Monitoring and compliance: Closing the Digital Divide with proof

How can states and territories ensure their BEAD projects remain on schedule to provide the specified service levels and prevent costly delays or disruptions?

Washington, DC (November 3, 2025) - By leveraging Connected Nation’s broadband expertise and experience in the field, states and territories have a trusted partner that can be their literal and virtual eyes in the field. CN has over 15 years’ experience in the broadband industry verifying grantee compliance with contract terms and specifications and assessing construction progress for local, state, and federal programs.

The specifications and terms may differ along with our approach, but, in the end, the objective is the same: to ensure compliance. We understand the need for connectivity and how it’s accomplished, as that is our mission. CN’s services apply to all technologies, including wireline and wireless, and go beyond self-reporting that may not uncover problems or issues that are evident in the field until it is too late to take corrective action.

The 1-10-100 rule from quality management illustrates how the cost of fixing an error increases exponentially the later it is detected. And to fix, you first need to detect. Too often as we have seen during construction, issues are hidden with the expectation by the provider that they will be corrected down the line, but that is not always the case. An independent eye is critical to ensure compliance with the contract specification.

That said, CN does not rest on its prior experience to do things the way it always has. At CN we are continually evolving with the pace of technology and adapting to our client needs. With the advancement of both wireline and wireless broadband technologies, the implementation of newer technology transmission platforms (e.g., Low Earth Orbit satellite), and overall technological advances such as Artificial Intelligence, CN has evolved to better support client and programmatic needs. We continually train our staff and provide opportunities for experimentation and improvement.

State Programs

CN does not apply a one-size-fits-all approach to monitoring and compliance. In some states we work in, field validation is included in every contract, and every location is tested and validated. In other states, we target selected locations and make multiple site visits to ensure progress is as expected.

Along the way, we build rapport with the provider community to ensure compliance and monitoring activities are not seen in a negative light but as a step in the overall process. CN can target its approach in consultation with the program administrator and contract specification to ensure the approach meets the need.

Although funding may come from the federal government, there are often state requirements that are introduced as part of the disbursement of funds. These could be state audits that include specific requirements on independent verification. Compliance and monitoring plans need to take into consideration federal, state, and program requirements. We have consistently seen in-the-field monitoring and compliance activities function as both ensuring what is being tested is in compliance and  to meet the general expectation that field verification can positively influence future work to better ensure compliance.

BEAD

The latest guidance, “Performance Measures for BEAD Last-Mile Networks,” released in September, requires speed tests to be conducted by the subgrantee from the subscribing customer premises. The test results are to be submitted following the Universal Service Administrative Company (USAC) speed test data template to the eligible entity on a yearly basis for the duration of the period of performance.

These subgrantee-conducted remote tests should be considered minimum requirements that are based on subscribers for a subgrantee across as their projects per technology. (Subscribers are counted across all BEAD-funded projects of a subgrantee in a state or territory for each technology type, not separately for each BEAD project). This could result in projects with 500 and 2,000 locations getting the same level of verification.

This does not account for the geographic variation and different environmental conditions on the ground or geographic dispersion of locations that may impact a project. Grantees may not be building at the project level, but that is what the states awarded funds based on and need to track at.

Going Beyond the Minimum

For states looking for greater assurance that their investments deliver the expected outcomes for their constituents, they could consider additional validation. In the case of BEAD, costs associated with monitoring subgrantees are not subject to the 2% administrative cap.

This is similar to the multi-pronged approach USAC takes. CN strongly suggests states adopt a data-driven, risk-based framework for determining additional locations to be validated in the field. CN can leverage existing publicly available and provider reported data to determine the optimal number and geographic distribution of locations to be validated. In this approach, both projects and providers would be objectively classified as "low," "medium," or "high" risk in a risk matrix to determine the recommended extent of the validation effort while maximizing the likelihood of catching projects in need of intervention or further attention.

Evaluating risk would draw on multiple variables, including project specifics, reporting completeness, environmental factors, regulatory hurdles, and information gathered directly from providers. These inputs would then be fed into a machine learning classification model to assign projects and providers to one of the three risk categories. This quantitative, evidence-based method ensures that validation resources are allocated efficiently while maintaining accountability and program integrity.

The variables considered vary by technology. This takes into consideration the years of experience CN gained processing millions of records of broadband data in the field and through consulting with our clients. For example, we would adapt our tree canopy model as a variable for defining risk for LEO satellite.

The below risk model matrix demonstrates the concept of considering multiple dimensions to defining risk and applying it to determining the number of locations to validate. From this, the geographic distribution would be determined.   

Conclusion

In an era of unprecedented broadband expansion, the stakes for delivering reliable, equitable connectivity have never been higher. While minimum compliance measures like subscriber-based speed tests offer a baseline, they fall short of capturing the full picture—especially in geographically diverse or environmentally complex regions. That’s where Connected Nation’s field validation expertise becomes indispensable.

With over 15 years of hands-on experience, CN brings more than just technical know-how—it brings a proactive, adaptive, and data-driven approach to oversight. CN’s field validation doesn’t just confirm what’s been built; it influences how future work is approached, fostering a culture of accountability and continuous improvement. By going beyond self-reporting and embracing risk-based validation, states and territories can ensure that every dollar spent delivers measurable impact.

Field validation is not a checkbox—it’s a strategic investment in program integrity, public trust, and long-term success. With CN as a partner, states can confidently move beyond a minimum standard and toward a future where broadband access is not just promised but proven.