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Navigating BEAD Post-Award Compliance: Key Strategies for State Broadband Offices

The release of the National Telecommunications and Information Administration’s (NTIA) Final Proposal Guidance for the Broadband Equity, Access, and Deployment (BEAD) program marks an important step in expanding broadband access across the country. However, with the opportunity to receive funding comes the responsibility to meet a range of complex compliance requirements. While the guidance provides a framework for securing grants, it leaves many questions unanswered about post-award obligations.

Given the complexity and evolving nature of these rules, State Broadband Offices (SBOs) must be prepared to manage their responsibilities effectively. By planning ahead and staying proactive, SBOs can avoid potential issues and maximize the impact of their broadband projects. In this article, we’ll share practical strategies to help SBOs manage their grants, stay compliant, and ensure the success of their BEAD initiatives.

1. Anchor Post-Award Strategy in the Final Proposal

The Final Proposal is much more than a submission document—it serves as the foundational reference for NTIA throughout the life of the grant. A well-constructed Final Proposal will lay the groundwork for post-award management by detailing assumptions, reporting methods, and coordination plans.

For example, specifying collaboration strategies with local stakeholders in advance will make ongoing community engagement reporting easier. Likewise, a well-organized budget section will help track financial compliance. Aligning the Final Proposal with anticipated reporting and oversight requirements from the outset can mitigate potential issues and streamline post-award activities.

2. Begin Post-Award Planning Early, but Remain Flexible for Changes

Rather than waiting for NTIA’s final post-award guidance, SBOs should start laying the groundwork now by drafting key compliance documents and templates that can be adjusted as new guidance is released. Final Proposal preparation is the perfect opportunity to not only draft required plans but also begin designing compliance systems, such as databases to track specific data from template forms to monitor coordination efforts.

More importantly, getting a head start will allow SBOs to adapt more easily to NTIA’s evolving requirements and reduce the burden when updates come. SBOs should begin working with their federal program officers to clarify core requirements and identify areas still in flux.

3. Develop a Detailed and Flexible Compliance Plan

BEAD’s post-award phase involves tracking a wide array of compliance areas, from financial monitoring to environmental and historical preservation (EHP) permitting, and cybersecurity implementation. SBOs need to develop comprehensive and adaptable compliance plans that incorporate:

Incorporating risk management practices, such as identifying early warning signs for budget overruns or project delays, will help SBOs quickly address issues and avoid jeopardizing funding.

4. Select a Grant Management System (GMS) Suited for Compliance

A robust GMS is a critical tool for managing the complexities of BEAD compliance. The right GMS will help SBOs centralize financial tracking, reporting, and communication in one system. Key features of an effective GMS include:

If adapting a CRM or other existing system, SBOs should ensure it can handle the full grant-lifecycle —this includes project tracking, financial oversight, and reporting.

5. Develop a Consistent Communication Plan

Effective communication is critical, especially with the variety of subrecipients involved. SBOs should establish a plan that sets expectations, schedules, and channels for regular updates. Key components of an effective communication plan include:

Transparent communication fosters a collaborative relationship and sets clear expectations, which can increase the likelihood that subrecipients will meet compliance requirements on time.

6. Hire and Equip a Skilled, Multifunctional Team

The post-award compliance period requires expertise in a range of areas, including legal, technical, programmatic, and financial disciplines. SBOs must evaluate staffing needs carefully and ensure they have access to specialized skills, by asking:

  • Who will review Cybersecurity plans and defend them to the NTIA?
  • Is there an engineer on the team who understands how to read network diagrams?
  • Who will review financial statements and pro formas to understand whether a project is actually feasible, particularly if the subgrantee begins to go over budget early on?
  • Is there a legal mind on hand to handle complex rules interactions in specialized topics or with practical experience in the Uniform Guidance?
  • How will your team oversee the joint responsibility for EHP documentation review?
  • Who is reviewing applicants’ Labor & Workforce information?
  • Who is designing the monitoring program to ensure all essentials are in place, such as a reliable waste, fraud, and abuse monitoring process?
  • SBOs are contracting with potentially hundreds of entities; who is creating, managing, and documenting that process?
  • Who will follow up with subrecipients to understand nuances of the connections?
  • Who will perform field checks and field data collection and analysis?

Conclusion

The post-award compliance phase of BEAD offers significant challenges but is manageable with the right approach. By anchoring compliance strategies in a well-structured Final Proposal, preparing early, selecting the right systems, and establishing clear communication, SBOs can meet NTIA’s complex requirements with confidence. At Tilson, our team has the experience and expertise to help navigate these challenges – from managing evolving compliance regulations to providing real-time visibility into subrecipient progress through site inspections. With our specialized knowledge and flexible approach, we’re here to support SBOs in making their BEAD programs a success.

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