Oversight and accountability
How Hawaiʻi watches the money after the award: what subgrantees report and when, how reimbursement is earned, what raises a subgrantee's risk tier, and what the state committed to. The commitments are public; performance against them is not yet.
Headline figures
Quarterly expenditure reports due after quarter end (days)
14
Receipt
“quarterly reports detailing deployment progress and expenditures for reimbursement will be due within two weeks (14 calendar days) of the previous quarter.”
Final Proposal Appendix, p.5Close-out report due after the project period (days)
60
Receipt
“A close out report due within 60 days of the end of the project period.”
Final Proposal Appendix, p.5Post-closeout report after close-out (months)
6
Receipt
“A post-closeout report due 6 months after the project closes out.”
Final Proposal Appendix, p.5Subgrant activities complete before the period ends (days)
120
Receipt
“UHBO will ensure that all subgrant activities by subgrantees are completed at least 120 days prior to the end of the period of performance”
Final Proposal, p.11Cure period before termination (calendar days)
7
Receipt
“The notice shall provide the subgrantee with an opportunity to cure its default or take satisfactory corrective action within the seven (7) days (or other longer time as specified by RCUH).”
Final Proposal Appendix, p.10Subgrantee records retained after the final expenditure report (years)
3
Receipt
“retaining subgrantee records for a period of at least 3 years from the date of submission of the subgrant’s final expenditure report”
Final Proposal, p.10Written report follow-ups
7 or 14 days
Receipt
“Written project reports are due at each status meeting, with follow-ups at 7 or 14 days, depending on the nature of the discrepancy or issue.”
Final Proposal Appendix, p.4Waste, fraud, and abuse hotline
Hawaiʻi State Ethics Commission, 808-587-0000
Receipt
“UHBO currently and will continue to publicize the Hawaiʻi State Ethics Commission’s public waste, fraud, and abuse hotline (808-587-0000)”
Final Proposal, p.11Monitoring cadence
Status reports
Weekly, after kickoff
Receipt
“subgrantees will be required to provide weekly reports to UHBO detailing project status and issues.”
Final Proposal Appendix, p.4Expenditure reports
Quarterly, due 14 days after quarter end
Receipt
“For expenditures, quarterly reports detailing deployment progress and expenditures for reimbursement will be due within two weeks (14 calendar days) of the previous quarter.”
Final Proposal Appendix, p.5Desk reviews
Quarterly
Receipt
“UHBO will conduct desk reviews of all BEAD deployment milestones each quarter”
Final Proposal Appendix, p.6Site visits
Periodic; twice a year at low risk
Receipt
“Site visits: Twice a year scheduled site visits, possible ad-hoc visits”
Final Proposal Appendix, p.7Close-out report
Within 60 days of the project period
Receipt
“This report should confirm that all contractual obligations were met.”
Final Proposal Appendix, p.5Post-closeout report
6 months after close-out
Receipt
“This report should provide subscriber counts, subscriber satisfaction rating, and any issues reported by subscribers, how they were resolved, and outstanding issues identified that may not be service-related for BEAD-funded areas.”
Final Proposal Appendix, p.5How monitoring works
- Purpose of monitoring“Hawaiʻi’s subgrantee monitoring program plan is designed to effectively meet BEAD program objectives by minimizing risk, limiting potential waste, fraud, and abuse of federal funds, ensuring projects are completed on time, while also not overburdening subgrantees.”Final Proposal Appendix, p.4
- Four components“1. Subgrantee reporting 2. Site visits 3. Desk reviews 4. Risk assessment”Final Proposal Appendix, p.4
- What site visits measure“To accurately measure download and upload speeds, along with latency (ping), at designated service locations.”Final Proposal Appendix, p.5
- Slow progress“In the event of slower project progression, additional site visits may be required to assess the project closely and make a determination on whether funds may need to be recouped, should a subgrantee fail to fulfill contractual obligations on their proposed timeline to service.”Final Proposal Appendix, p.6
- Risk assessed every reporting period“At each reporting period, UHBO will evaluate and assign a risk category for each subgrantee.”Final Proposal Appendix, p.6
- Final review at close-out“Upon project close-out, UH will conduct a final review of all reports and a financial review to ensure all contractual obligations were met and BEAD funding is compliant with the NOFO.”Final Proposal Appendix, p.6
Risk tiers
| Tier | Text | Source |
|---|---|---|
| Low risk: criteria (all four) | “1. Subgrantee submits timely reporting 2. Subgrantee is responsive to UHBO inquiries 3. Deployment progress is on track or only slightly delayed 4. Subgrantee is compliant with BEAD requirements” | Final Proposal Appendix, p.7 |
| Low risk: actions | “Reporting: Standard reporting frequency as described above ● Site visits: Twice a year scheduled site visits, possible ad-hoc visits ● Desk Reviews: Standard desk reviews and meeting frequency” | Final Proposal Appendix, p.7 |
| Medium risk: criteria (one, over two reporting periods) | “A subgrantee will be considered medium risk if it is shown that they meet one of the following criteria over two reporting periods:” | Final Proposal Appendix, p.7 |
| Medium risk: actions | “Site visits: Twice a year scheduled site visits, possible ad-hoc visits ● Desk Reviews: Increased desk reviews and meeting frequency” | Final Proposal Appendix, p.7 |
| High risk: criteria (more than one, over two reporting periods) | “A subgrantee will be considered high risk if it is shown that they meet more than one of the following criteria over two reporting periods:” | Final Proposal Appendix, p.7 |
| High risk: actions | “Site visits: Increased scheduled site visits, possible ad-hoc visits ● Desk Reviews: Increased desk reviews and meeting frequency ● Clawback or suspension of funding reimbursement” | Final Proposal Appendix, p.7 |
| Medium or high risk and funding | “As stated in the Hawaiʻi BEAD Subgrantee Monitoring Plan, subgrantees considered medium or high risk for compliance may have their funding withheld or clawed back depending on the severity of non-compliance, delays to the subgrantee’s proposal timeline, and/or progress towards fulfilling BEAD objectives.” | Final Proposal Appendix, p.10 |
Assigned at every reporting period; medium and high risk change the site-visit and desk-review frequency and can withhold or claw back funding.
How reimbursement is earned
- Who administers the grant“Under the designation of the Governor, the State of Hawaiʻi Department of Budget and Finance (B&F) will be responsible for administering the BEAD Grant.”Final Proposal Appendix, p.9
- The contract“This will be a cost reimbursement contract where the responsibility is placed on the contractor for completion of the services in accordance with the contract terms.”Final Proposal Appendix, p.9
- Milestone payments“The services agreement will specify the start and completion dates as well as a compensation schedule according to milestone targets that must be satisfactorily met for the subgrantee to receive payment(s).”Final Proposal Appendix, p.9
- Reports and invoices“Subgrantees will submit quarterly progress reports detailing performance milestones met and invoices with expenditure reports to the University of Hawaiʻi Broadband Office (UHBO).”Final Proposal Appendix, p.9
- Condition of payment“All payments under this agreement shall be made only upon (a) submission by the subgrantee to RCUH original invoices specifying the amount due and certifying that services requested under the Agreement have been performed by the subgrantee and (b) confirmation of satisfactorily performance as determined by RCUH.”Final Proposal Appendix, p.9
- Evidence of finished work“In order to secure project cost reimbursements, subgrantees must provide evidence that they have finished the required work.”Final Proposal Appendix, p.5
- Location-by-location status“UH should be able to ascertain through this report whether an individual location is in progress, completed, tested, or deployed but awaiting a customer to order service.”Final Proposal Appendix, p.5
- Withholding“Unfavorable review of the submitted reports may lead to withholding reimbursement of funding until the issues are resolved between the subgrantee and UHBO.”Final Proposal Appendix, p.10
- Grounds for withholding or clawback“Justification for such actions includes, but is not limited to, the subgrantee not submitting timely reporting, unresponsiveness to UHBO inquiries, deployment progress being severely delayed, or non-compliance with BEAD requirements.”Final Proposal Appendix, p.10
- Termination“RCUH shall have the right to terminate the agreement in whole or in part, by giving written notice at least seven (7) calendar days (or any longer time as specified by RCUH in writing) before the effective date of termination.”Final Proposal Appendix, p.10
- Notice of clawback“Any official notice of funding clawback will be from UHBO.”Final Proposal Appendix, p.10
What the state committed to
| Commitment | Text | Source |
|---|---|---|
| Service within four years of the subgrant | “Both fiber and low earth orbit satellite (LEO) subgrantees will be required to provide service to each customer that desires broadband service within the project area not later than four years after the date on which the subgrantee receives the subgrant.” | Final Proposal, p.11 |
| Fiber period of performance | “Fiber providers will be held to a period of performance that concludes four (4) years from the date upon which the subgrantee certifies to the State of Hawaiʻi that broadband is available to every location covered by the project area.” | Final Proposal, p.11 |
| LEO period of performance | “LEO subgrantees will be held to a period of performance that concludes ten (10) years from the date upon which the subgrantee certifies to the State of Hawaiʻi that broadband is available to every location covered by the project area.” | Final Proposal, p.11 |
| Reimbursable basis | “Distribution of funding to subgrantees for, at a minimum, all deployment projects on a reimbursable basis (which would allow the Eligible Entity to withhold funds if the subgrantee fails to take the actions the funds are meant to subsidize)” | Final Proposal, p.13 |
| At least semiannual subgrantee reporting | “including timely subgrantee reporting mandates, including at least semiannual reporting, for the duration of the subgrant to track the effectiveness of the use of funds provided” | Final Proposal, p.13 |
| Low-cost option for the 10-year federal interest period (certified) | “Certify that all subgrantees selected by the Eligible Entity will be required to offer the low-cost broadband service option for the duration of the 10-year Federal interest period.” | Final Proposal, p.21 |
| Reliability and resilience planned (certified) | “Certify that all subgrantees have planned for the reliability and resilience of BEAD-funded networks.” | Final Proposal, p.22 |
| Federal labor and employment law compliance (certified) | “Affirm that the Eligible Entity required subgrantees to certify compliance with existing federal labor and employment laws.” | Final Proposal, p.21 |
| Hotline in every newsletter | “UHBO will make the link and contact information for the fraud hotline a permanent feature at the bottom of all future newsletters, which will continue to be sent out on a regular basis as the subgrantee proceeds with deployment.” | Final Proposal, p.12 |
| Reporting templates and reminders | “UHBO will provide templates to subgrantees to ensure uniformity of reporting. UHBO will also remind subgrantees of the expenditure reporting deadline.” | Final Proposal Appendix, p.5 |
| Quarterly report: per-location fields | “The FCC fabric location ID, fabric version (e.g. Dec 2022, Jun 2023), and latitude/longitude of each location deployed to” | Initial Proposal Vol. 2, p.110 |
| Quarterly report: completion date per location | “The date deployment to the location was completed in MM/DD/YYYY format” | Initial Proposal Vol. 2, p.110 |
| Semi-annual site visits (Initial Proposal) | “Semi-annual project site visits: Site visits to project areas will occur twice a year, around six months apart” | Initial Proposal Vol. 2, p.110 |
| Nonpayment or termination for missed obligations | “Potential subgrantees should be aware that funds will be granted on a reimbursable basis, and are otherwise subject to nonpayment and/or termination in the event funds are awarded but the subgrantee fails to meet contractual obligations, including reporting requirements and availability for other routine subrecipient monitoring activities.” | Initial Proposal Vol. 2, p.111 |
| Monthly program status meetings | “Regular monthly meetings will include participation by B&F staff, University grant program staff, the Department of Business, Economic Development, and Tourism (DBEDT) staff, Department of Hawaiian Home Lands (DHHL) staff, and the Lieutenant Governor’s office staff.” | Initial Proposal Vol. 2, p.111 |
The receipted report
Every figure and quoted commitment on this site, with its source, in one printable document. Open the receipted report →
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