Treasury, Capital Projects Fund Best Practices for States, Territories, and Freely Associated States

Summary

Treasury's June 8, 2022 best-practices paper for Capital Projects Fund (CPF) Grant Plans and Program Plans from states, territories and freely associated states; it does not apply to Tribal governments. All Grant Plans and Program Plans were due by September 24, 2022, and Treasury reviews completed proposals on a rolling basis, often with follow-up questions. The paper walks through the Grant Plan executive summary, Program Plans, the allocation table and the Use Code Questionnaires for broadband (1A), devices (1B) and multi-purpose community facilities (1C). Broadband infrastructure must meet or exceed 100/100 Mbps symmetrical unless impracticable; a recipient claiming impracticability must justify it and still deliver at least 100/20 Mbps, scalable to 100 Mbps symmetrical. Recipients must keep SAM.gov information updated throughout the grant period.

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“Treasury, Capital Projects Fund Best Practices for States, Territories, and Freely Associated States.” Original at home.treasury.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/treasury-capital-projects-fund-best-practices-for-states-territories-a-7e73ff8c58/, SHA-256 6b62d04013adff4ebd0b4af098accc04dd6e67687c800f0ab558bb81503b0b87.

Full text

June 8, 2022

Capital Projects Fund (CPF) Grant Plan Best Practices
For States, Territories, and Freely Associated States
June 8, 2022

This document provides a brief overview of the CPF Grant and Program Plan submission process and
identifies several best practices for recipients. This document does not pertain to Tribal governments.

This document may be updated or modified periodically; changes will be clearly marked. Recipients
should consult the CPF Guidance for States, Territories, and Freely Associated States (CPF Guidance),
Frequently Asked Questions (FAQ) document, the Sample CPF Grant Plan (which also includes links to
the Use Code Questionnaires), and the CPF website (treasury.gov/CPF) for additional information.
Terms used in this document but not defined herein have the meaning specified in the CPF Guidance.

CPF PROGRAM OBJECTIVES
THE CAPITAL PROJECTS FUND WILL ADDRESS MANY CHALLENGES LAID
BARE BY THE PANDEMIC, ESPECIALLY IN RURAL AMERICA, TRIBAL
COMMUNITIES, AND LOW- AND MODERATE-INCOME COMMUNITIES,
HELPING TO ENSURE THAT ALL COMMUNITIES HAVE ACCESS TO THE
HIGH-QUALITY MODERN INFRASTRUCTURE, INCLUDING BROADBAND,
NEEDED TO ACCESS CRITICAL SERVICES.

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June 8, 2022

Table of Contents
General Overview, Reminders, and Resources ....................................................................................... 3
Submission Checklist ................................................................................................................................ 4
Completing the CPF Grant Plan & Program Plan(s) ................................................................................. 4
Grant Plan Executive Summary ........................................................................................................... 4
Program Plan(s) .................................................................................................................................... 5
Pre-Award Cost Annex (if applicable) .................................................................................................. 6
Allocation Table .................................................................................................................................... 6
Modifying the Amount of Program Administrative Funds ..................................................................... 6
Completing a Use Code Questionnaire: Use Code 1A (Broadband) ....................................................... 7
Completing a Use Code Questionnaire: Use Code 1B (Devices) ............................................................. 9
Completing a Use Code Questionnaire: Use Code 1C (Multi-Purpose Community Facilities) ............. 11

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June 8, 2022

General Overview, Reminders, and Resources
Overview and Reminders

Tip: Blue “tip” boxes found throughout this document highlight deadlines, reminders to
recipients, examples, and other information Treasury will be looking for when reviewing
submissions.

• All Grant Plans and Program Plans must be submitted by September 24, 2022. For more
information about the Grant Plan deadline, including information about potential fund
forfeitures and deadline waivers, see Section II.G of the CPF Guidance for States, Territories, and
Freely Associated States.

Tip: Treasury will review completed proposals (i.e., the Grant Plan and at least one Program
Plan) on a rolling basis.

• Recipients should be prepared to answer additional questions Treasury may ask when reviewing
the submitted Grant or Program Plan(s); Treasury’s review process is iterative and additional
information may be needed to complete the review.

• Recipients are permitted to submit additional attachments and documents to respond to
questions but should specify which question or prompt to which they correspond. Treasury will
consider relevant documentation submitted.

• Recipients are responsible for keeping their SAM.gov information updated and ensuring all
identification numbers provided are active throughout the entire CPF grant period of
performance.

Additional Resources

• CPF recipients should contact their Treasury point of contact with questions.
• General questions may also be submitted to CapitalProjectsFund@treasury.gov.
• Recipients should consult the following documents prior to submitting Grant or Program Plan(s):
o Capital Projects Fund Website
o CPF Guidance for States, Territories, and Freely Associated States
o CPF Frequently Asked Questions (FAQs)
o Sample CPF Grant Plan

Tip: Click here to access step-by-step instructions on how to complete and submit a Grant
Plan and Program Plans.

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June 8, 2022

Submission Checklist
Recipients must include the listed documents to successfully submit a Grant or Program Plan.
Grant Plan Program Plan
☐ Executive Summary ☐ Use Code Questionnaire (1A, 1B, 1C, 2)
☐ Allocation Table* ☐ Program Narrative**
☐ At least one completed Program Plan ☐ Program Budget**
☐ Pre-Award Cost Annex (if applicable)**
*This document does not need to be uploaded separately. Each completed Program Plan will automatically populate the
Allocation Table.
**This document is part of the Use Code Questionnaire but may need to be uploaded separately.

Tip: Recipients are only required to submit one Grant Plan but will submit at least one
Program Plan for each program type it intends to undertake. A Grant Plan and at least
one Program Plan must be submitted before Treasury will review a recipient’s
submission.

Completing the CPF Grant Plan & Program Plan(s)
States, territories, and freely associated states must submit a Grant Plan and at least one Program Plan.
The Grant Plan consists of an Executive Summary, the Allocation Table, and one or more Program Plan.

Grant Plan Executive Summary
Purpose
The Executive Summary provides high-level information about the recipient’s overall plan for using CPF funds
and will be submitted by uploading a document to Treasury’s Submission Portal.
Best Practices and Reminders
• Should be uploaded as a PDF, if possible.
• Should be approximately two pages in length.
• Is intended to provide an overview of a recipient’s entire Capital Projects Fund proposal.
o Further detail should be provided in individual Program Plans.

Tip: The Executive Summary and the Program Narrative are two separate documents.
The Executive Summary should be uploaded and submitted with the Grant Plan, while
the Program Narrative is program specific and should be uploaded to a Program Plan.

• Should include a paragraph, with corresponding headers, for each of the following:
o A brief description of the objective(s) for the full CPF allocation, to be carried out by one or more
Program Plans;
o A narrative that explains the recipient’s rationale on how CPF funds are allocated, as reflected in the
Allocation Table; and
o A description of how the recipient identified communities of critical need, addressing the following
questions:
▪ What process(es) did you undertake, and factors did you consider, in identifying critical needs?
▪ How has community engagement and public participation informed your approach for spending
CPF grant funds and planning for implementation and operation of capital assets?
▪ How was equity considered in the selection of programs and the distribution of funds?

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June 8, 2022

Tip: If recipients choose to use their entire allocation for one program, they are still
required to submit an Executive Summary and a Program Plan Narrative.
Recipients should also indicate why they chose to allocate all CPF funds to a single use in
the Executive Summary.

Program Plan(s)
Purpose
A Program Plan constitutes a recipient’s request for funding for a specific use. Program Plan(s) should provide
detailed information on a particular program type the recipient intends to undertake, including the objectives of
the program, the way in which the program will be administered, how equity and critical need are considered in
program design and implementation, among other pieces of information outlined in the Program Plan
questionnaire.

Tip: Program Plans can vary in length but are typically 5-10 pages. Recipients may include
supplemental attachments that support answers provided in the Program Plan (such as
RFPs, scoring criteria, etc.), but must indicate which questions they correspond to.

Best Practices and Reminders
• Project funds will be made available once a Program Plan is approved by Treasury.
• Recipients should submit one Program Plan for each intended use of funds.

Example: A single Program Plan could propose using CPF grant funds towards the
improvement of several existing libraries and the construction of new ones in accordance
with the CPF guidance. A recipient would not need to submit a Program Plan for each
library it intends to update.

• Recipients are asked to submit a Use Code Questionnaire based on the type of proposal being submitted.
Each Use Code has its own questionnaire that must be completed and submitted for Treasury’s review.
• Each Use Code Questionnaire contains the Program Narrative template, Budget template, and Pre-Award
Cost Annex.
o Use Code 1A – Broadband Infrastructure Projects
o Use Code 1B – Digital Connectivity Technology Projects
o Use Code 1C – Multi-Purpose Community Facilities
o Use Code 2 – Other (Case-by-Case Review)

Tip: The Program Narrative, Program Budget, and Pre-Award Cost Annex are found in the
Use Code Questionnaire templates.

• If CPF grant funds cover costs related to a program that were incurred after March 15, 2021, and prior to
the execution of the Grant Agreement, recipients must complete and submit a Pre-Award Cost Annex.
• Recipients will have an opportunity to revise and resubmit portions of their Program Plan(s) that Treasury
determines do not meet the criteria set out in the Capital Projects Fund Guidance or that require additional
information for approval.

Tip: Revised Program Plans will be submitted as a new document uploaded to the
Portal. The deletion or editing of existing Program Plan(s) is not permitted.

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June 8, 2022

Pre-Award Cost Annex (if applicable)
Purpose
Recipients with program costs incurred after March 15, 2021, and prior to the execution of the Grant
Agreement (“Pre-Award Costs”), will be required to provide additional information detailing these costs. Pre-
Award Costs must have been incurred in anticipation of a CPF grant award and must be necessary for the
efficient and timely performance of the proposed project(s).

The Pre-Award Cost Annex template can be found at the end of each Use Code Questionnaire. Recipients are
required to upload the completed Pre-Award Cost Annex as an attachment to the related Program Plan. Costs
incurred prior to March 15, 2021, are not eligible CPF costs.

Allocation Table
Purpose
The Allocation Table depicts the use of funds and includes program titles, program use codes, program costs,
proposed start and completion dates, short program descriptions, and program objectives. The Allocation Table
is generated automatically from data entered in each Program Plan in Treasury’s Submission Portal. No
additional actions are needed to create or submit the Allocation Table.
Best Practices and Reminders
• Information provided in the fields in Section 2 of the Program Plan on the Treasury Submission Portal
automatically populates the Allocation Table once the information is saved.
• The Allocation Table serves as a current record of the uses of CPF funds.
o Fund amounts shown in the Allocation Table should match amounts provided in other documents
submitted via the Grant Plan and Program(s).
• Changes are made to the Allocation Table by updating the Program Plan fields in the Portal. All changes to
the Allocation Table should be made in a timely manner.
• Recipients may download and view a PDF of their Allocation Table at any time.

Modifying the Amount of Program Administrative Funds
Recipients may increase or decrease the total amount of Program Administrative Funds at any time
during the period of performance. Recipients may submit requests to change the total amount of
Program Administrative Funds on the Grant Plan page of the Treasury Submission Portal. Once
submitted, Treasury will review requests and notify the recipients once approved.

• The Treasury Submission Portal displays a recipient’s total amount of available Program
Administrative Funds.
• CPF recipients may reallocate Program Administrative Funds to instead be used for Project Costs
in the Treasury Submission Portal.
o Recipients should reach out to their Treasury point of contact if they decide to do so.

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June 8, 2022

Completing a Use Code Questionnaire: Use Code 1A (Broadband)

Use Code 1A: Broadband Infrastructure Projects
Reminders
• Recipients should reference the CPF Guidance for States, Territories, and Freely Associated States when
completing and submitting a Program Plan for a Broadband Infrastructure Project.

Tip: Treasury requires Broadband Infrastructure Projects to meet or exceed speeds of
100/100 Mbps symmetrical unless impracticable.

Review Rubric
The following is the general rubric Treasury will be following when reviewing a Use Code 1A Program Plan.
 The proposed program is designed to meet or exceed Treasury’s 100/100 Mbps symmetrical speed
requirement.
o Recipients submitting Broadband Infrastructure Projects that do not meet Treasury’s 100/100 Mbps
requirement must provide a detailed and reasonable justification of impracticability using all available
qualitative and quantitative data.
o In cases where the impracticability justification will be used, the program must be designed to reliably
meet or exceed 100/20 Mbps and be scalable to a minimum of 100 Mbps symmetrical in the future.

Tip: Recipients should develop a process to assess subrecipient project proposals that do
not meet speeds of 100/100 Mbps symmetrical to determine whether it would in fact be
impracticable to deliver the required speeds. Factors to consider may include excessive
deployment costs per location or geographic barriers. Recipients must include specific
data sources relied on to develop this process and provide a description of that process.

 Program Plan expresses a preference for fiber and last-mile projects.
 Recipient requires participating service providers to participate in the Affordable Connectivity Program
(ACP, previously Emergency Broadband Benefit).
 The recipient describes the process it followed to address affordability in the project specifications and
selection criteria.
o Treasury encourages the use of data from surveys, community engagement, existing studies, or other
data to determine affordable broadband service for the areas to be served. For example, recipients
may cite pricing data, the characteristics of a basic service, latency, non-recurring costs, data caps, or
whether the application of ACP will reduce the monthly fee to an amount less than the average
monthly service fee for that community.

Tip: Recipients are required to publish the description (e.g., make public in recipient’s
program guidance, publish on recipient’s program website, etc.) of their process for
considering affordability in their project selection process and must provide this
information in their Program Plan.

 The Program Plan addresses a critical need that was exacerbated by the COVID-19 public health emergency
in the communities where the investments will be made.
o The recipient provides evidence of how a critical need was identified and how the recipient plans to
address the need. For example, critical need can be a lack of access to broadband or affordable
broadband service options or a historically disadvantaged community or population.
 Recipient describes the type of program that is to be created/continued with CPF funds (e.g., competitive
grant program, direct project funding, etc.).
 Recipient details initial and ongoing (i.e., post deployment) community engagement efforts.

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June 8, 2022

 The Program Plan demonstrates that the proposed use of funds is fully funded and will be operational by
December 31, 2026.
 Recipient lists all relevant federal and state data used throughout the planning process.
 If applicable, the recipient lists all other federal and state funding streams used to supplement the
proposed project(s).

Tip: If proposing broadband deployment to locations with existing federal or state funding
commitments for wireline services, recipients should ensure CPF funds will not be used for
costs that will be reimbursed by other federal or state funding streams. Recipients must
also ensure funding is complementary, and that there is additional public benefit and
justification for using additional public funding in these locations.

 The recipient demonstrates financial, managerial, and institutional capability to complete the proposed
program.
o Recipients may demonstrate financial, managerial, and institutional capability by, for example,
detailing previous experience managing similar grant program, increasing staff to oversee program, or
partering with outside organizations or agencies for program assistance.
 Recipient provides detailed timelines and milestones related to administering the program during the
period of performance including the following (as applicable):
o Request for Proposal (RFP) publish date; application deadline; application review timeline; award
date; grant agreements signed; construction phase(s); projected project completion; and start date of
subsequent round of applications.
 If proposing a subgrant program, the CPF recipient (i.e., the state) provides the following to Treasury (as
applicable):
o Subgrant application announcement; subgrant application; Request for Proposals (RFPs); subrecipient
scoring rubrics; subaward grant agreement; and description of outreach to eligible applicants.
o Where applicable, the recipient provides documentation of the processes and guidelines used to
select subrecipients.

Tip: Recipients are encouraged to include an estimate of the number of locations (i.e.,
households, businesses, etc.) to be served by the CPF investment.

 Recipient describes how the compliance, subrecipient monitoring, and technical assistance described in the
Program Plan will be conducted.
 The requested amount of funding for a Program Plan is consistent across all submitted documents (e.g.,
Executive Summary, Allocation Table, submitted budget, Program Plan Narrative, etc.), and the
components of the budget submitted total to the requested amount of funding.

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June 8, 2022

Completing a Use Code Questionnaire: Use Code 1B (Devices)

Use Code 1B: Digital Connectivity Technology
Reminders
• Recipients should reference the CPF Guidance for States, Territories, and Freely Associated States when
completing and submitting a Program Plan for a Digital Connectivity Technology Project.

Tip: Ownership of CPF Digital Connectivity Technology devices must be retained by the
recipient or subrecipient.

Review Rubric
The following is the general rubric Treasury will be following when reviewing a Use Code 1B Program Plan.
 Proposed devices are for public distribution or made available in a public facility.
 The Program Plan describes the types of digital devices and their uses.
o Where applicable, the recipient describes anticipated ancillary costs required to operate and
maintain the digital devices.
 Recipient describes type of digital device program that is to be created/continued with CPF funds (e.g.,
long-term loan device program, short-term loan device program, computer lab, etc.).

Tip: The recipient or, where applicable, subrecipient must retain ownership of devices
purchased with CPF grant funds.

 The Program Plan addresses a critical need that was exacerbated by the COVID-19 public health
emergency in the communities where the investments will be made.
o The recipient provides evidence of how a critical need was identified and how the recipient plans to
address the need.
 Recipient lists all relevant federal and state data used throughout the planning process.
 Recipient details initial and ongoing (i.e., post project implementation) community engagement efforts.
 Recipient addresses affordability in the proposed plan.

Tip: Recipients are required to publish the description of their process for considering
affordability in their project selection process. Recipients must provide this
information in their submitted Program Plan.

 The Program Plan demonstrates that the proposed use of funds is fully funded and will be operational
by December 31, 2026.
 If applicable, the recipient lists all other federal and state funding streams used to supplement the
proposed project(s).
 The recipient demonstrates a financial, managerial, and institutional capability to oversee the selection
of specific investments and completion of the proposed program and any projects funded by it.
o Recipients may demonstrate financial, managerial, and institutional capability by, for example,
detailing previous experience managing similar grant program, increasing staff to oversee program,
or partering with outside organizations or agencies for program assistance.
 Recipient provides a detailed timeline and milestones related to administering the program during the
period of performance including the following (at a minimum, where applicable):
o RFP publish date; application deadline; application review timeline; award date; grant agreements
signed; programmatic delivery phase(s) (e.g., digital literacy training), projected project completion;
and start date of subsequent round of applications.

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 If proposing a subgrant program, the CPF recipient (i.e., the state) provides the following to Treasury (as
applicable):
o Subgrant application announcement; subgrant application/RFP; subrecipient scoring rubrics;
subaward grant agreement; and description of outreach to eligible applicants.
o Where applicable, the recipient provides documentation of the processes and guidelines used to
select subrecipients.
 Recipient describes how the compliance, subrecipient monitoring, and technical assistance described in
the Program Plan will be conducted.
 The requested amount of funding for a Program Plan is consistent across all submitted documents
(e.g., Executive Summary, Allocation Table, submitted budget, Program Plan Narrative, etc.), and the
components of the budget submitted total to the requested amount of funding.

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June 8, 2022

Completing a Use Code Questionnaire: Use Code 1C (Multi-Purpose Community
Facilities)

Use Code 1C: Multi-Purpose Community Facilities
Reminders
• Recipients should reference the CPF Guidance for States, Territories, and Freely Associated States when
completing and submitting a Program Plan for a Multi-Purpose Community Facility Project.

Review Rubric
The following is the general rubric Treasury will be following when reviewing a Use Code 1C Program Plan.
 The Program Plan demonstrates that the recipient’s overarching program has been designed to ensure
investments funded using CPF funds will jointly and directly enable work, education, and health
monitoring.
 The Program Plan demonstrates that the recipient’s overarching program has been designed to ensure
investments funded using CPF funds will provide services for at least five years after the completion of
the project.

Tip: Multi-Purpose Community Facilities must enable work, education, and health
monitoring. Recipients must explain how it will ensure any project selected to be
funded using CPF funds (i.e., subgrants) meets all three objectives in the Program Plan.

Tip: 1C Program Plans must demonstrate that the investment serves a community with
a demonstrated community need and that the facility is publicly accessible to that
community.

 Recipient lists all relevant federal and state data used throughout the planning process.
 Recipient details initial and ongoing (i.e., post construction) community engagement efforts.

Tip: Recipients must provide assurance that the operations and maintenance (O&M)
costs necessary to operate the project past the CPF grant period of performance have
been considered and a financial structure is in place to pay those costs.
Note that CPF award funds may not be used for O&M costs.

 The Program Plan demonstrates that the facility proposed for the use of funds is fully funded and will be
operational by December 31, 2026.
 If applicable, the recipient lists all other federal and state funding streams used to supplement the
proposed project(s).
 The recipient demonstrates a financial, managerial, and institutional capability to oversee the selection
of specific investments and completion of the proposed program and any projects funded by it.
o Recipients may demonstrate financial, managerial, and institutional capability by, for example,
detailing previous experience managing similar grant program, increasing staff to oversee program,
or partering with outside organizations or agencies for program assistance.
 Recipient provides a detailed timeline related to administering the program during the period of
performance including the following (at a minimum, where applicable):

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June 8, 2022

o RFP publish date; application deadline; application review timeline; awards made; grant agreements
signed; construction phase(s); projected project completion; and start date of subsequent round of
applications.
 If proposing a subgrant program, the CPF recipient (i.e., the state) provides the following to Treasury (as
applicable):
o Subgrant application announcement; subgrant application/RFP; subrecipient scoring rubrics;
subaward grant agreement; and description of outreach to eligible applicants.
o Where applicable, the recipient provides documentation of the processes and guidelines used to
select subrecipients.
 The Program Plan provides assurance that the recipient or, if applicable, subrecipients retain ownership
of the CPF investment.
 Recipient describes how the compliance, subrecipient monitoring, and technical assistance described in
the Program Plan will be conducted.
 The requested amount of funding for a Program Plan is consistent across all submitted documents (e.g.,
Executive Summary, Allocation Table, submitted budget, Program Plan Narrative, etc.), and the
components of the budget submitted total to the requested amount of funding.

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