Preparing ISPs for BEAD Subrecipient Agreements: What to Expect and How to Get Ready 

December 2, 2025

As states finalize their NTIA BEAD provisional awards, Internet Service Providers (ISPs) should be turning their attention to the next big step — meeting the conditions required before a subrecipient agreement can be executed. 

While every state will apply its own version of these requirements, most share a common set of financial, operational, and cybersecurity obligations. ISPs that start preparing now will be far better positioned for a smooth contract execution and project launch. 

Here’s what to expect — and where to focus your readiness efforts: 

1. Financial Assurance 

If you were a provisional awardee, your Letter of Credit (LOC) or Performance Bond will soon move from a commitment to a requirement. Engage your bank or surety provider now to confirm terms and amounts — waiting until the agreement stage can delay execution. 

2. Cybersecurity Readiness 

A Cybersecurity Plan isn’t optional — it’s a BEAD requirement. States may require either a full plan submission or an attestation, but every ISP must have a comprehensive, compliant plan in place that aligns with industry standards and protects both network integrity and customer data. 

3. Supply Chain Risk Management 

BEAD funding requires a Supply Chain Risk Management (SCRM) Plan, outlining vendor assurance, equipment risk, sourcing vulnerabilities, and mitigation strategies. States may require either attestation or full plan submission here as well — if you haven’t developed one, prioritize it alongside your cybersecurity plan. 

4. Updated Project Milestones 

Expect to submit deployment schedules based on your provisional award with timelines that are realistic and updated. These will set your official period of performance and ensure your timelines align with state-defined scoping and sequencing. 

5. Revised Budgets 

Budgets must reflect final BSL-level awards and negotiated unit costs. Updated cost data helps establish reimbursement frameworks, validate cost reasonableness, and prevent delays in the first drawdown. 

This is especially important in states where:  

• BSL negotiations occurred during curing  

• Reimbursement will be based on a percentage of construction costs  

• Cost reasonableness was tied to cost-per-location figures  

6. Updated Pro-Forma Financials 

States may request updated pro-forma financials or sustainability analyses based on revised awards. As NTIA updates operational support guidance, expect closer scrutiny of long-term viability and financial models.   

Don’t Forget: Audit Readiness 

ISPs will be treated as federal subrecipients and are subject to audit requirements as stipulated in the award or sub-award between the Federal awarding agency and the recipient. Before the first reimbursement request, ensure you have: 

• Accounting and cost allocation systems that comply with Uniform Guidance and clearly segregate BEAD costs. 

• Procurement and conflict-of-interest procedures that meet federal standards 

• Timekeeping, payroll, and property management controls 

• Policies for reporting, documentation, and records retention 

These tasks should not be put off — they’re baseline conditions for successful program participation. 

How Witt O’Brien’s Can Help 

At Witt O’Brien’s, we support ISPs and state broadband offices prepare for post-award success — from compliance planning and subrecipient monitoring to audit readiness and financial management. 

Our team can assist you in: 

• Developing required cybersecurity and SCRM plans 

• Aligning your systems with Uniform Guidance requirements 

• Building readiness before the state — or federal auditors — come knocking. 

BEAD isn’t just about building broadband — it’s about building capacity. 
Preparation now ensures your project starts strong, stays compliant, and finishes without costly surprises. 

Managing grants efficiently, without compromising compliance and integrity, can be a challenging task. If your organization is navigating the complexities of grant management, we can help you enhance oversight, streamline processes, ensure outcomes and reduce the risks of waste, fraud, and abuse. Reach out today to learn how our expertise in grants management can ensure your programs meet their goals, stay compliant, and make the best use of taxpayer dollars. 

Authored by: