Alongside the third round of the Tribal Broadband Connectivity Program (TBCP), the National Telecommunications and Information Administration (NTIA) opened a companion Notice of Funding Opportunity (NOFO) for the Native Entities Grant Program (NEGP)—the dedicated set-aside for Indian Tribes, Alaska Native entities, and Native Hawaiian organizations under the Digital Equity Act. NTIA has set aside at least $250 million for this round, and applications are due the same day as TBCP's: September 17, 2026.

Unlike TBCP, NEGP requires applicants to put up matching funds—at least 10 percent of the award, though NTIA will consider waiving some or all of that requirement for entities that can document financial need. For Tribes weighing whether to apply to TBCP, NEGP, or both, the matching fund requirement is one of the most consequential differences between the two programs, and it's easy to miss if you're reading quickly.

The Program, in Brief

The Digital Equity Act, part of the Infrastructure Investment and Jobs Act (Public Law 117-58), created two grant programs: the State Digital Equity Capacity Grant Program and the Digital Equity Competitive Grant Program. Both contain a Native Entity set-aside—by statute, NTIA must reserve at least 5 percent of the Capacity Grant Program's funds and exactly 5 percent of the Competitive Grant Program's funds for Native Entities. Rather than run two separate competitions, NTIA is releasing both set-asides through this single combined NOFO "to reduce administrative burden and cost."

NTIA frames this NOFO in the same terms as the TBCP NOFO released alongside it:

Who Can Apply, and for What

Eligible applicants are an Indian Tribe,¹ an Alaska Native entity, or a Native Hawaiian organization, individually or as a Consortium—a partnership between Eligible Entities. NTIA will treat an entity as meeting these definitions if it appears on one of several federal lists—the Bureau of Indian Affairs' list of federally recognized tribes, Alaska's Index of Regional Native Corporations, or the Department of the Interior's Native Hawaiian Organization and Homestead & Beneficiary Associations lists—or if it otherwise satisfies the NOFO's definitions.

As with TBCP, each Eligible Entity may submit only one application, and NTIA warns that participating in more than one risks delaying or losing consideration for all of them. A Native Entity applying on its own behalf, as a Consortium's lead applicant, or as a Consortium member must submit a Tribal Government Resolution² or equivalent formal authorization from its governing body.

Applicants should also know what they're certifying to: among the required certifications is one stating that "all beneficiaries of the proposed activities and interventions are members of a Native Entity." That's a narrower beneficiary population than TBCP's framing, which speaks more broadly about people living on Tribal Lands—worth keeping in mind for any project that might otherwise serve a mixed population on or near Tribal Lands.

How Much Money Is Available, and Where It's Going

NTIA expects to make individual awards between $500,000 and $2,500,000, describing this as a target rather than a hard cap. Applicants seeking amounts outside that range must justify the variance. Consortium applications don't need additional justification so long as no member's share exceeds $2,500,000. Any set-aside funds not awarded in this round will roll into a future NEGP NOFO rather than reverting to the broader Digital Equity Act pool.

What Applicants Must Show

The application largely tracks TBCP's: an SF-424 application, a Project Information Form, a Funded and Unfunded Entity Form, and a Tribal Government Resolution. The Project Narrative requires a 1,000-word Executive Summary, a Status as an Eligible Entity statement, a Demonstrated Need section grounded in data—including, notably, the percentage of households in the service area at or below 150 percent of the federal poverty line—and a Funded Activities description tied to measurable outcomes in areas like workforce development, education, health, or "Delivery of Other Essential Services." [NTIA notes it may use all or part of an applicant's Executive Summary in its own press releases.]

Two requirements here are more specific than their TBCP counterparts: 

• Applicants proposing workforce-development activities must tie their plans to demonstrated employer demand and describe how hiring will align with applicable Tribal Employment Rights Office (TERO) ordinances—Tribal laws giving Tribes authority over employment practices on their lands—using the Telecommunications Industry Registered Apprenticeship Program as a model.
• Where an applicant has obtained Tribal consent for BEAD deployment, it must submit "a BEAD Tribal Resolution" as a standalone supporting document, not simply describe its BEAD coordination in narrative form.

As with TBCP, applicants must disclose all other federal, state, or outside funding sought or received, explicitly including BEAD, the Capital Projects Fund, and TBCP itself, and certify against duplicative funding.

What the Money Can—and Can't—Be Used For

NEGP eligible activities include:

• developing and implementing broadband use and adoption programs;
• facilitating educational and employment opportunities through broadband;
• workforce training;
• providing low- or no-cost equipment and broadband subsidies; and
• constructing, upgrading, or operating public access computing centers through community anchor institutions.³

Administrative costs are capped at 10 percent of the award, and a separate evaluation-and-measurement cost is capped at another 10 percent (a considerably more generous overhead allowance than TBCP's flat 2 percent administrative cap). As with TBCP, applicants without a Negotiated Indirect Cost Rate Agreement⁴ (NICRA) may instead elect a 15 percent de minimis indirect cost rate.

The device distribution, remote learning, and broadband subsidy restrictions are essentially identical to TBCP's: no markup on devices; recipients must be U.S. citizens 18 or older who complete a "Learn to Earn" training program; no smartphones; generally one device per household; remote learning programs for people under 18 are "discouraged" and face additional scrutiny; and subsidized service must reach at least 100 Mbps download/20 Mbps upload, go directly to the provider rather than the household, and not duplicate the Federal Communications Commission's Lifeline program.

NEGP's subsidy provisions add a detail that TBCP's parallel section states less explicitly: subsidy eligibility is "limited to income-qualified households verified through federal means-tested programs or other approved income verification methods." This income-qualification standard is distinct from the area-level poverty statistic applicants report in their Demonstrated Need section—the percentage of households in the service area at or below 150 percent of the federal poverty line. One is a per-household eligibility gate for receiving a subsidy; the other is a service-area planning statistic used to justify the project in the first place. The NOFO doesn't ask applicants to reconcile the two, but  the application requires tracking poverty status against more than one undefined standard at once.

NEGP also has two restrictions without a direct TBCP counterpart: 

• The "Prohibition on Supplanting" bars using NEGP funds to substitute for committed BEAD or TBCP funding and
• The "Prohibition on General Research" limits funded projects to serving Native Entities, explicitly excluding "general research projects or academic studies"—paired with a separate Human Subjects Research compliance requirement for any recipient activity that does involve research on people.

How NTIA Will Decide Who Gets Funded

NEGP application reviews proceed through the same three stages as TBCP—Initial Eligibility and Administrative Review, Merit Review, and Programmatic Review—but with one fewer prioritization tranche. Where TBCP sorts applications into three tiers, NEGP uses two: applications tied to a Tribal Resolution approving BEAD deployment go first, and "all other projects" go second.

NEGP's NOFO doesn't single out community anchor institution connections for separate, lower-priority treatment the way TBCP's does. But the narrower issue from TBCP doesn't disappear here—it just shows up differently. NEGP's only infrastructure-adjacent eligible use is constructing, upgrading, or operating public access computing centers through community anchor institutions. Since NTIA has said it will interpret "community support organization"—one of the categories within the CAI definition—narrowly, consistent with BEAD, that narrow definition doesn't just affect priority ranking the way it does in TBCP. Here, it determines which facilities are eligible to host a computing center at all. A facility that wouldn't count as a qualifying CAI under that narrow reading isn't deprioritized—it's simply ineligible.

Merit Review scoring again runs 0–100, with 65 needed to be "Qualified for Funding." The four scoring categories are Project Purpose and Need (35 points), Performance Measures and Sustainability (15 points), Strength of Project Implementation Plan and Budget (25 points), and Strength of Applicant's Organizational Capability (25 points).

Programmatic Review includes de-duplication against other federal programs, explicitly including TBCP's third NOFO. If an application qualifies for funding under both, NTIA will decide which to fund "based on the availability of funding." Among the discretionary factors the Office of Internet Connectivity and Growth (OICG) Associate Administrator may weigh at the next stage is "[w]hether the applicant has received or is set to receive other federal funding for broadband, excluding an award from the Tribal Broadband Connectivity Program"—meaning a Tribe's TBCP award specifically won't count against it in NEGP's competitive consideration, even though other federal broadband funding might.

Compliance and Accountability After Award

Most compliance provisions mirror TBCP's: the Uniform Administrative Requirements (2 C.F.R. Part 200), Build America, Buy America domestic-content rules for any NEGP-funded "infrastructure project," NIST Cybersecurity Framework and CISA Cybersecurity Performance Goals alignment, and the Executive Order 14173 ("Ending Illegal Discrimination and Restoring Merit-Based Opportunity") requirement that they do not operate diversity, equity, and inclusion programs that violate federal anti-discrimination law.

Nothing in this NOFO's compliance section mentions the Davis-Bacon Act, in either direction. TBCP's NOFO explicitly states Davis-Bacon doesn't apply and that Tribes may use their own Force Account wage rates⁵ instead. The NEGP NOFO is silent on the question entirely—even though NEGP can fund "infrastructure projects" (public access computing center construction) that would seem to raise the same wage-rate question TBCP addresses head-on. 

NEGP also adds a reporting and integrity requirement without a TBCP counterpart: applicants and recipients must comply with Department of Commerce human-subjects-research regulations for any research activity, separate from the broader "Prohibition on General Research" discussed above. This isn't as far afield as it might sound at first: NEGP's own reporting requirements direct recipients to collect baseline data and follow up with participant surveys over multiple years to measure program outcomes—activities that can themselves qualify as "research involving human subjects" under federal regulation, triggering protections like informed consent and data-privacy safeguards regardless of how informal the survey work feels in practice. Applicants planning anything beyond basic usage tracking should build this into their evaluation design from the start, not treat it as a late-stage compliance afterthought.

What Stands Out

Several of the items below represent real new constraints or notable design choices in how Native Entities can use this funding. NTIA frames these, as it does in the TBCP NOFO, as part of a single rationale: avoiding duplication with other federal broadband investment and stretching available dollars as far as possible. Set against this, keep in mind that a Tribe's TBCP award doesn't count against it in NEGP's competitive review—the two programs are explicitly designed to be used together rather than to compete with each other for the same applicant.

The two Tribal NOFOs are built to dovetail, not duplicate.

Several mechanisms in this NOFO point toward genuine coordination with TBCP rather than the two programs simply happening to share a deadline. A Tribe's TBCP award is explicitly excluded from "other federal funding for broadband" in NEGP's discretionary selection factors. Programmatic Review cross-checks NEGP applications against TBCP's third NOFO specifically, and where the two qualify for the same activity, NTIA resolves it based on available funding rather than rejecting either application outright. And NEGP funds are barred from supplanting committed TBCP or BEAD funding, suggesting NTIA expects Tribes to draw on more than one program for a single broader effort, not pick one and avoid the others. Taken together, these provisions point to a Tribe with both an infrastructure need and a use-and-adoption need, able to pursue both programs within the same overall initiative, rather than having to choose.

A 10 percent match requirement set by statute, not by this NOFO.

Unlike TBCP, which requires no cost share, NEGP requires Eligible Entities to contribute at least 10 percent in matching funds, cash or in-kind. This isn't a discretionary choice NTIA made in drafting this NOFO—federal law (see 47 U.S.C. §1724(e)(1)) caps the federal share of a Digital Equity Competitive Grant Program award at 90 percent. TBCP's no-match rule comes from a different statute altogether (the Infrastructure Investment and Jobs Act's TBCP provisions), which simply doesn't impose one. The practical effect on applicants is the same either way—a real barrier for Tribes and Native organizations without ready access to non-federal cash or in-kind contributions, partially offset by the financial-need waiver—but the source of the difference is Congress, not NTIA.

Eligible beneficiaries are limited to Native Entity members.

The required certification that "all beneficiaries...are members of a Native Entity" sets a narrower population than TBCP's framing around people living on Tribal Lands generally. A digital-skills or device program at a community anchor institution that also serves non-member households or staff on or near Tribal Lands may need to account for this distinction in its design and reporting.

The same minors-related restrictions as TBCP, now appearing in a second concurrent NOFO.

NEGP discourages remote-learning programs for people under 18 and bars device distribution to anyone under 18, in language nearly identical to TBCP's. Seeing the same restriction surface, unexplained, in two companion NOFOs released the same week strengthens the case that this reflects a deliberate, cross-program policy choice rather than an isolated drafting decision in either document—though neither NOFO states what that policy rationale is.

A larger administrative and evaluation cost allowance than TBCP — also set by statute.

NEGP permits up to 10 percent for administrative costs and a separate 10 percent for evaluation, both fixed in law (47 U.S.C. §1724(d)(2)(B)) and its companion provision on administrative costs. TBCP's 2 percent administration cap comes from its own separate authorizing statute. As with the match requirement, this is a difference between what Congress wrote into two different programs, not a choice NTIA made when designing either NOFO. Applicants weighing whether a given project fits better under TBCP or NEGP should still factor in how much overhead capacity each program allows.

Davis-Bacon's applicability to NEGP-funded construction is simply unaddressed.

As noted above, the NEGP NOFO funds a narrower category of construction (public access computing centers) than TBCP, but doesn't say one way or the other whether prevailing-wage requirements apply to it.

No stated rationale for the Lifeline anti-duplication rule.

Both the NEGP and TBCP NOFOs bar subsidy programs from duplicating FCC Lifeline service—but neither document explains why, beyond the single sentence stating the rule itself. The logic may follow the broader anti-duplication theme running through both NOFOs: preventing a household from receiving two federal subsidies for the same service. But that's an inference from context, not something NTIA states about Lifeline specifically, and it leaves open practical questions the NOFO doesn't answer—for instance, whether a household already on Lifeline is excluded from an NEGP-subsidized plan entirely, or only from subsidy for the same service tier Lifeline already covers. 

Subsidy eligibility ambiguity

Neither NOFO defines what counts as a "federal means-tested program" nor specifies which "other approved" methods NTIA will accept, leaving applicants to either guess or seek individual sign-off. That ambiguity carries more weight on Tribal Lands than it might elsewhere: American Indian and Alaska Native households had a median income of roughly $46,000 in 2020, compared with about $65,000 nationally, and a poverty rate of 24.1 percent against a national rate of 12.8 percent. Those figures describe the American Indian and Alaska Native population broadly, not Tribal Lands specifically — most AI/AN people live outside tribal statistical areas—but they show a meaningfully higher share of households likely to qualify under any income-based standard than the national rate would suggest. The practical risk isn't that too few households qualify; it's that an Eligible Entity won't know, until well into designing its program, exactly which documentation NTIA will accept as proof.

Finally, the subsidy provisions reveal something about funding mechanics: "[s]ubsidies are reimbursed annually upon documentation confirming compliance with program requirements, including qualifying service speeds"—meaning an Eligible Entity appears to front subsidy costs and recover them from NTIA after the fact, rather than receiving subsidy funds up front. For an Eligible Entity operating in a lower-income service area with limited cash reserves, that reimbursement lag could be a design constraint.

Timeline

Completed NEGP applications are due by 11:59 p.m. ET on September 17, 2026—the same deadline as the third TBCP NOFO. NTIA expects to complete review, select successful applicants, and begin award processing by Spring 2027, with awards announced on a rolling basis.

Recipients must expend their grant funds within four years of the award date, and may continue measuring and evaluating funded activities for an additional year after that period ends. Evaluation reports are due no later than 15 months after the award date and annually thereafter.

Notes

1. Note: the NOFO's definition of "Indian Tribe" describes it as covering "any Indian tribe, band, nation, or other organized group or community (i.e., Tribal Organizations)"—using "Tribal Organizations" as a loose, parenthetical stand-in for Indian Tribes generally. But the same Definitions section separately defines "Tribal Organization" as something much more specific: a Tribe's recognized governing body, or a sanctioned or chartered organization controlled by or democratically elected from that Tribe's community. Those are two different things, used interchangeably in one place and distinctly in another, within the same document.
2. A Tribal Government Resolution is a formal authorization from the governing body of the Eligible Entity (or, for a Consortium, from each participating Eligible Entity) certifying express authority for the entity—or the lead applicant, in the case of a Consortium—to file a TBCP application on its behalf. NTIA will also accept "equivalent formal authorization" in place of a resolution where a Tribal Government's own governance procedures don't produce a resolution as such.
3. Community anchor institution as defined in this NOFO: a public school, public or multi-family housing authority, library, medical or healthcare provider, community college or other higher-education institution, State or Territory library agency, or other nonprofit or governmental "community support organization," which NTIA says it will interpret narrowly, consistent with BEAD.
4. A Negotiated Indirect Cost Rate Agreement (NICRA) is a formal agreement with a federal agency that establishes the allowable percentage used to recover overhead costs (like facilities, human resources, and administration) on federal grants.
5. Tribal Force Account Wage Rates refer to the compensation paid to a tribe's own direct employees ("force account labor") for construction or maintenance projects, rather than using outside contractors. Many tribes set their own rates under tribal law to bypass standard federal Davis-Bacon or HUD-determined prevailing wages.

The Benton Institute for Broadband & Society is a non-profit organization dedicated to ensuring that all people in the U.S. have access to competitive, High-Performance Broadband regardless of where they live or who they are. We believe communication policy - rooted in the values of access, equity, and diversity - has the power to deliver new opportunities and strengthen communities.

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