Broadband Funding: Stronger Management of Performance and Fraud Risk Needed for Tribal and Public-Private Partnership Grants

The Consolidated Appropriations Act, 2021, established two new broadband grant programs—the Tribal Broadband Connectivity Program (TBCP) and Broadband Infrastructure Program (BIP), administered by the National Telecommunications and Information Administration (NTIA) within the Department of Commerce. NTIA’s process generally aligned with recommended practices. However, NTIA’s current performance goals and measures will not tell the whole story of whether these programs succeed. In TBCP, NTIA does not have a performance goal or measure for funding broadband use and adoption projects on tribal lands—a stated program purpose. NTIA also has no way of measuring if the broadband deployed under TBCP is reliable and affordable even though it established those as goals of the program. Similarly, NTIA established affordability as a goal for broadband deployed under BIP but does not have a way of measuring affordability. NTIA officials said that they are still developing performance goals and measures for the programs, but without more complete goals and measures, the extent to which these two important grant programs, totaling billions of dollars, succeed will be unclear. As NTIA prepares for the next round of funding for the TBCP program, establishing clear goals and measures that reflect all of the program’s purposes prior to receiving applications and making award decisions would help NTIA ensure that it is making award decisions that consider those goals and measures. In addition, although NTIA has taken some steps to identify fraud risks, NTIA’s actions did not align with leading practices for fraud risk management in two key ways. First, NTIA has not designated a dedicated entity to lead its fraud risk management efforts. Instead, NTIA has several offices with different responsibilities associated with TBCP and BIP oversight without a clearly designated entity leading these efforts. Leading practices indicate that one entity should lead efforts to identify and manage fraud risks. Second, NTIA has not conducted fraud risk assessments for TBCP or BIP, as called for by leading practices. Without designating an entity to oversee fraud risk management activities and conducting a fraud risk assessment, NTIA lacks assurance that its controls are mitigating fraud risks in TBCP and BIP and that it is sufficiently positioned to combat fraud in the programs.