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BEAD Post-Award Strategies: What ISP’s Need to Know

The BEAD program offers a significant opportunity for Internet Service Providers (ISPs) and State Broadband Offices (SBOs) alike. But while much of the focus has been on the application process, there’s another critical phase ahead: post-award compliance. If you’re an ISP bidding on BEAD grants, it’s never too early to start preparing for the complex post-award requirements that will come after you’ve secured funding. Anticipating what will likely be required will also prepare ISPs for easy and quick answers when information is requested.

Right now, there’s a bit of uncertainty surrounding BEAD’s post-award phase. This is because the full scope of the process is still being refined, and many aspects are evolving as the program develops. It’s important to note that the NTIA isn’t going to hand out a step-by-step guide for the post-award process for subrecipients, which means the road ahead requires careful planning and flexibility. The Final Proposal Guidance (FPG) is the key document guiding the process at the state level, but the post-award requirements are still taking shape and that matters for states and eventual subrecipients.

Given the complexity of the post-award phase, we wanted to break down some of the essential steps and considerations for ISPs and SBOs. The goal is to help you understand the bigger picture of what’s coming, and how to prepare now to ensure compliance and successful project implementation. Below, we’ve outlined what you should expect and how you can start planning for the post-award process today.

The Final Proposal: Your Baseline for Reporting

Post-award work for the SBO begins with a baseline indicating everyone is on the same page regarding the budget, timelines, and other essential elements of the award: the Final Proposal. Once approved, the SBO will begin finalizing awards. ISPs can expect, as a part of that process, that individual projects will require similar initial reporting up to their SBO. Additionally, the elements required in the Final Proposal signal what subrecipients can expect to be required for their ongoing reporting to the SBO.

Key Elements of Post-Award Reporting to Consider

A strong post-award program is rooted in the expectations laid out in the Final Proposal. While subrecipients are responsible for providing a lot of information, SBOs will play a key role in monitoring and reporting to NTIA. Here’s what to expect:

• Timeline Information: Expect to regularly provide updates about timelines across all subawards. Have a plan for managing and reporting this data to the SBO.
• Middle-Class Affordability Plans (MCAPs): These plans will need to be tracked and updated, and subrecipients should be prepared for feedback from the SBO.
• Environmental and Historic Preservation (EHP) Progress: SBOs will be closely monitoring each project’s EHP status. Subrecipients should plan to provide regular updates on their progress with permits and approvals.
• Financial Reporting: SBOs will require ongoing financial updates—what’s being spent, when, and on what. Make sure your spending aligns with your proposed budget, and don’t forget to include necessary compliance details like Build America, Buy America (BABA) confirmation and labor requirements.
• Property Access Permitting: Subrecipients should be prepared to provide written updates on the status of property access permits, especially if the SBO is coordinating with state departments of transportation and other permitting agencies.
• Cybersecurity Plans: Regular updates on the implementation and progress of cybersecurity plans will be required. Don’t expect the SBO to lay out the process for you—be ready to report on your progress.

Reporting will include not only data but also narrative descriptions of progress, changes to timelines, budgets, and other key factors. SBOs will be reviewing and discussing any concerns with subrecipients, especially when it comes to potential delays or risks. Be prepared for regular check-ins—monthly or quarterly—where your project’s progress and any compliance issues will be discussed.

What to Expect During the Post-Award Process

The post-award phase will involve a wide range of reporting requirements, many of which require specialized knowledge.

• Who will review and defend your cybersecurity plans and progress?
• Is there an engineer on your team who can interpret network diagrams and communicate effectively with the SBO?
• Who is responsible for tracking budgets and reimbursements and who will update the SBO?
• Do you have legal expertise on hand to navigate the complex compliance rules and regulations, such as those related to the Uniform Guidance?
• Who will oversee the EHP process and be responsible for reporting to the SBO?
• Who is reviewing the Labor and Workforce information required?
• Who will be responsible for reviewing field reporting from your team and coordinating verification by the SBO?
• Who is handling your quality assurance and control processes?

Managing these responsibilities will require more than just submitting paperwork—it’s about processing, analyzing, and responding to data. A competent team and a solid plan are essential for success.

At Tilson, we understand the intricacies of managing complex broadband projects. Our Broadband Consulting team is here to help you navigate the post-award process, ensuring you stay compliant and on track every step of the way.