NTIA Limits Community Anchor Institution BEAD Eligibility

What is a community anchor institution?

The National Telecommunications and Information Administration (NTIA) recently changed its answer to this question. The change will affect which locations nationwide are eligible for a new or upgraded gigabit speed (1000 Mbps upload and download) internet connection through the Broadband Equity, Access, and Deployment (BEAD) Program. 

NTIA’s June 6 BEAD Restructuring Policy Notice included a direction to states to revise lists of community anchor institutions (CAIs) to follow a “narrow interpretation” of the term Community Support Organization (CSO).  The Infrastructure Investment and Jobs Act defines a community anchor institution as:

The original BEAD Program Notice of Funding Opportunity (NOFO) had allowed states some flexibility, extending to them the option to propose additional types of institutions to be treated as CAIs, following the language about CSOs. At least 45 states had proposed additional types of CAIs, either by delineating criteria, naming an organization type (e.g., senior center, job training center), or doing both in their BEAD Initial Proposal Volume 1 documents approved by NTIA. 

On July 15, an FAQ document issued by NTIA redefined “community support organization”: 

“[F]or BEAD purposes, a community support organization (CSO) is “located in a government-owned facility that provides publicly accessible Internet service and currently offers digital skills training.” 

Previously, many states defined CSOs to include organizations—such as daycare centers, senior centers, and job training sites—that are not explicitly listed in the Infrastructure Investment and Jobs Act’s CAI definition but are nevertheless ideal sites for community connectivity. By doing so, states ensured these organizations could receive gigabit-tier service with BEAD support. However, NTIA imposed three new conditions:

1. location in a government-owned facility, 
2. that provides public internet access, and 
3. currently offers digital skills training. 

Effectively, this redefinition means that BEAD funds will not help establish any new sites that support digital access and opportunity unless they fall squarely within the types of entities named in the statutory definition (e.g., schools, libraries, health clinics, and so on). BEAD funds may enhance connectivity at government-owned sites that already offer internet access and training, but the opportunity to spur digital inclusion at new sites is all but negated by the re-definition. 

As state broadband offices prepare their new Final Proposals (due September 4, 2025), they now have the task of reviewing eligible CAI lists and verifying that conditions are met for any locations they include as CSOs. Verification that CSOs are located in a government-owned building and that they are currently sites for public access to the internet and skills training may be laborious, depending on the number of CSOs and types of information previously gathered about them. Arizona’s 1403 CSOs will surely require more effort to verify than Arkansas’ 18.

The re-definition may also create new questions for states: If a government organization leases a space, does that exclude it as an eligible CAI? What constitutes publicly accessible Internet service – the existence of a network that is explicitly provisioned for the public, that network is advertised to the public at the facility, or something else? Similar questions arise for currently offering digital skills training – must training be offered continuously and available year-round, on-demand to any member of the public, or something else? 

What Kinds of CAIs were Added Under the Original Guidance?

My review of BEAD Initial Proposal Volume 1 documents indicated that 45 states added more types of locations to their CAI lists to those types of entities explicitly named in the definition. 

Some of those most commonly added locations that are subject to the CSO redefinition are:

• Senior centers (at least 36 states)
• Job training centers (at least 33 states) 
• Social safety net-related organizations, such as food banks and pantries, shelters, community action agencies, and government offices that assist people in signing up for benefits and services (at least 21 states)
• Corrections facilities, including juvenile detention centers (at least 17 states, though a handful of these classified corrections facilities in the “public safety entity” category)
• Government buildings, such as courthouses and town halls (at least 17 states)
• Youth development organizations, including daycares and childcare centers, Head Start programs, and Boys and Girls Clubs (at least 14 states, though some additional states added such facilities in the “schools” category)

Some states revised their eligible CAI lists for Benefit of the Bargain rounds, though they did so to varying extents. Illinois, for example, dropped 945 CAIs from its list, primarily, parks and childcare centers. Alabama removed 25 CAIs, mostly government buildings. And Arizona opted to simply reclassify all CAIs that were categorized as government buildings or non-profit organizations as CSOs. Virginia demonstrated an unusual response to the new instructions for CAIs, indicating to applicants in its Benefit of the Bargain round policy notice that “inclusion [of CAIs] into an applicant’s application shall be completely optional.”

What Kinds of CAIs Will Be Removed Under the July 15 Re-definition?

NTIA’s new, limiting definition of a CSO will reduce the number of organizations eligible for BEAD’s high-speed broadband. Though the conditions must be considered in combination, an analysis of any one condition can give us an idea of the scope of what will be lost because of the re-definition of CSO.

• The condition that CSOs must operate in a government-owned location eliminates a large number of potential CAIs from states’ lists and introduces a burden on state broadband offices to verify building ownership. Senior centers, job training centers, youth development organizations, and even government agencies may not operate within government-owned buildings (note that governments at every level lease space in buildings not owned by the government).  
  • A significant number of social safety net-related organizations—such as those serving people with disabilities, the food insecure, the houseless, people re-entering society after incarceration, and other vulnerable populations—assist the public in important online tasks related to government, like enrolling in government benefits and accessing government services. Government agencies located in government-owned buildings are far from the only organizations that provide this crucial service, which is mentioned as justification for connecting CAIs in many BEAD proposals.
• The condition that CSOs must currently offer public access to the internet eliminates potential CAIs that currently have a connection but do not have adequate bandwidth to make public access to the internet possible or desirable. Such locations are also unlikely to meet the condition for offering current digital skills training, since entirely offline digital skills training is uncommon. 
  • This condition precludes establishing new sites where the public can access internet service. 
  • This condition likely rules out many corrections facilities, which have complex requirements when it comes to internet networks and the service that can be offered securely to incarcerated persons and the public on-site. 
• The condition that CSOs must currently offer digital skills training eliminates potential CAIs that do not currently have adequate bandwidth to facilitate digital skills training. It also eliminates the possibility of utilizing BEAD support to establish new training sites that would be catalyzed by an investment in connectivity, such as in correctional facilities and government buildings in rural and sparsely populated areas.
  • As many states note in initial proposals, town halls and courthouses may be some of the only places offering public internet access in rural communities. In communities that lack schools and libraries, government buildings that are open to the public are potential sites for public access; brief, periodic training (e.g., workshops) on digital skills related to government services; and hosting other community organizations to offer more intensive training.
  • Periodic and seasonal skills training offerings create ambiguity related to this condition. Museums and cultural sites, summer camps, and parks are among the locations that states identified as potential hosts for digital skills training that may not be offered continuously year-round. 

What’s Next for States and CAIs?

NTIA has directed states to submit their revised CAI lists in their new Final Proposal documents, but to only include those CAIs that will be served through states’ provisional selection of BEAD subawards. In other words, CAIs may disappear from lists because they are no longer eligible under the re-definition or because there were no bidders for the associated project area. So advocates and researchers could have great difficulty determining just how many CAIs ultimately lost access to BEAD support for better broadband access. 

Today, the Schools Health & Libraries Broadband Coalition and the Benton Institute for Broadband & Society are calling on NTIA to defer to states’ designations of CAIs. The states’ lists were developed in consultation with local stakeholders and more accurately reflect what communities consider to be “anchor” institutions. Changes to the BEAD Program that effectively reduce the number of locations designated for high-speed broadband would bypass sites that states have deemed important for getting communities online.

Dr. Caroline Stratton is the Research Director for the Benton Institute for Broadband & Society.