program Management 

Complex federal programs create a need to implement a technology solution that conserves time and staff resources while enhancing operational efficiency. This solution should enable the team, manage stakeholders, and achieve the necessary outcomes for distributing grant funding efficiently, effectively, and objectively. Key considerations for a technology solution include providing:

• A public portal for applicant intake, allowing for a seamless application experience.
• An administrative portal to review applications and manage the full grant lifecycle.  
• Automated communications and reporting capabilities that comply with NTIA, NIST, and other state and federal requirements.
• The ability to customize and, if needed, connect with other software mandated by state requirements. 

Performance Management and Continuous Monitoring

Continuous monitoring and evaluation practices are essential for identifying and addressing issues promptly. States should establish performance metrics and conduct regular reviews to assess the effectiveness of their BEAD Program. Feedback from these evaluations should be used to make necessary adjustments and improvements.  

Monitoring ISPs is required and should include subrecipient risk assessments, training, technical assistance, reporting requirements, and financial oversight functions required by the Uniform Guidance 2 CFR Part 200. ISPs should also conduct internal assessments to ensure that their projects meet performance standards and contribute to the program’s goals.   

Compliance and grants management are fundamental to the success of the implementation and operations of the NTIA BEAD Program. By understanding the federal guidelines, establishing robust compliance frameworks, applying effective grants management principles, deploying efficient technology solutions, and monitoring programs continuously, BEAD recipients can focus on the effective implementation of the program.  

EisnerAmper professionals help grant recipients navigate the challenges associated with managing federal funds, drawing upon our years of experience in grants management, IT audit, application development, change management, and reporting for public sector organizations. Contact us below to discuss your program needs.