Subgrantee agreements turn billions of public dollars into enforceable obligations, measurable outcomes, and real connections. Over the next decade, states will manage up to $42.5 billion in BEAD subgrant agreements. A single poorly drafted clause could trigger millions in clawbacks.  Strong, specific agreements paired with the right systems become blueprints for success, while weak or boilerplate language multiplies risks like audits, clawbacks, delays, and missed timelines. 

For consultants, you’re helping states and operators translate evolving federal guidance into programs that can withstand more than a decade of scrutiny. That means navigating four major compliance shifts unique to BEAD:

Consultants must help clients prepare for a compliance journey that stretches across affordability, labor, performance, and documentation—long past the initial award.

Without a deep understanding of the reporting and compliance nuances within BEAD, consultants risk underselling the scope and mischaracterizing it as a “paperwork sprint.” In reality, BEAD is a location-level, evidence-driven operating regime that spans design, build, activation, service, and long-term monitoring. 

If R&C is scoped narrowly, everyone loses. States struggle to enforce. Awardees can't get reimbursed. Rework multiplies. Your edge as a consultant is to right-size expectations from the start and guide clients toward an operating framework that makes reporting and compliance manageable. Here’s how:

1) Calibrate agreements to risk and complexity. 

Help states move beyond one-size-fits-all. Tie reporting cadence, verification intensity, and site visits to award size, awardee history, and project complexity. Build clear cure periods and objective remedies into the enforcement ladder so problems can be fixed before the hammer drops.

2) Design agreements that generate usable evidence.

Push for requirements that naturally produce audit-ready artifacts: GPS-verified construction data, certified payrolls, BABA documentation, photo evidence tied to locations, and milestone gates linked to reimbursement. This is how you avoid stalled payments and after-the-fact paper chases.

Encourage clients to instrument networks so performance targets are measurable from day one: throughput, latency, reliability, and time-to-repair, tied to both edge and core. Compliance ends at the subscriber. If the network does not perform, nothing else matters.

4) Treat BABA as supply-chain mastery, not a hurdle.

BABA discipline creates durable advantages: better vendor relationships, cleaner records, and resilience against disruptions. Bake manufacturer certifications, procurement trails, and waiver procedures into the agreement and workflow.

Guide awardees to avoid “BEAD-only” processes. Unify data, field ops, QA, reporting, and procurement so every project benefits and parallel processes do not erode margins or reliability.

Clarify how statute, NTIA Specific Award Conditions, Policy Notices, and state terms interact. Your job is to resolve conflicts in favor of the governing source and keep agreements aligned with the ladder your clients will be held to.

Insist on definitions, data schemas, submission formats, and acceptance criteria that an operations team can follow. Move ambiguity out of the field and office. The agreement should read like a spec the project can actually run.

Subgrantee agreements only succeed if they can be executed consistently over years of construction, activation, and service. That’s where 

 comes in. It helps states and awardees turn agreement language into day-to-day practice by standardizing how evidence is collected, validated, and reported.

ARC converts agreement language into structured, step-by-step processes that guide awardees through each milestone phase. Clear checklists specify required evidence, acceptable formats, and submission deadlines—eliminating ambiguity about what documentation proves completion. Automated validation checks flag missing or non-compliant submissions before review, reducing back-and-forth cycles. States gain visibility into milestone progress across all projects, while awardees know exactly what's needed to trigger their next payment. The result: milestones function as they're intended—as progress accelerators, not payment bottlenecks.

For consultants, ARC can serve as the backbone of a workable compliance model:

Consultants who scope reporting and compliance realistically, and back it with practical systems become indispensable. They cut program risk for states, speed payments for subgrantees, and keep the focus on broadband delivery. 

To put this into practice, strengthen your client programs with the same discipline we recommend to states. For a full picture of how to apply these principles across BEAD reporting and compliance, check out the companion posts in this series: 

Billions in BEAD funds hinge on the strength of subgrantee agreements. Clear, specific language and the right systems turn these contracts into blueprints for success—while vague or boilerplate terms risk audits, clawbacks, and costly delays.

Subgrantee agreements are the backbone of BEAD implementation—turning billions in public funds into enforceable obligations and measurable outcomes. Learn how consultants can navigate evolving compliance demands, design audit-ready agreements, and help clients build lasting success with tools like ARC (Automated Reporting & Compliance).

What Consultants Must Know About BEAD Subgrantee Agreements | Turning Compliance into an Advantage

For consultants, BEAD compliance isn’t just paperwork—it’s a 14-year accountability journey. Learn how to design audit-ready agreements, operationalize reporting, and help clients stay ahead with ARC, the platform that turns subgrantee requirements into repeatable, verifiable workflows.

What Consultants Must Know About BEAD Subgrantee Agreements

 What Consultants Must Know About Subgrantee Agreements

The BEAD program is entering its most critical phase: moving from awards on paper to networks in the ground and homes connected. The real test will be whether states can oversee thousands of subgrants in a way that is transparent, enforceable, and workable for providers.

What We’re Seeing in Subgrant Agreements

Across the country, states are publishing draft BEAD subgrant agreements for public comment. At first glance, these agreements look strikingly alike — drawing on the same federal authorities and reiterating provisions from IIJA, the BEAD NOFO and Policy Notices, and 2 CFR 200. 

But this uniformity should not be confused with a formal NTIA template. Instead, states appear to be working from a shared boilerplate — whether through consultants, legal counsel, or interstate collaboration.

Beneath that surface consistency, practices diverge:

The result: while the contracts read alike, the 

progress and reimbursement structures are inconsistent

This variability creates serious challenges:

When designing oversight systems, states should consider:

Milestones are not just about measuring progress — they also anchor the flow of funds. Under BEAD, states can choose different reimbursement approaches

By mapping reimbursement to a standardized set of milestones, states can create fair, transparent systems that protect public funds while giving providers confidence that payments won’t be delayed.

No single office, provider, or platform can deliver BEAD oversight on its own. Federal requirements are intricate, state contexts vary, and providers bring a wide range of capacities and constraints. That’s why 

consultants and technical partners are essential allies in this work

For us, the goal is not to prescribe a single model, but to 

 — with consultants, providers, and state broadband offices — to design oversight systems that are rigorous, workable, and built to last.

Standardized milestones are more than a reporting tool. They are the foundation of trust:

Turn Compliance Into an Advantage with ARC

Ready’s Automated Reporting & Compliance (ARC)

 turns BEAD reporting from a manual grind into a push-button process. Instead of wrestling spreadsheets and inboxes, you get faster reimbursements, fewer back-and-forths with the state, and clear status across locations, milestones, and claims—all fed by source-of-truth data.

When states adopt ARC, subgrantees spend less time on paperwork and more time building. Every automated submission moves milestone payments sooner. Every compliance check is verified in the background. Every audit trail is ready when you need it.

ARC meets BEAD’s bar—and helps everyone win: subgrantees stay focused on delivery; states get complete, consistent reporting.

less time on compliance and more time serving customers

, ask your state broadband office to adopt ARC.

The BEAD program now faces its biggest test: turning awards on paper into real networks and connected homes. Success will depend on whether states can manage thousands of subgrants transparently, enforceably, and efficiently.

As BEAD transitions from paper awards to real networks, states face the challenge of managing thousands of subgrants transparently and consistently. Standardized milestones can streamline oversight, speed reimbursements, and strengthen accountability across projects.

Streamlining BEAD Post-Award Management: Why States Need Standardized Milestones

Streamlining BEAD Post-Award Management: Why States Need Standardized MilestonesBEAD is moving from plans to progress — and oversight is now the test. States can simplify management and ensure fairness by adopting standardized milestones that bring clarity, consistency, and confidence to every subgrant.

Why States Need Standardized Milestones to Streamline BEAD Post-Award Management

State broadband directors face a persistent challenge: In their role, they must ensure public investments deliver promised outcomes while also avoiding delays that prevent communities from accessing needed connectivity. LEO satellite broadband is emerging as the dominant technology for remote areas, making this challenge more complex. Orbital dynamics, shared capacity networks, and rapid deployment timelines construct new verification scenarios that traditional terrestrial oversight methods do not adequately address.

The Ready.net team and I are analyzing this new intersection of opportunity and accountability. We care about the outcome of the BEAD program and want to do everything we can to ensure efficient and effective use of public funds. LEO technology offers genuine opportunities to serve extremely remote locations, bolster emergency response, enhance network redundancy, and bridge coverage gaps while terrestrial infrastructure develops. Importantly, there are unique characteristics of orbital networks. Satellites travel at 17,000+ mph, promise dynamic capacity allocation, and have service areas spanning thousands of square miles… affordances that all require adapted verification approaches.

Drawing from conversations with State Broadband teams across multiple BEAD implementations, I hear concerns about the management of satellite provider project oversight. State Broadband Offices (SBOs) and their teams express worry about how to monitor whether satellite dishes are being distributed and successfully installed at end-user premises, particularly given the remote nature of many BEAD-funded locations served by the technology. Stakeholders are also grappling with how to track and verify that reserved capacity commitments are being met over time, since traditional fiber, cable, or even fixed wireless monitoring approaches do not translate directly to satellite deployments. Additionally, there is confusion around tracking requirements for the up-to-three upgraded or replacement dishes allocated per BEAD-awarded location and whether the replacement cost is calculated per location or per subscriber. Each of these factors have significant compliance implications.

The technical challenge isn't insurmountable, but its coordination requirements are complex and states need practical tools to fulfill their oversight responsibilities without creating unnecessary administrative burden. We developed Ready’s open source ORBIT satellite monitoring framework as a baseline for the broader community to adopt or adapt. As a public benefit corporation, Ready’s mission centers on helping connect more families to better utilities at lower cost. This framework is part of our mission and serves the broader goal of bridging the digital divide. As I have grown closer to my colleagues, I assert that lowering barriers and reducing friction for clients and communities is simply who we are and what we care about.

Together with a team of other subject matter experts, we developed a framework for risk mitigation that also serves to maximize opportunity for stakeholders. The ORBIT Framework (Orbital Reliability, Broadband Integrity, and Transparency) provides a three-layer verification system specifically designed for satellite broadband programs:

Layer 1: Service Availability Verification

 ensures LEO providers can deliver promised speeds and latency within specified timeframes, typically requiring 10-day service initiation capability across awarded locations.

 confirms actual service adoption rather than just theoretical availability, preventing ghost subscriber schemes that have plagued other telecommunications subsidy programs.

 validates that providers maintain sufficient network capacity to serve awarded locations throughout the performance period, addressing concerns about network congestion during peak usage periods.

Practical Implementation for BEAD LEO Capacity Subgrants

The ORBIT framework structures funding distribution in order to balance deployment acceleration alongside accountability by anchoring progress to milestone-based payments. Here's how ORBIT may work in practice:

This structure addresses several practical concerns: 

1) The substantial service availability payment enables providers to begin deployment immediately while creating accountability for actual capability; 

2) Subscriber milestone payments incentivize genuine adoption rather than paper compliance;

3)The extended capacity reservation period—distributed as 3% annually over ten years—maintains provider incentives for continued service quality while matching the infrastructure-focused timeline of terrestrial deployments.

The ORBIT framework is designed to be nimble; states can adjust milestone percentages based on local market conditions and risk assessments. Also, rural areas with historically low broadband adoption could choose to weight service availability heavily, while regions with strong demand might prefer to emphasize subscriber milestones. The percentage-based approach in the ORBIT framework scales from small community projects to statewide deployments, maintaining consistent incentive structures across projects, large and small.

The technical aspects of the ORBIT framework focus on measurable outcomes rather than process compliance:

LEO satellite broadband represents a transformative tool for closing coverage gaps, but its deployment through public funding necessitates appropriate safeguards. For stakeholders seeking to ensure the efficacy of BEAD funds, the challenge and promise of LEO lies not in the technology but in implementing verification systems that fuel rapid deployment and protect taxpayer investments. A scalable subgrant verification plan is the best insurance to realize promised LEO service delivery to beneficiary communities.

We designed the ORBIT Framework to acknowledge both LEO's strengths and limitations. Some locations awarded to LEO providers may ultimately prove unsuitable for satellite service due to topography, interference, or economic factors. In our research, we find that structuring disbursements with performance bonds, subscription milestones, and fund recovery mechanisms provides necessary capital protection while allowing providers the flexibility to optimize network resources.

Moving forward requires recognition that perfect solutions don't exist, but rather, understanding that practical progress remains achievable through strategic prioritization. States implementing LEO capacity subgrants need verification frameworks that match the technology's unique characteristics while maintaining the accountability standards that broadband programs require.

For state broadband directors evaluating LEO deployment options, the ORBIT framework provides a starting point for balancing deployment speed with program integrity—ensuring that communities counting on connectivity receive the reliable service they need while protecting the public investments that make it possible. We look forward to hearing your feedback and continuing to work with you all to solve these unique challenges.

Please stay tuned for a white paper on how and why Ready arrived at the ORBIT framework.

State broadband offices face new oversight challenges as LEO satellites emerge in BEAD deployments, and the ORBIT Framework offers a practical approach to ensure fast rollouts while safeguarding accountability and service reliability.

State broadband offices face new oversight challenges with LEO satellite deployments under BEAD. Ready.net’s ORBIT Framework provides a three-layer verification system to balance rapid rollout, accountability, and service reliability.

The ORBIT Framework: Ensuring Accountability in LEO Satellite Broadband for BEAD

LEO satellites are reshaping broadband access in remote areas, but oversight is complex. The ORBIT Framework helps state broadband offices ensure BEAD funds deliver reliable, verifiable results.

The ORBIT Framework: Balancing Speed and Accountability in LEO Broadband

Practical Framework for LEO Satellite Broadband Oversight

State Broadband Offices (SBOs), you’ve been through a lot. Years of mapping battles, policy debates, planning requirements, and public scrutiny. Now, BEAD is entering the post-award stage, and the spotlight shifts squarely onto you.

The question is no longer whether funding will flow — it’s whether the networks built under your oversight will deliver for decades to come. NTIA’s September 2025 

Performance Measures for BEAD Last-Mile Networks

 Policy Notice gives you a strong foundation. But what you do next will determine if BEAD becomes a generational success story or a cautionary tale.

Give credit where it’s due: NTIA has put forward performance measures that are smarter, clearer, and stronger than those of past federal broadband programs. They do a few important things:

Require annual testing of BEAD-funded networks for speed, latency, and reliability.

Mandate random sampling across subscribers and technology types.

Set firm thresholds for latency and reliability.

Together, these measures reduce loopholes, cut down administrative burden, and give you tools that simply didn’t exist under past programs. They’re not the ceiling — but they 

a stronger floor than we’ve seen before.

You’re not the first broadband leaders to face this challenge. But you are the first with tools this strong. Compare BEAD’s framework with what came before:

 starting at 100/20 Mbps minimum, enforcing tech-specific reporting, requiring verified testing, and empowering states with corrective action tools.

NTIA has given you the foundation. But the real legacy is yours to write. Federal performance measures prevent failure. State measures can ensure excellence.

Performance measures are only as good as their implementation. Watch for:

NTIA sets the performance measures, but you hold the levers:

Going beyond the baseline doesn’t need new federal law. It needs:

Stronger performance measures don’t have to mean more paperwork or heavier burdens. The reality is that testing and reporting can be done faster, more efficiently, and more reliably if states use modern tools to automate the process.

That’s exactly what platforms like ARC are designed for:

In other words: states don’t need to choose between rigor and practicality. With the right systems in place, performance measures can be trustworthy and low-burden at the same time — ensuring accountability without slowing deployment.

You don’t have to do this alone. Every state is grappling with the same questions: how to balance burden with rigor, how to close loopholes, how to protect investments.

point_down

We’re convening a working group to tackle these issues together. Email standards@ready.net to join the conversation.

State Broadband Offices, you’ve been through a lot. Years of mapping battles, policy debates, planning requirements, and public scrutiny. Now, BEAD is entering the post-award stage, and the spotlight shifts squarely onto you.

Explore NTIA’s new BEAD performance measures. Learn how states can go beyond federal baselines to ensure reliable, lasting broadband networks.

NTIA BEAD Performance Measures: Post-Award Guide

NTIA’s new BEAD performance rules give states a strong foundation. But the true legacy depends on how broadband offices go beyond the baseline.

BEAD Performance Measures: Building Beyond the Baseline

NTIA BEAD Performance Measures: Building Beyond the Baseline for Better Broadband

As final proposals undergo final curing and the very last BSLs find their home into different project areas, many stakeholders eyes’ are set on the next iteration of these historic awards. Winning a BEAD award is not the end of the process, after all…the binding subgrantee agreement is where obligations, enforcement, and timelines are locked in for the lifespan of the project. These agreements are already circulating in draft form and they share common structures that all parties should understand. This guide highlights the contract mechanics that matter most.

Subgrantee agreements are just as critical for states and territories, who must enforce them at scale. For that perspective, see our related post: 

What Every State and Territory Must Know About Subgrantee Agreements

Zoom in on what BEAD actually asks for—location-level accountability, measurable performance, milestone discipline—and you’ll see strong alignment with how scaled operators manage growth.

BEAD affords a four-year maximum build from execution to “substantial completion”, meaning service available to all locations. The longer number? A Ten-year “federal interest period” after closeout where obligations persist: service levels, affordability, record retention, clawback exposure.

Operators who extend BEAD-grade systems across their entire footprint can expect key advantages: clearer insight into customer behavior, faster course corrections, and a stronger foundation for future growth.

Five Operational Pillars in Your Subgrant Agreement

Your subgrantee agreement contains several core requirements that, when properly leveraged, become competitive moats, including:

1. Financial Controls That Drive Capital Efficiency

Letters of Credit or Performance Bonds are standard across draft agreements. Many also hold back a percentage (often 10%) of the award until final acceptance, and some allow limited contingency funding requests. These measures are not just red tape but rather keep both state and subgrantee aligned on accountability and solvency.

Funding flows through milestone gates: planning, permitting, mid-build, substantial completion. Each state template attaches evidence checklists that contain multiple pathways for evidence to resolution: network design receipts, certified payrolls, BABA documentation, even photos of completed segments. Missing pieces in the evidence trail will result in stalled payments.

Build and automate your milestone documentation process before breaking ground. Align field teams, finance, and compliance staff so that every pole attachment and permit generates the proof you’ll later need to unlock funds and unleash a reliable stream of operational intelligence.

BEAD’s Build America, Buy America (BABA) requirements enforce strict domestic sourcing and documentation. Meeting BABA standards requires stronger supply chain management, which can also create lasting advantages. Operators that align their procurement systems to BABA can build closer vendor relationships, improve purchasing leverage, and strengthen resilience against disruptions.

The documentation required for compliance doubles as a supply chain risk management system, giving awardees greater visibility and control without adding new layers of cost.

4. Labor Standards as Workforce Excellence

Build your milestone documentation process before breaking ground. Align field teams, finance, and compliance staff so that every pole attachment and permit generates the proof you’ll later need to unlock funds.

Compliance starts with the subgrantee agreement, but it ends at the subscriber. If the network doesn’t perform, nothing else matters.

Make performance measurable from day one. Plan to measure clear performance targets (throughput, latency, reliability/uptime, jitter, time-to-repair) and tie them to how you design, build, and operate. Instrument at the edge and core so you’re not guessing later.

When rules collide, agreements establish a hierarchy. Across states, the order looks familiar: IIJA statute first, Specific Award Conditions from NTIA second, Policy Notices third, then state Final Proposals and terms. This ladder matters when disputes arise over ambiguous language.

Don’t assume your state’s terms override federal law. In any conflict, the federal sources almost always win. Read your agreement with that ladder in mind.

Every template includes teeth: suspension of reimbursements, termination for default, clawback of funds, and record access for up to ten years post-closeout. Enforcement is not hypothetical.

Default and clawback are avoidable if states build “cure period” language into agreements. This gives subgrantees a window to fix issues before facing the hammer!

Don’t create a BEAD standard and a non-BEAD standard. Unify your data, field ops, QA, reporting, and procurement so every project benefits—and you’re not maintaining parallel worlds.

Today’s reports and audits are tomorrow’s proof points—for additional public funding, commercial partnerships, and regulatory trust. Invest in traceability and make it easy to produce evidence on demand.

 can be an inflection point. Success favors teams that operationalize the standards—not just survive them.

At the heart of BEAD reporting and compliance is the subgrantee agreement. This document defines how awardees will meet requirements, safeguard funding, and prove results.

Awardees who go beyond checking the box are finding that BEAD’s demands, including location-level tracking, strong financial controls, and structured reporting, can also strengthen their broader operations. In doing so, they turn compliance into a foundation for long-term growth.

Subgrantee agreements are the foundation of BEAD success. Learn how financial controls, reporting, BABA, labor standards, and performance requirements shape awardees’ obligations—and how to turn compliance into a competitive advantage.

What Every BEAD Subgrantee Must Know About Subgrantee Agreements

Winning a BEAD award is just the beginning. Subgrantee agreements lock in the rules that define success for the next decade. This guide shows awardees how to meet requirements, protect funding, and use compliance as a growth accelerator.

The Definitive Guide to BEAD Subgrantee Agreements

What Every BEAD Awardee Must Know About Subgrantee Agreements

Subgrantee agreements are the operating system of your BEAD program. For a full perspective from the awardee side, see our companion piece: 

What Every BEAD Awardee Must Know About Subgrantee Agreements.

Once awards are finalized, states must oversee multiple subgrantees working across thousands of locations while meeting federal compliance and reporting requirements that were not specifically designed for a program of this scale.

Your subgrantee agreements establish the framework for three essential functions:

The Five Non-Negotiable Elements of Subgrantee Agreements

Subgrantee agreements are the legal mechanism that turns federal program requirements into enforceable obligations. Each agreement must translate BEAD’s rules into contract terms that your office can monitor and enforce. Most importantly, know the governing compliance and reporting rules – all reimbursable costs must be reasonable, allowable, and allocable.  At a minimum, every agreement should cover five non-negotiables:

Federal law requires financial scrutiny, clawbacks, and audit rights — but the agreement is where you define the details. Agreements must spell out requirements for:

BEAD requires continuous location-level reporting, and the subgrantee agreement dictates the cadence, format, and enforcement mechanisms. States and territories should require:

BABA rules apply to BEAD, but enforcement has shifted. Subgrantee agreements should still define:

Subgrantee agreements must make adherence to the performance standard minimums enforceable. That means:

Federal requirements like NEPA and Section 106 apply to every project, but only the subgrantee agreement gives the state or territory enforcement powers. Each agreement should state:

The Three Fundamental Shifts Driving BEAD Compliance

BEAD contains monumental compliance and reporting challenges: tracking and verifying service delivery across millions of locations, every month, for over a decade.

Past programs operated at the census block group (CBG) level, allowing awardees to claim entire areas as “served” by reaching only one location within the census block. Fortunately, BEAD flips this model: every Broadband Serviceable Location (BSL) must be individually connected, verified, monitored, and remain audit-ready. That means moving from ~10,000 CBGs to 10+ million discrete individual locations, each requiring proof of connection, proof of service, GPS precision, and location-level performance standards and metrics.

Previously, federal program “success” meant network infrastructure “passed” a home or delivered service to the demarcation point, to determine whether service was completed and ultimately adopted. BEAD requires the documentation of actual physical connections—subgrantees must connect and serve every eligible location and customer who requests broadband within four years. This adds BSS integration, churn management, privacy protections, and customer satisfaction monitoring into the compliance and reporting mix.

Old NTIA programs ended robust compliance monitoring once network construction was certified, and many other federal programs do not conduct or require oversight and monitoring at all. BEAD has introduced continuous compliance monitoring for more than a decade: 120+ monthly reports per location, ever-evolving federal program requirements, and compounding violations that can cascade across numerous projects. Compliance and oversight may seem to start as manageable tasks in the first few years, but they intensify as equipment ages, staff turnover builds compliance debt, and legacy systems strain under long-term program obligations.

Smarter Oversight Through Agreements and Automation

Strategic states and territories will treat their subgrantee agreements as opportunities to apply lessons learned from BTOP, RDOF, CASF, and other programs by including much stronger compliance guardrails in place from the start. The smartest approach is not one-size-fits-all: rather, compliance and oversight should be calibrated to award size, awardee history, and project complexity. High-risk projects require frequent grant and financial management reviews, site visits, equipment checks, and non-routine touch points, while low-risk projects can operate with more autonomy, all while maintaining the levels of oversight and scrutiny needed to thwart waste, fraud, and abuse.

What will set leading states and territories apart is how they harness automation to make oversight simpler and yet stronger. Tools that reduce manual effort, such as manual spreadsheet and PDF reviews, and provide early visibility, will help directors stay ahead of problems, 

Finally, strong subgrantee agreements should build on what was learned during the pre-qualification phase. States and territories can carry forward those insights to develop comprehensive risk profiles, assessments, and mitigation plans that guide how each award will be managed. That means:

Introducing ARC: Automated Reporting & Compliance 

When tracking subgrantees across thousands of locations, with millions of compliance checkpoints, traditional tools like spreadsheets, emails, PDFs, and manual reviews quickly reach their limits. Blind spots can creep in, slowing projects, increasing payment approval and processing time, and making oversight harder. That is why we built ARC, Automated Reporting & Compliance. 

ARC solves this by turning subgrantee agreements into living, enforceable commitments and automates the hardest and most complex parts of reporting and compliance. ARC validates evidence in real-time, streamlines reimbursements with AI checks, and gives state directors a single dashboard to monitor every project at once.

The states and territories that succeed in connecting every household, business and anchor institution won’t simply be the ones with the most funding or the biggest awardee providers. Success will come to those who recognize early that BEAD requires strict adherence to operational capabilities, processes, and procedures designed to manage work at this scale.

ARC transforms overwhelming reporting and compliance demands into clear, actionable geospatial workflows that protect every dollar, verify every connection, and deliver on the promise of broadband for every community.

BEAD accountability depends on strong subgrantee agreements. This guide outlines the five essential elements states must include to protect billions in federal investment, enforce compliance, and manage oversight across thousands of projects.

What Every State Must Know About Subgrantee Agreements

Subgrantee agreements are how BEAD succeeds. They turn federal requirements into enforceable obligations and give states the tools to protect funds, ensure compliance, and manage oversight at unprecedented scale.

“Victorious warriors win first, then go to war.” – Sun Tzu

As we prepare to celebrate America’s 250th birthday, we must confront a sobering reality: the critical infrastructure connecting and powering our nation contains a not-so-secret vulnerability that, if exploited, would send us back into the digital dark ages.

America’s vulnerable critical infrastructure is one cascading failure away from collapse:

A few coordinated tactical electromagnetic pulse attacks could render our smart infrastructure very dumb in less than a blink. Our adversaries know this. They’ve studied our weaknesses for decades,

developing strategies and weapons designed to cripple America before a single shot is fired

, America relies on infrastructure unable to withstand a wide and growing range of systemic risks. A coordinated attack on the U.S. power grid could exceed

 in the first year alone. Such a price makes proactive investment required to harden, shield and distribute our critical systems look negligible by comparison.

Good News: Resilient Critical Infrastructure Funding Exists

America already committed to invest in resilient critical infrastructure, provided leaders in Washington work to follow through on our commitment. The Infrastructure Investment and Jobs Act (IIJA) authorized over $1 trillion for essential projects, with $42.5 billion allocated through the Broadband Equity, Access, and Deployment (BEAD) program.

Here's one opportunity for our nation’s leaders: Estimates suggest $10-25 billion in BEAD non-deployment funds remain available for reallocation. Today, the fate of BEAD non-deployment is up in the air, but these already-authorized dollars can and should be refocused toward making resilient the infrastructure that keeps America online.

Because BEAD non-deployment funding is already appropriated under IIJA, no new spending is required. Instead, America has an opportunity to strategically reallocate existing funds to address one of the most critical gaps in our national defense. This isn't new spending—it's strategic reallocation of existing commitments toward our most pressing national security priority. Redirecting these funds to resilience is the fastest way to secure America’s digital backbone.

Building on this win-win, non-deployment funds could be paired with the visionary bipartisan

, introduced by Senator Roger Wicker (MS) & Senator Michael Bennet (CO), to dramatically amplify public and private investment into resilient critical infrastructure. If approved and combined with BEAD non-deployment dollars, this approach could significantly increase the resources available for resilience, potentially doubling or even tripling the impact of BEAD non-deployment.

Great News: Resilience Investments Unlock AI at the Edge

 today protects lives, strengthens our economy, and positions America to continue leading the AI revolution. Resilience ensures the benefits of AI reach deep into rural America for next-generation wellness, precision agriculture, robotic manufacturing, re-industrialization, and more.

Investment in making America's vulnerable infrastructure resilient is the exact same investment needed to bring next-generation AI to "the edge"— also known as where people live, work, and play.

When we distribute computing power away from over-concentrated hyperscale centers, and into thousands of hardened edge nodes, we simultaneously:

Consider the near future of emergency response or telehealth. An outage from a fiber cut that doesn’t fail over to a backup within seconds puts lives at risk. Hundreds of milliseconds of latency added when critical services are routed thousands of miles to a hyperscaler and back is the difference between success and failure. Critical processing must happen locally, with storage in nearby infrastructure nodes and transmission maintaining constant availability. We must proliferate our nation’s IXPs — from dozens to thousands.

The same hardened, distributed infrastructure that protects America from attack also unleashes the greatest economic opportunity in our 250-year history.

Every hardened substation, redundant fiber route, and distributed computing node makes America more resilient and better positioned to lead the AI revolution. The infrastructure hardest to secure today becomes tomorrow's greatest competitive advantage.

The window for action is closing fast. BEAD funding decisions must be finalized within the next month to meet NTIA’s end of year goal. We cannot afford to let this moment pass.

We can keep operating on the assumption that solar flares or cunning adversaries will never put our nation to the ultimate test. Or we can invest in distributed, resilient systems that ensure America remains connected, protected, economically dominant, and ready for the next 250 years.

For a deeper analysis of how to design and secure the critical infrastructure America depends on, read 

7 Key Principles of Resilient Critical Infrastructure

Billions in BEAD funds can be redirected to harden America’s digital backbone, unlock AI at the edge, and secure our future. 

Securing America’s Infrastructure for a Resilient Future

Billions in BEAD funds can be redirected to harden America’s digital backbone, unlock AI at the edge, and secure our future.

America’s Infrastructure Crossroads: From Risk to Resilience

America’s Infrastructure Crossroads: From Vulnerability to AI Leadership

America’s critical infrastructure is under pressure. From hostile adversaries to climate-driven disasters, the threats are growing faster than our defenses. We've built world-class cybersecurity systems, but neglected the physical layer underpinning networks, devices and essential services.

America’s critical infrastructure is exposed. Learn seven principles to build systems ready for anything.

Articles by Clayton Wooley

Practical Framework for LEO Satellite Broadband Oversight