Brooke Coleman: Importance of Compliance in Broadband Grant Programs

Financial requirements for broadband grant applications include audited financials and letter of credit requirements.

Brooke Coleman: Importance of Compliance in Broadband Grant Programs
The author of this Expert Opinion is Brooke Coleman, senior manager of business development at Widelity

The number of broadband grants in the United States is expanding every week. With funding from the Capital Projects Fund, to the Broadband Equity, Access and Deployment program, to ReConnect, there are billions of dollars available for the expansion of broadband networks.

However, these grant programs come with strict requirements that don’t end when the application is complete. In fact, much of the work comes from post-award reporting.


As part of your application there are financial requirements that will typically be a part of your submission. Most grant programs require a funding match, typically from 20-50% in the form of cash or in-kind contributions. In the cases where they don’t require a match, often preference is given to applications that choose to offer a funding match regardless.

This is coupled with audited financials, which often need to be completed by an individual outside of your corporation, and a letter of credit demonstrating that you have 25-100% of the grant amount in your account. This is to prove to the government that in case of an issue with the project, they’ll be able to recoup the expense.

Submissions are also required to comply with other federal regulations, such as the National Environmental Policy Act, as well as submit a robust cybersecurity plan. The latter is increasingly important, given government concerns about the security of our digital shores, and concerns about foreign technology (ie., the “Rip-and-Replace” tactic currently happening with Huawei tech).

In addition, your group must be FCC compliant and submit the FCC Form 477 or Broadband Data Collection Form.

All of these requirements will take time to compile.

Post-award reporting

The application is finished and you were lucky enough to receive your award. Sadly, this means your work is far from complete–and not just the project itself.

Depending on the rules of the specific program, the vendors and equipment you purchase will need to comply with Build America, Buy America requirements, which has regulations about where the equipment that can be used for broadband expansion was manufactured and obtained. You will also be required to participate in the Affordable Connectivity Program, which provides a discount to your subscribers on their monthly broadband bill.

Then there are reporting requirements. These typically include financial and project progress reports on a quarterly or semi-annual basis. The amount of detail necessary will vary depending on the program, the funding amount, and the location that you report from. This can include but is not limited to speed tests of the new technology (failing to reach the program upload/download speeds can cause you to suffer penalties), explanations of work completed, detailed lists of technology purchased, how it is implemented, and more. You will need to properly report on every penny spent with government funds in order to receive your reimbursement of those grant funds.

This will all need to be completed within the scope of your project timeline, and within the guidelines of the program. Failing to meet these requirements for reporting can result in some or all of the grant money being paid back in some cases, so it is extremely important that you keep track of your reporting requirements.

Brooke Coleman is the Senior Manager of the Business Development division of Widelity’s Compliance Team. Her expertise lies in federal and state grant programs, specializing in broadband programs created by multiple government acts, such as the American Rescue Plan, IIJA, and more. This piece is exclusive to Broadband Breakfast.

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