Written by Carla Juarez, Manager of Communications and Marketing at IEM
& Tammy Breski, Broadband Infrastructure Manager at IEM
Compliance – that one word often strikes fear into anyone who hears it. We roll our eyes and think about the time-consuming minutia involved when all we want to do is get our program working and our funding out the door. Why do we dread this word and its associated tasks?
Everyone’s experience with compliance is different. Maybe a project you were working on took twice as long to complete because of a requirement that you felt was unnecessary, or you felt like the governing agency was “picking” on your project or that they didn’t trust you and your agency to do the job and do it right.
The Benefits Outweigh the Burden
The past four years working at a state agency’s broadband office gave me a new appreciation for compliance and what it really means.
Starting off with a definition of compliance from Merriam-Webster – “Conformity in fulfilling official requirements,” it’s rather benign, right? While this is a simple description, many often find compliance, especially with the federal government’s regulation – 2 CFR § 200 – an unpleasant idea. My desire is to help push you past the laborious tasks involved in meeting compliance while providing guidance and tools to help state broadband offices remain good stewards of allocated funds and to ensure the accountability of our taxpayers’ dollars.
Increasing Access to High-Speed Internet Together – State & Grantee Collaboration
An early and important lesson learned while working for the Virginia broadband program was our motto – “We are not a gotcha agency.” Essentially, we weren’t trying to find ways to take back the money from our grantees. Instead, we were partners in this endeavor and committed to serving our constituents and helping connect them to high-speed internet access through effective collaboration with grantees.
A perfect example of a state best practice established with the grantee in mind is when we developed forms for state funded projects to closely mirror those for federally funded programs. Because our team was familiar with this easy-to-use template it offered our grantees a less cumbersome process that ensured a smooth transition when navigating from state- to federally-funded programs and their respective compliance requirements.
Collaboration between the state and the grantees is essential to a successful partnership and project delivery. Working together, states and grantees are helping to ensure disadvantaged and unconnected communities are accessing funding to even the playing field. In addition –grantees – take advantage of your state counterparts, they are a great resource and ally to have throughout your project timeline.
Prioritize & Invest Time in Compliance Training
It is important to regularly stay “in the know” of new compliance measures and take advantage of resources available through agencies like the U.S. Department of Housing and Urban Development (HUD) and the U.S. Department of the Treasury (Treasury), who offer online, no cost trainings and toolkits.
While at Virginia, our team members completed HUD compliant environmental training. Since, we had federally-funded broadband projects, we needed this to certify our environmental response. Thanks to the great foresight of the Broadband Director, with these free trainings, we were able to aid our grantees who were awarded Capital Project Funds (CPF) that had a requirement for an Environmental Assessment.
Some trainings I would encourage any grantee or state office complete are listed below:
- Environmental Review Training – HUD Exchange
- Financial Management 201: 2 CFR Part 200 Online Module – HUD Exchange
Documentation is Key in Compliance
Prior to my departure, I had the opportunity to work with the Virginia Broadband Program Analyst on the compliance for American Rescue Plan Act (ARPA) Funds and CPF. A quarterly report was due as part of the federal compliance process. In Virginia, the internal grants management system allowed a user to create and assign templates for specific projects. Together, we created a federal compliance template and developed guidance on how to use information already supplied to the state by grantees on other various reports to complete it. Finding ways to streamline reporting goes a long way as documentation is a crucial piece of compliance.
Similarly, anticipating what may be requested at audit will significantly help you in the long run to avoid last-minute scrambling to find the information when requested. While at Virginia, our team aimed to “get ahead” of the ask. For example, we knew for certain auditors would inquire about our procurement process. With this “ask” in mind, we initiated conversations with our grantees early to make sure we documented and captured information and relevant policies early in the process to ensure it was ready upon request.
A Partner in Broadband
Our team stands ready to be your partner in broadband implementation. The IEM team provides direct support and/or guidance for your broadband compliance needs. By investing the necessary time and resources to adhere to federal and state compliance requirements, we will ensure your projects success and improve opportunities for future funding.
Want to learn more? Let’s connect and discuss your broadband needs today.