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Preparing for BEAD Reporting: A Comprehensive Guide for States to Ensure Compliance and Avoid Delays

Now that all states and territories have received approval on their initial BEAD proposals, unserved and underserved communities across the U.S. are one step closer to accessing high-speed internet access. NTIA has allocated approximately $42 billion in BEAD funding to support universal broadband coverage. And some States are now in the process of preparing their Final Proposals, which outline the outcomes of their provider selection processes and coverage plans. Once approved, states can allow their awardees to begin work on their projects. 

As part of the NTIA’s Final Proposal Guidance (FPG), each state is required to submit up to six data files detailing their BEAD program’s subgrantee selection, deployment locations, and project plans, among others. States, having already completed the eligibility analysis and challenge process for their Initial Proposals, are familiar with the CSV-formatted data files required. However, this new data submission is more closely tied to the ongoing BEAD application process.

Given the interconnected nature of the data and complex reporting requirements, preparing early is crucial for states to receive timely feedback from the NTIA and ensure their program approval is successful. To support states through this process, Tilson’s Broadband Consulting experts have developed a strategy guide, condensing over 50 pages of requirements into a concise resource below. Our goal is to help states prioritize and organize their data to ensure their programs launch without delays.  

“With our expertise in state and federal grant proposals, including the BEAD program, Tilson’s Broadband Consulting team helps clients navigate the complexities of data compliance, ensuring that reporting requirements are met and funding is secured for their communities.” Heather Mills, Principal Consultant

Preparing for NTIA’s Ongoing Data Review Process: What You Need to Know

NTIA’s subgrantee selection monitoring process requires each state to submit data files at key milestones, including at the conclusion of the first competitive grant round, every 60 days thereafter, and at least once before considering alternative technology projects. In practice, NTIA has been eager to review states’ data more frequently to provide earlier feedback. This chart from NTIA outlines the initial timing requirements for submitting data:

NTIA’s review process identifies missing data, formatting errors, and invalid inputs, such as performance start and end dates that fall outside the acceptable time range. While NTIA has implemented a robust system of checks to flag data issues, they cannot account for every potential entry error. Although NTIA will likely continue to refine its review process, states should not rely solely on these checks to catch all mistakes. States must perform their own internal reviews to ensure their data accurately reflects the information submitted by applicants.

Here are some essential tips for states to prepare for NTIA’s reporting requirements:

• Understand the relationships between the different data files: NTIA uses information about what locations are included in each project to connect project-level information to related locations and vice versa. Similarly, the list of provisional subgrantees and their awarded projects can link subgrantees to both project-level and location-level information. States should understand these relationships and perform accuracy and consistency reviews to ensure the data aligns correctly across files.

• Review the data requirements outlined in the Final Proposal closely: The Final Proposal includes specific data requirements, with variables that can be confusing. For example, the “Non-Traditional Broadband Provider” variable requires entering “Yes” if the subgrantee is a traditional broadband provider and “No” if it is a non-traditional provider. In other words, a “Yes” to the Non-Traditional Broadband Provider category means that it is NOT a non-traditional provider, a counter-intuitive coding rule. The Locations and CAIs files require that each location’s upload speed be listed BEFORE the download speed, defying the general convention used throughout the industry. It’s crucial for states to closely read the variable descriptions in the Final Proposal Data Submission section (pages 12-18) and the Appendix (pages 82-97) and seek clarification from NTIA early on.

• Leverage data exports from the grant management platform: Well-designed BEAD grant application portals include questions that align directly with NTIA’s data categories, allowing states to quickly populate the required data files. However, the data exports from these portals often don’t match the CSV formatting requirements. To address this issue, states should work closely with their platform vendors to reorganize the data into a usable format. Some fields, such as technology, provider type, and project type, may use non-coded inputs that need to be converted into the numeric or alphanumeric codes required by the NTIA data files. If the application portal was not designed with these data file requirements in mind, states may still be able to infer missing answers from other provided information.

• Perform the application evaluation process in parallel with data reporting: As stakeholders review each application, they should carefully verify the accuracy of answers that will be used in the data files. During this process, states may request clarifications or corrections for missing or potentially incorrect data, particularly if the submissions did not provide enough information to answer all NTIA data categories. 

NTIA’s Technology and Location-Based Prioritization Requirements

The BEAD Notice of Funding Opportunity (NOFO) established a clear hierarchy for awarding grants, prioritizing end-to-end fiber broadband projects first. States can then award grants to projects using other reliable broadband technologies, such as cable, hybrid fiber-coaxial networks, DSL, and terrestrial licensed fixed wireless service.¹ If locations receive no acceptable bids utilizing these technologies, the state can consider proposals offering alternative technologies, such as Low Earth Orbit (LEO) satellite and fixed wireless networks using unlicensed spectrum exclusively.² NTIA will also monitor which projects provide internet access for unserved vs. underserved communities to ensure funds are allocated appropriately.

NTIA’s “Graphical Illustration of Reliable Broadband Service and Other Broadband Technologies”³

The BEAD program’s technology and location prioritization requirements are a key reason why NTIA is has established an ongoing review process, as NTIA has emphasized that decisions related to these rules “cannot be recreated after the fact.”⁴ NTIA reviews the data files after the first completed application round and before the state evaluates alternative technology proposals to ensure that the state has prioritized fiber projects over others and properly complied with competitive bidding requirements before advancing to alternative technologies.

Each data submission must identify the technology being used to connect each location in provisionally selected projects. If the NTIA discovers that projects providing other reliable broadband service technologies were awarded during the first application round, they can ask the state to verify whether those project areas received any fiber-based applications. States should be prepared to explain why non-fiber technologies were selected, whether due to a lack of fiber applications or from bids exceeding the extremely high cost per location threshold (EHCPLT).

In every submission, NTIA has also requested information on the number of unserved and underserved locations remaining that have not yet been included in the projects provisionally selected, along with how much BEAD funding remains to cover those locations. At the conclusion of the first grant round, NTIA will likely take action if a significant portion of unserved locations have not been included in selected fiber projects or if little funding is available to connect any remaining unserved locations. States should be prepared to analyze and explain the viability of connecting remaining unserved locations at the end of the first round if either of these issues arise.

To facilitate NTIA’s review of these prioritization factors, states should:

• Review and submit ongoing data updates to NTIA for early feedback: Rather than waiting until the end of the first application round, states should submit ongoing updates to NTIA that reflect how they are complying with prioritization requirements. States should first focus on fiber project applications to cover unserved locations and perform due diligence reviews to ensure validity and that they do not approach the EHCPLT. Once completed, states can submit this subset of data to obtain early feedback and begin to address formatting issues.
  
  Next, states can review fiber and other priority broadband service-based project applications to underserved areas that received no other applications, then to the lengthier review of fiber applications in competitive areas. Concurrently, states should identify locations that did not receive bids and consider opening a second round if planned. These smaller test submissions will help the NTIA better understand the state’s prioritization methods, enabling earlier feedback and allowing the state to proceed with subsequent grant rounds more efficiently.
  
• Analyze patterns of selected projects and group them together based on shared characteristics: States should review provisionally selected projects and group them together based on key characteristics for each stage of the project, such as technology codes, fiber mileage information, technology performance, and any issues related to the EHCPLT. Because all locations within a project area will generally share the same technology and service characteristics, this grouping approach allows for more focused analysis and quality control at each project stage, rather than waiting until a large portion of the data is developed.

The New “No BEAD Locations” File Updates

In version 1.1 of the Final Proposal Guidance, NTIA introduced the “No BEAD Locations” file, giving states the opportunity to explain why certain eligible locations were not included in BEAD projects. This new data file is a clever way to provide states with an opportunity to submit a limited range of location challenges and use recent FCC data to update its eligibility map, but NTIA explains that these updates should be “rare cases.” ⁵

• Updates for reporting challenging locations and project exclusions: States can submit evidence demonstrating that a location does not require broadband service, does not need mass-market broadband, or is already served by an enforceable commitment. This option allows states to exclude locations that have been demolished, are not Broadband Serviceable Locations (BSLs), or use enterprise-level broadband service.
• Updates from FCC data: States may use a more recent version of the FCC’s address fabric to remove locations that no longer appear within it. States may also reclassify locations as served if they are listed as such in the current National Broadband Map and the state can provide evidence that “unequivocally demonstrate[s] that the location is already served with qualifying broadband.”⁶

While this evidence does not need to be submitted with the data files, the state must retain it for review if requested. Although the FPG does not explicitly require states to solicit or consider evidence from ISPs, states may allow ISPs to submit such evidence demonstrating these circumstances.

The “No BEAD Locations” file is also used to identify eligible locations that could not be feasibly connected using BEAD funding. If a state includes any of these locations, it must provide a thorough explanation of its technology and location prioritization method, along with an analysis of why BEAD funding may not have been sufficient to achieve universal connectivity in the state.

Ultimately, every eligible BSL listed in the state’s approved post-challenge location eligibility data must appear in either the Locations or No BEAD Locations data files. States should maintain a list of all eligible locations to track whether each has been included in the Locations file or is planned to be addressed in the No BEAD Locations files. As selections progress, the Locations list will grow, while the list of unassigned eligible locations will shrink. This list can also be used to plan future grant rounds and direct solicitations with ISPs.

Start Early: Ensure BEAD Data Compliance and Avoid Delays with Support from Tilson

Achieving BEAD compliance can be challenging, so it’s critical to begin planning your program early to meet the ongoing data reporting requirements and avoid delays.

Tilson’s consulting team has extensive experience navigating both federal and state BEAD compliance requirements and offers comprehensive support to help your organization address data reporting needs, assist with the review processes, support subgrantees, and achieve your BEAD objectives. 

Learn more about our services or contact us to discuss your specific broadband connectivity goals.

Footnotes

¹ NTIA, Broadband Equity, Access, and Deployment (BEAD) Program: Selecting the Most Robust, Affordable, Scalable Technology, June 26, 2024, p. 3, https://broadbandusa.ntia.gov/sites/default/files/2024-06/BEAD_Selecting_Technology_Policy_Notice_0.pdf.
² If each project application for reliable broadband service to a location or area exceeds the EHCPLT, the state may consider alternative technologies. NTIA, Proposed BEAD Alternative Broadband Technology Guidance, Version 1.0, August 26, 2024, p. 4, (“Draft Alternative Technology Guidance”), https://www.ntia.gov/sites/default/files/publications/bead-alternative-broadband-technology-policy-notice-for-public-comment-final.pdf. Additionally, a state may conclude that a project application does not meet all necessary criteria to be considered valid, under the NTIA’s BEAD program rules and those additional standards adopted by the state and approved by NTIA.
³ Taken from NTIA, Draft Alternative Technology Guidance, p. 6.
⁴ NTIA, Broadband Equity, Access, and Deployment (BEAD) Program: Final Proposal Guidance for Eligible Entities, v1.2, November 2024, p. 8, (“FPG v1.2”).
⁵ FPG, v1.2, p. 38.
⁶ FPG, v1.2, p. 44.