As this unprecedented investment becomes available to states and communities, it represents both an incredible opportunity and a complex challenge: an opportunity to finally bring internet infrastructure and access parity for rural communities and families with fewer resources, and a challenge in the design and administration of such a large and complex set of regulatory programs in the tight timeframes that the law requires. Below are some key considerations to help state and local grant administrators feel better prepared to capitalize on this once-in-a-generation federal investment.
Best practices for securing funding
1. Invest in robust planning
The planning process for all these programs can appear daunting for understaffed local governments. Most states and territories are establishing a dedicated broadband office for the first time or incorporating broadband teams into departments with potential synergies. Planning is the most critical step in the grant lifecycle. It sets the stage for all future phases, including resource management and staffing, community outreach practices, data collection, road mapping, and local stakeholder identification. The goals and priorities of the funding are identified at this stage as well.
Each state and territory will need to develop a Digital Equity Plan, Five-Year Action Plan, and Initial/Final Proposals for the BEAD and Digital Equity Grant programs. Plans need to account for federal eligibility rules, including the Broadband Equity, Access, and Deployment program's (BEAD) definitions of “unserved” and “underserved” households. Ensuring these households are correctly identified and receive funding is one of the first and most important steps in the planning process. To make this community outreach as productive as possible, familiarity with the technical complexities of broadband service, technologies, and associated infrastructure is needed. Local governments will need to build teams of experts in not only broadband but also federal grants administration and sub-recipient oversight.
2. Be deliberate about program design
Successful implementation of complex grant programs relies upon the quality of the program design and application scoring criteria. A well-thought-out design has scoring criteria with definite connections to desired policy outcomes. Definitions of success for the program are clearly stated but also remain flexible to allow grantees to re-evaluate their program design and adjust them as needed to remain responsive to changing community needs.
When evaluating community broadband needs and market forces, identifying stakeholders is a crucial step. Community members, beneficiaries, ISP partners, and even elected officials can provide invaluable insight into local areas of improvement, guidance, and potential technical limitations or issues. Soliciting this kind of feedback keeps grantees one step ahead of roadblocks and guides smart project investment and avoids 11th Hour protests that can derail progress.
This community outreach should remain open through the program life cycle. A regular two-way communication channel keeps local stakeholders involved and informed about the progress of projects. With community support and trust, plans will be much easier to implement.
3. Be strategic in building capacity
States and local governments can and should be strategic about building their capacity to support this federal funding. Rather than recruiting and hiring internal broadband grant management staff for a one-time influx of funding, municipalities can rely on hired vendors and firms to provide short-term support over the course of the grant life cycle. Grantees should assess what level of capacity is needed and build out actionable steps to reach the support levels identified in the assessment process, such as training and staff augmentation. After collecting this information, grantees can move forward with implementing and integrating the plan into current staffing models and workstreams. The work isn't done here, however. Capacity building is a continuous process. Grantees should constantly monitor and assess the capabilities and level of success of their capacity plan throughout program implementation to ensure needs are being met and the program is running at maximum efficiency.
Even so, grantees often find themselves wondering where to find the support they need. This is a complicated space with limited expertise available. Partnerships with local and regional internet service providers (ISPs), universities, vendors, and firms with subject matter expertise will strengthen the implementation of IIJA funding by taking the weight off the shoulders of the newly developed state broadband teams. Well-built teams with proper staffing greatly contribute to the development of well-structured broadband plans and connecting the areas of greatest need—maximizing the positive impact of this grant.
1. All provider types must be considered.
2. Subgrantees must have accountability.
3. Coordinate with local stakeholders.
4. Distribute funds in an equitable and nondiscriminatory manner.
5. Follow Fair Labor Practices using a highly skilled workforce.
6. Keep compliance with Civil Rights and Nondiscrimination laws
7. Climate resiliency must be incorporated.
4. Plan for closeout
Planning for program closeout will save grantees many headaches down the road. Initially, the program’s focus tends to be on startup and implementation practices. States and local governments are eager to get the ball rolling and use the funding to benefit their communities. As a result, steps needed for closeout are often missed in the earlier stages of the grant life cycle. Data tracking and retention of records can be weaker at the start. Standard contract clauses, or “boilerplate,” can be missed by grantees. Uses of funds can lack sufficient monitoring and documentation can be lost without the proper practices. Retracing years of steps can raise problems when closeout is near, and those federal agencies that pressured grantees to get funds out to applicants at the program start could begin calling for the recapture of funds. However, putting a focus on closeout from day one of the grant mitigates these risks significantly. Focus on collecting and maintaining support for all activities regardless of the program’s age.
5. Implementation and regulation
Such a dramatic increase in funding will require careful management in accordance with federal requirements. After all the planning, new challenges arise with the actual use of grant funds and their disbursement to broadband projects. Eligible entities that receive federal funds from the BEAD program are required to comply with standards set by several regulatory rulebooks, including but not limited to:
- Notice of Funding Opportunity (NOFO) upon formal announcement of the availability of funding
- National Telecommunications and Information Administration (NTIA) Standard Terms and Conditions
- 2 CFR Part 200 (uniform administrative requirements, cost principles, and audit requirements for federal awards)
Other rules are likely to be included regardless of policy considerations such as permitting, environmental compliance, civil rights considerations, and labor standards. Failure to follow any of these rules—even before the first federal dollar reaches the state—can jeopardize entire projects. Building expertise in compliance can save a grantee many unnecessary headaches in the long run and streamline implementation processes for more cost-effective broadband deployment. Less time and money lost to cleaning up regulatory errors means more underserved people get the assistance they need—and more funding is available to invest in educational materials and training for newly online Americans adopting the internet. For additional insights, keep an eye out for our upcoming article discussing best practices for subrecipient oversight.
The Broadband Equity, Access, & Deployment Program is a critical step in creating a more equitable society for all Americans, both online and offline. States and local governments are currently in startup phases across the country, preparing for the challenges and opportunities federal funding can provide. To maximize the value of the broadband grants, entities can invest in robust planning, carefully construct their program design, strategically build capacity, put an early focus on closeout, and practice precise implementation tactics. Following these practices has led to success in many other grants, cut clawback risks, and reduced inefficiencies—allowing grantees to reach the greatest number of citizens in need.