Native Entities Capacity Grant Program

This is the third in a three-part series about the State Digital Equity Capacity Grant Program announcement from the National Telecommunications and Information Administration (NTIA). Read the first blog post with an overview of the program and the second with information for states and territories. The State Digital Equity Capacity Grant Program is the second set of funds available in the Digital Equity Act (DEA) authorized by the Infrastructure Investment and Jobs Act (IIJA) of 2021.

The State Digital Equity Capacity Grant Program includes funds for Native entities to address barriers to digital equity in their communities. Funds may be used to create a digital equity plan, implement digital equity activities, and administer subgrants to eligible organizations that support the Native entity’s digital equity outcomes and goals. These funds cannot be used for broadband deployment projects.

Watch the video: Native Entities Capacity Grant Info Session with AMERIND Critical Infrastructure’s Digital Inclusion Manager, Davida Delmar, and NDIA’s Senior Policy Manager, Shauna Edson.

Things to Know

Applications open September 25, 2024, and are due February 7, 2025.
$45.3 million is available for Native entities.
The grants are competitive – meaning only some applicants who apply for one will receive it.
Grant awards will range from $500,000 to $2,000,000.
Native entities can use the funds for digital equity planning and implementation of the plans, or for implementing digital inclusion activities alone but will not be able to use the funds solely for planning.
Native entities can use these funds without involvement from states.
NTIA expects to begin awarding funds to Native entities in the Summer of 2025, likely on a rolling basis (pg. 62 of the NOFO).
Entities that receive funding must complete the grant activities within five years (pg. 42 of the NOFO).

Eligibility

For this grant, NTIA will define Native entities as Indian Tribes, Alaska Native entities, and Native Hawaiian organizations who appear on one of the below lists. The Native entity must be listed on the list before the closing of the application window to qualify as a Native entity for the grant (pg. 45 of the NOFO). If your Native entity is not on one of these lists, we recommend you contact NTIA directly by email at [email protected].

To demonstrate eligibility, the Native entity must receive a Tribal Government Resolution or equivalent formal authorization from the governing body explicitly permitting the entity to apply on behalf of the Native entity.

Consortia of Native entities (a group of Native entities applying together) are allowed and encouraged too. However, NTIA stresses Native entities may only apply once, either via a Consortia application or an individual application—not both. And applicants cannot be part of multiple applications or consortia.

Allowable Uses

The grant funds may be used to 1) create digital equity plans AND implement digital inclusion activities or 2) implement digital inclusion activities to address digital equity barriers in your community (without completing a digital equity plan first). Funds cannot be used for planning activities alone. For a full description of allowable uses see pgs. 52-53 of the NOFO.

Digital Equity Plans

Native entities can, but are not required, to use a portion of the capacity award—up to 7.25 percent—to create digital equity plans. While not mandatory, creating digital equity plans before launching an implementation project would help design a digital equity vision with and for your community, a digital equity needs assessment, identify assets, and identify barriers to digital equity.

The NOFO outlines the requirements for a Native entity’s digital equity plan, which are different from the requirements that were noted for states in the Planning Grant. Native entities can use these funds and create a digital equity plan without involvement from states. However, if the Native entity’s goals and strategies are aligned with those of the state, their digital inclusion activities may align with the state’s digital equity plan. The plans may include data about digital equity as it currently stands for their community, a description of assets and partners for digital inclusion efforts, and strategies for implementing digital inclusion activities.

Funds may not be used to create a digital equity plan alone, the planning must be coupled with the implementation of digital inclusion activities. Keep an eye out for NDIA’s upcoming Indigenous Digital Inclusion Planning Guide with more information on creating digital equity plans and implementation strategies. In the meantime check out NDIA’s State Digital Equity Planning Toolkit for some ideas, best practices and strategies.

Subgrants

The Capacity grant funds can be used to provide subgrants to eligible entities to support digital inclusion implementation activities. Non-profits, a local education agency, or an entity that carries out a workforce development program, are some of the entities that are eligible for a subgrant. *See the first blog post in this series for more information on entities eligible for subgrants.

Strategies and Activities

According to the NOFO, capacity grant funds are to be used to achieve digital equity through supporting digital inclusion and broadband adoption activities that benefit the *covered populations of the Native entity. NTIA does not tell Native entities how to implement their digital equity plans or implement digital inclusion activities, as NTIA expects them to propose various strategies to address digital equity barriers (pgs. 52-53 of the NOFO).

Strategies should include digital inclusion activities to address digital equity barriers in your community. Activities are how your digital equity goals are accomplished, and implementation is how you do the activities. Indigenous communities have been actively engaged in digital inclusion activities (such as programs, events, and projects) by helping folks find jobs online, supporting individuals in learning how to use devices, digital navigation or one-on-one computer help, telehealth, and more.

*The Digital Equity Act defines covered populations as (a) individuals who live in covered households (defined as households with income of not more than 150% of the poverty level); (b) aging individuals; (c) incarcerated individuals (as defined by the State or Territory), other than individuals who are incarcerated in a Federal correctional facility; (d) veterans; (e) individuals with disabilities; (f) individuals with a language barrier, including individuals who are English learners and have low levels of literacy; (g) individuals who are members of a racial or ethnic minority group; and (h) individuals who primarily reside in a rural area.

Key Elements to Consider When Developing Your Strategy

Focus on covered populations
Ensure long-lasting and meaningful change
Have measurable implementation strategies
Regularly engage with stakeholders impacted by the digital equity plan to improve the effectiveness of the plan
Example strategies include:
- Digital Literacy and Skills Training
- Device Distribution Programs
- Online Accessibility
- Access to Affordable Broadband Service

Digital Inclusion Implementation Activities

Activities to put your digital equity plan or strategy into action may include:

A digital inclusion program is a planned and executed series of activities that address the need for one or more of the following:
- Affordable and low-cost internet access
- Appropriate device access
- Digital skills instruction
- Technical support
- Digital inclusion programs can be located within organizations that may not explicitly have a digital inclusion mission or vision
Digital inclusion events are one-off or regularly occurring stand-alone actions that draw attention and provide immediate digital inclusion services, such as sign-ups for free or low-cost internet, device distribution, or a single training session.
Digital inclusion projects are smaller, more agile activities that fall between programs and events. These activities may be fast-paced, short-term initiatives that respond to an identified need or current event or they may be components of larger digital inclusion programs. During the initial season of the COVID-19 pandemic in 2020, we saw a flurry of digital inclusion projects created to address the work and learn-from-home digital divide.

Limits and Prohibited Uses of Capacity Grant Funds

The NOFO outlines a few activities that can only take up a portion of the award and others that are not allowed (pg. 53-56 of the NOFO).

Limits on Allowable Expenditures

20 percent to update or maintain the digital equity plan. This is separate from the 7.25 percent Native entities may use to create a digital equity plan. The 20 percent may be used to update the plan from lessons learned throughout the grant period and include measurement and evaluation activities.
5 percent for subgrant evaluation. This applies to subgrantee program evaluation only, not the full evaluation of the program.
3 percent for administrative costs (not including the costs for program evaluation and updating the digital equity plan). This consists of a combined total of direct and indirect administrative costs charged to the award.
10 percent for subsidies for affordable broadband programs (like the Affordable Connectivity Program). If a Native entity chooses to implement an affordable broadband program, they must meet the following requirements:
- Promotion of any existing low-cost services programs (FCC, federal, state, local) should take precedence.
- While a new affordable access program may be established, a Native entity must first use funds from existing programs, grants, and other resources. Funds from the Capacity Grant program must be used as a last resort.

Prohibited Activities

Previously awarded federal or state grant funds to create a digital equity plan or implement digital inclusion activities must be used before using funds from the Native Entity Capacity Grant program. If Native Entity Capacity Grant funds are used to build up (rather than replace) other federal or state-funded programs that implement the type of activities listed in this NOFO, the application must describe how the funds will not duplicate other funds. Native entities should ensure that TBCP-funded activities are separate from the funds for activities requested in this NOFO. *See Other Funding in the Application Details section below for more details on how to do this.
While the activities should align with TBCP, grant funds may not be used for TBCP or BEAD deployment expenses. If an activity or program is eligible and requires minimal installation of broadband infrastructure (such as installing fixed equipment on a building as part of a strategy to promote access to affordable broadband service), then it is subject to environmental and purchasing regulations found on page 54 of the NOFO.
Grant funds may not be used for website upgrades or other accessibility projects otherwise required by law. This would include IT Accessibility Laws and Policies in Section 508 of the Rehabilitation Act, which ensures access to information communication technologies for individuals with disabilities.
Profit, fee, or other incremental charges above the actual cost.

Measurement and Evaluation

The NOFO requires awardees to measure and evaluate progress made on the implementation activities and evaluate the effectiveness of meeting the digital equity plans’ measurable objectives. Collecting data can help show how implementation activities positively impact the everyday lives of Indigenous community members, lessons learned to improve digital equity work, and advocacy for sustainability.

Measurement and evaluation processes and procedures are up to the Native entity. Still, NTIA requires collecting data points to document and measure progress. These data points include documenting the number, attendance, and types of program activities, performance data that is measurable or countable data, and participant assessment and feedback that may include conversations, surveys, and stories of community members.

NTIA also requires measurable objectives. Measurable objectives are concrete outcomes, based on defined metrics, designed to achieve the goals of the digital equity plan by addressing digital equity barriers.

Once the grant is complete, Native entities will use the data to assess the effectiveness of meeting the objectives outlined in digital equity plans and implementation strategies. See pages 42-43 of the NOFO for a complete description of measurement and evaluation requirements.

Application Details

The NOFO outlines elements Native entities must include in their application. See pages 47-53 of the NOFO for a complete list of application requirements.

General Applicant Information

A Tribal Government Resolution or equivalent formal authorization from the governing body explicitly permitting the entity to apply on behalf of the Native entity (pg. 48 of the NOFO).
A qualifying Native entity may authorize a non-profit corporation to administer grant funds (pg. 50 of the NOFO).

Consortium Applications

A consortium application is when multiple eligible entities apply using one application for a collaborative program, with one entity serving as the lead entity for the program. When it makes sense for entities to work together, NTIA encourages entities to coordinate and collaborate to work toward digital equity with a consortium application (pg. 46 of the NOFO).
Only the lead entity should apply for the whole consortium.

If applying as a consortium, the lead applicant must submit a Memorandum of Understanding (“MOU”) with each participating Native Entity and clearly state each member’s responsibilities. All entities in the consortium application must include a Tribal Government Resolution or equivalent formal permission from the authorized governing body of the Native entity to apply for funds (pgs. 46, 48 of the NOFO).

Native entities may only be part of one consortium application (pg. 46 of the NOFO).
Entities included in a consortium application cannot also submit an individual application (pg. 46 of the NOFO).

Multiple applications will significantly delay the application process. If an entity submits multiple applications, NTIA may remove any entity for consideration for their individual and consortium applications (pg. 46 of the NOFO).
This only applies to a Native entity applying directly to the Capacity Grant Program and does not include the Competitive Grant or state subgrants.

Project Narrative

An executive summary of the proposed projects. Include a statement on whether funds to create a digital equity plan are requested (pg. 48 of the NOFO).

Data that demonstrates the needs and barriers faced by the Native entity’s covered populations

This includes the poverty rate of the Native entity, the covered populations that will be served and how many individuals from each covered population will be served, the number of individuals that lack access to devices that enable access to the internet, the number of individuals that are not using the internet or do not have a subscription, and any other data that demonstrates a need for digital equity support (pg. 48 of the NOFO).

Digital Equity Plan

Native entities requesting funds for a digital equity plan should include a description of the plan in their application. The description should include planning activities, the outputs of those activities, a timeline, and a plan to share the plan with their community and the broader public. Other elements of the plan should include (pg. 49 of the NOFO):
- A vision statement
- Outreach and engagement with the community members to identify barriers and a needs assessment
- Identify barriers to digital equity in the community
- Measurable objectives that address the barriers identified
- Implementation strategies to achieve the measurable objectives

*Keep an eye out for NDIA’s upcoming Indigenous Digital Inclusion Planning Guide with more information on creating digital equity plans and implementation strategies.

Description of the implementation activities to be funded by the grant and a project plan.

Applications must include the total amount requested and account for all activities that will use funding from the grant (pg. 50 of the NOFO).

Anticipated long-term impact, and a plan for sustainability

Sustainability includes collaborating with key stakeholders and members of the community as well as measuring the long-term impacts and benefits of digital equity within the Native entity (pg. 50 of the NOFO).

Subgrants

A description of the subgrants you will fund with this grant or the process you will follow for awarding subgrants (pg. 50 of the NOFO).

Other Funding Sources

Native entities may apply for and receive funds from multiple federal or state grant programs, such as a subgrant from a state or NTIA’s forthcoming Digital Equity Competitive Grant, in addition to this Capacity Grant Program. These are different funding opportunities, and Native entities may apply separately for each. In these instances, Native entities must mention in their applications how the funds will be utilized for each of these programs. This demonstrates collaboration and coordination between agencies and ensures that the funds are used as efficiently and effectively as possible. A state’s digital equity plan may include programs and activities on Tribal lands, and care should be taken so efforts are not duplicated. NTIA will want to make sure they are not funding the same work twice. The clarification should include:

Description of all other funding sources for digital inclusion and digital equity activities including, but not limited to, the applicant status/role in the TBCP, subgrants from states, and private philanthropic organizations.
Amount that will be allocated from each funding source.
Specific elements in their digital equity plan you will fund using alternative sources.
Explanation of how the capacity grant funds will not duplicate other funding (pg. 50 of the NOFO).

Consolidated Budget Form

A detailed budget spreadsheet and a budget narrative that outlines the necessity and basis for all costs (pg. 51 of the NOFO).

Standard federal financial assistance forms and documentation (pg. 51 of the NOFO).

Award Amounts and Process

NTIA expects to award Native entities between $500,000 to $2,000,000. This funding range is not a required minimum or maximum, but Native entities requesting funding for projects outside this range must explain the request (pg. 50 of the NOFO).

Grant Award Process

NTIA received a significant number of Letters of Intent (LOI) from Native entities in response to the State Digital Equity Planning Grant NOFO in the summer of 2022. However, due to high interest and limited funds, NTIA did not open an application window for Native entities to apply for a planning grant at that time. Instead, NTIA combined the funds for Native entities from the Planning Grant with the funds for Native entities in this NOFO (pg. 43-44 of the NOFO).
NTIA has determined the most equitable way to distribute the funds to Native entities is through a competitive grant process. This means that not all applicants will get funding (pg. 43-44 of the NOFO).
Native entities do not need to include past LOIs but will submit a new application for this grant opportunity.

Future Funding

This funding opportunity includes funding for the first three years of the Capacity Grant program. Funding for years four and five will be provided in future funding rounds and via two additional NOFOs and applications.
We expect each of the future funding rounds will allocate (up to) an additional $300,000,000 to states, Native entities (with a set aside of five percent), and territories (with a set aside of one percent) to continue the work under the Capacity Grant Program (pg. 21 of the NOFO).

A “set aside” means funds are reserved for specific purposes. The funding set-asides are mandated by the IIJA and outlined in the NOFO. This means that Native entities will have five percent set aside of the total amounts from future funding for the Capacity Grant Program. In this case, it would be five percent of $300,000,000.

*See the first and second blog posts in this series for information on funding

What You Can Do Now

Work on getting the necessary approvals from your Tribal government including a Tribal Government Resolution or equivalent formal authorization from the governing body explicitly permitting the entity to apply on behalf of the Native entity (pg. 48 of the NOFO)
Decide if you want to apply in a consortium or as a single entity
Determine if you would like to apply to 1) create digital equity plans with activities that support the implementation of your plan, or 2) just implementation activities to address digital equity barriers in your community
Keep an eye out for NDIA’s upcoming Indigenous Digital Inclusion Planning Guide with more information on creating digital equity plans and implementation strategies.
Watch for the NTIA’s application guide for Native entities (as noted in State Digital Equity Capacity Grant Program: States and Territories Application Guidance, pg. 4)
Register with SAM.gov and Get your Unique Entity ID(UEI) from SAM.gov. This can take two days to three weeks. Make sure this step is completed well before the application deadline
Register in the NTIA Grants Portal
Native entities should direct questions to [email protected]