NTIA Directs States to Conduct BEAD True-Up for Second Benefit of the Bargain Round

The National Telecommunications and Information Administration (NTIA) has issued a Supplemental Deployment Policy Notice directing states to identify additional unserved locations and run a second Benefit of the Bargain round under the Broadband Equity, Access, and Deployment (BEAD) Program. For providers, this opens two distinct opportunities: a chance to compete for new BEAD dollars in areas that fell outside a state’s original Final Proposal, and a window to challenge any locations on the new list that are already served. Each state will run its own version of this process once NTIA sends its updated location list.

True-Up Process

NTIA is running this true-up to identify locations covered by another federal or state program which were left out of a state’s original Final Proposal, and the provider committed to serve them has since defaulted; locations were removed from a state’s original challenge process based on a competing claim of service that was never delivered; and updated federal broadband data now shows locations as unserved that weren’t reflected in the data used for the original Final Proposal.

Each state follows the same sequence once it receives its list from NTIA:

• Initial review (30 days): the state reviews the list and removes locations already covered by a separate state or local funding commitment.
• Publication and challenge window (7 days, then 30 days): within 7 days of finishing that review, the state publishes the list and opens a 30-day window for providers, local governments, and nonprofits to submit evidence that a location is already served or has service planned within 12 months.
• Challenge decisions (30 days): the state decides each challenge based on the evidence submitted, with no rebuttal round.
• Funding determination: once the state submits its final list, NTIA sets a funding amount based on the state’s average per-location cost from its original Final Proposal.
• Second round and deployment plan (180 days): the state has 90 days to run the second Benefit of the Bargain round, then submits a deployment plan and budget modification, which NTIA reviews within another 90 days.

Because each state’s clock starts when it receives its own list from NTIA, actual dates will vary by state and haven’t been announced yet.

Next Steps

If you’re interested in participating in your state’s second Benefit of the Bargain round, whether to compete for funding on newly eligible locations or to challenge locations that shouldn’t be on the list, please reach out to Amanda Molina or Brett Hallagan.