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BEAD and E-ACAM Risk Management Compliance

Meet Your BEAD and E-ACAM Cybersecurity and Risk Management Compliance Requirements

We work with telecommunications companies and co-ops nationwide to safeguard CPNI and ensure adherence to the grant requirements in BEAD and E-ACAM. Our information risk and cybersecurity services align your internal processes and leadership's expectations to get you ready for future FCC regulatory mandates.

BEAD and E-ACAM Requirements

The Broadband Equity, Access, and Deployment (BEAD) and Enhanced Alternative Connect America Cost Model (E-ACAM) programs are two major federal initiatives aimed at expanding high-speed internet access across the United States. Funded through the Infrastructure Investment and Jobs Ace (IIJA) and administered by the NTIA and FCC respectively, these programs allocate billions of dollars to support broadband infrastructure in underserved and rural areas. As part of this investment, both programs include strict cybersecurity and compliance requirements to ensure that taxpayer-funded networks are secure, resilient, and aligned with national standards.

Entities that must comply with BEAD and E-ACAM requirements include state broadband offices (for BEAD) and telecommunications carriers (for E-ACAM) that receive federal funding to deploy or maintain broadband networks. These organizations are responsible for not only building infrastructure but also implementing robust cybersecurity and supply chain risk management practices. Compliance is mandatory for funding eligibility, and failure to meet requirements - such as submitting certified cybersecurity plans - can result in withheld payments or disqualification from the programs.

BEAD

The Broadband Equity, Access, and Deployment (BEAD) program is a federal initiative created under the Infrastructure Investment and Jobs Act (IIJA) to expand high-speed internet access across the United States. Administered by the National Telecommunications and Information Administration (NTIA), BEAD allocates over $42 to states and territories to fund broadband infrastructure projects in unserved and underserved communities. The program aims to close the digital divide by ensuring that every American has access to reliable, affordable internet service. Recent reforms to BEAD have emphasized a technology-neutral approach, reduced regulatory burdens, and prioritized cost-effective deployment strategies to maximize the impact of federal investment.

E-ACAM

The Enhanced Alternative Connect America Cost Model (E-ACAM) is a funding mechanism managed by the Universal Service Administrative Company (USAC) under the oversight of the Federal Communications Commission (FCC). It provides financial support to rate-of-return carriers that agree to meet specific broadband deployment obligations in rural and high-cost areas. E-ACAM offers a predictable funding model in exchange for commitments to expand and maintain broadband service to locations that might otherwise be economically unfeasible to serve. The program includes strict compliance requirements, including cybersecurity and supply chain risk management plans, to ensure that supported networks are secure, resilient, and aligned with federal standards.

Protecting Systems

While these programs do not directly protect personal data like HIPAA or CMMC frameworks, they do require recipients to safeguard critical infrastructure and operational data. This includes protecting network configurations, system access credentials, and any sensitive information related to broadband deployment. The emphasis is on securing the systems and supply chains that support broadband delivery, ensuring that networks funded by BEAD and E-ACAM are not vulnerable to cyber threats or foreign interference.

Network Equipment

What Are You Attesting To

A key compliance element for both the BEAD and E-ACAM programs is the attestation requirement, which ensures that recipients of federal broadband funding have robust cybersecurity and supply chain risk management (SCRM) plans in place. For BEAD, prospective subgrantees must formally attest that they have a cybersecurity risk management plan that is either operational or ready to be operationalized upon service delivery. This plan must be submitted to the state or territory administering the funds before any allocation is made and must be updated periodically or when significant changes occur. Similarly, under E-ACAM, telecommunications carriers must submit certified cybersecurity and SCRM plans to the Universal Service Administrative Company (USAC). If a carrier fails to submit or certify its plan by the required deadline, it faces a 25% reduction in monthly support payments until compliance is achieved.
 
The attestation is not a mere formality - it confirms that the organization's cybersecurity plan aligns with federal standards, specifically the NIST Cybersecurity Framework (CSF) and Executive Order 14028. The plan must detail the security and privacy controls being implemented, demonstrate readiness to protect critical infrastructure, and reflect a commitment to continuous improvement. It must also incorporate guidance from NIST SP 800-161 and NISTIR 8276 for managing supply chain risks. These attestations serve as a formal declaration of compliance and accountability, ensuring that only organizations with credible, standards-based cybersecurity strategies are entrusted with building and maintaining federally funded broadened networks.

NIST Cybersecurity Framework (CSF)

Both BEAD and E-ACAM require alignment with the NIST Cybersecurity Framework (CSF), a widely adopted set of guidelines for managing cybersecurity risk. The CSF provides a flexible structure based on five core functions - Identify, Protect, Detect, Respond, and Recover - and is designed to help organizations of all sizes improve their cybersecurity posture. E-ACAM recipients must specifically reference the latest version of the NIST CSF in their cybersecurity plans, ensuring that their practices reflect current best practices and federal expectations.

Other NIST Frameworks

In addition to the CSF, E-ACAM recipients must also incorporate guidance from NIST SO 800-161 and NISTIR 8276, which focus on supply chain risk management. These documents outline key practices for identifying and mitigating risks associated with third-party vendors, hardware, and software components. This requirement reflects growing concern over supply chain vulnerabilities and ensures that broadband networks are built with secure, vetted technologies.

Risk Assessments

Both BEAD and E-ACAM emphasize the importance of risk assessments as a foundational element of cybersecurity planning. Recipients must regularly evaluate their systems for vulnerabilities, assess the likelihood and impact of potential threats, and implement mitigation strategies accordingly. These assessments must be updated whenever there are significant changes to the organization's risk profile and are critical for maintaining compliance, securing infrastructure, and protecting the integrity of federally funded broadband projects.

 

How We Can Help You

 

Community

The BorderHawk Community, composed of security and compliance professional, offers strategic value to leadership and risk management teams. Within the community, leaders gain access to real-time insights on emerging threats, regulatory updates, and proven mitigation strategies - shared by BorderHawk experts and peers who face similar challenges.

This collective intelligence accelerates decision-making, enhances incident response readiness, and fosters a culture of continuous improvement. For compliance officers and CISOs, the ability to benchmark practices, validate interpretations of complex regulations, and source solutions to nuanced problems reduces isolation and increases confidence in their programs.

Ultimately, the BorderHawk community strengthens organizational resilience and ensures that security and compliance efforts are both proactive and aligned with industry best practices.

Community Engagement

Risk Assessment

 

Risk Assessment

Risk assessments are essential for any organization aiming to maintain strong security and compliance postures. They provide a structured approach to identifying vulnerabilities, evaluating potential threats, and understanding the impact of security incidents on sensitive information.

By regularly conducting risk assessments, organizations can prioritize resources effectively, implement targeted safeguards, and demonstrate due diligence in meeting their regulatory, contractual, and internal requirements. Risk assessments not only reduce the likelihood of data breaches and compliance violations, but also build trust with patients, partners, and regulators by showing a proactive commitment to protecting sensitive information.

In a rapidly evolving threat landscape, risk assessments are not just a regulatory checkbox - they are a strategic necessity.

Overwatch Compliance Framework

A detailed compliance framework is critical for organization to navigate the complex landscape of regulatory and contractual mandates. Such a framework provides a structured, repeatable approach to managing policies, processes, incident response, and security controls - ensuring that every aspect of compliance is addressed systematically. 

The rigor the Overwatch Framework brings helps eliminate gaps, reduce human error, and align internal practices with external expectations. Moreover, a well-documented framework enhances accountability, simplifies audits, and enables faster adaptation to regulatory changes.

The Overwatch Framework transforms compliance from a reactive obligation into a proactive, strategic asset that supports operational excellence and builds stakeholder trust.

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