The Race Is On
How to Stay Ahead in the BEAD Implementation Timeline
December 16, 2025
The BEAD program is finally shifting into action, states are moving through approvals, subgrant agreements are being drafted, and projects will soon be under construction.
That’s the good news.
The challenge? We’re entering the most complex part of the process—where funding, supply chain, workforce, and compliance all collide on tight timelines.
In a December 11th webinar entitled: Navigating Post-Award BEAD Risk Mitigation, KGPCo’s Vice President of Strategic Partnerships, Ashley Travers, joined industry experts Lori Adams, Vice President of Broadband Policy & Funding Strategy at Nokia; Heather Mills, Principal Consultant from ITG, and Steve Coran, Attorney at Lerman Senter, to unpack what BEAD awardees need to be thinking about right now to avoid delays, cost overruns, and compliance headaches later.
Fixed-Amount Subawards
One of the most important—and misunderstood—features of BEAD is the widespread use of fixed-amount subawards.
Roughly 47 states have chosen to structure their BEAD subawards this way. While “fixed amount” sounds like a technicality, it carries two huge implications for awardees:
- No federal cost-principles compliance on the subaward.
- The ability to bypass federal procurement rules, including formal RFPs, multiple-bid requirements, and lengthy competitive processes.
In plain terms: if your state is using fixed-amount subawards, you can go directly to contract with your vendors—as long as you stay within your budget and follow any applicable state rules.
That flexibility is there for a reason. NTIA knows that if every awardee has to launch a full formal procurement cycle, projects will stall before they start. Fixed-amount subawards are a built-in accelerator—but only if you use them.
If you’re still waiting to see how things shake out before you engage suppliers and distributors, you’re giving up one of the biggest advantages BEAD offers.
Supply Chain Reality: If You Wait, You’re Already Behind
If there was one theme Ashley Travers returned to again and again, it was this:
Make decisions now.
Supply chain constraints are not hypothetical. They’re here already—and they’re exactly where you’d expect them:
- BABA-compliant fiber is under serious pressure.
- Loose-tube lead times: often 7–40 weeks.
- Ribbon lead times: 22–52+ weeks, with some suppliers already booking into 2027.
- Many non-BEAD projects are already consuming BABA-compliant inventory, shrinking the pool before BEAD construction even ramps.
That creates a domino effect:
- Material delays
- Construction delays
- Idle or lost labor crews
- Timeline risk and budget erosion
Crews will not sit and wait for fiber, cabinets, or electronics that are months late. They will move to other projects and other states. Once they’re gone, they rarely come back.
Even if your subgrant agreement isn’t fully executed yet, you should be working now on procurement planning—forecasting, identifying primary and backup suppliers, understanding lead times, and locking in commitments where your risk tolerance allows.
You don’t have to take every shipment on day one. But you do need a clear roadmap for when, how, and from whom you’ll source the materials that make your build possible.
BABA: No Workarounds, No Shortcuts, No “We’ll Fix It Later”
Another misconception the panel addressed: the idea that you can sidestep BABA requirements by shifting costs around.
You can’t.
For BEAD projects:
- If you are using the equipment or materials in a BEAD-funded build, they must comply with Build America, Buy America (BABA)—regardless of whether they are:
- Listed explicitly in your BEAD budget,
- Paid with matching funds, or
- Funded “out of pocket.”
There is no work-around that excludes you from BABA.
- You need early, direct engagement with suppliers on BABA status.
- You must insist on audit-ready documentation:
- Manufacturer letters on the NTIA template,
- Correct product IDs and part numbers,
- Traceability back to production location.
- You should assume you will be audited and build your documentation and file structure accordingly.
This is where a strong distribution partner matters. Managing hundreds or thousands of BABA certificates, SKUs, deliveries, and keeping everything organized for years of potential audits is a full-time job. The more you can centralize and standardize that work, the less risk you carry later.
Subgrant Agreements Are Negotiable
On the legal front, attorney Steve Curran shared a simple but important message:
You can and should negotiate your subgrant agreement.
States are moving fast. Many have never run broadband programs of this size, and some are repurposing templates from other programs that don’t fully fit BEAD’s structure.
Awardees should pay particular attention to:
- Budget flexibility
- Are you required to ask permission for every minor budget shift?
- Is there a reasonable threshold (e.g., changes below a certain percentage) that you can manage internally?
- Termination for convenience
- Some agreements give states broad latitude to “pull the plug” in their sole discretion.
- If states insist on these provisions, awardees should push for:
- Clear rules on what happens to the network and assets, and
- Symmetry (e.g., similar rights for the awardee in certain scenarios).
- Claw back & default provisions
- Understand what happens if you miss a milestone or run into delays.
- Are there cure periods, corrective action, and conditional remedies—or does the contract jump straight to “nuclear” options?
- Partial termination rights
- What if you can’t reach a handful of locations because of easements, tribal consent, or existing qualifying service?
- Can you partially terminate those locations and adjust funding, without being treated as in default on the entire project?
These aren’t theoretical issues; they go straight to financial risk, ownership of assets, and long-term viability. The time to address them is before you sign.
Compliance & Permitting: Plan Like You Will Be Audited
Finally, the panel spent considerable time on compliance, permitting, and environmental review—areas that can derail projects if left to the last minute.
Key points:
- Environmental & historic preservation (EHP) clearances are mandatory before you put shovels in the ground.
- States will assign risk levels to awardees, which will determine how deeply and frequently they monitor you.
- Record-keeping isn’t optional:
- BABA documentation,
- Serial numbers and installation traceability,
- Milestone certifications,
- Permitting records and correspondence.
The best way to de-risk this area is to assume from day one that your project will be audited and design your workflows, file structures, and internal responsibilities accordingly.
Awardees who treat the federal and state governments like investors—with transparent reporting, clean documentation, and strong internal controls—will be in a far better position if (and when) questions arise.
Where KGPCo Fits In
BEAD is a once-in-a-generation opportunity—but it’s also a once-in-a-generation execution challenge.
Between fixed amount subawards, BABA requirements, long and tightening lead times, a constrained workforce, and complex compliance obligations, success will favor those who decide early, plan ahead and surround themselves with experienced partners.
KGPCo is engaged in this work every day—supporting providers across the country with:
- BABA-compliant material strategies,
- Multi-vendor sourcing and risk diversification,
- Supply chain planning aligned to BEAD timelines, and
- Close collaboration with state broadband offices, OEMs, and network operators.
As Ashley Travers put it during the webinar, the message is simple:
“If you take one thing away, let it be this—don’t wait. The decisions you make now will determine whether you can deliver on your BEAD commitments later.”
If you’d like to talk about how KGPCo can help you de-risk your BEAD projects—from planning through procurement and deployment—contact your representative today and let’s talk!
Ready to Move Forward?
[email protected] | www.kgpco.com | +1 (800) 328-5142
Let’s build the future of connectivity—together.
