Official Site of The State of New Jersey

All projects funded by the Board of Public Utilities under the New Jersey Broadband Infrastructure Deployment Equity (NJBIDE) program—whether executed by a Local Government Unit (LGU) subrecipient or an ISP contractor on a fixed subaward—must strictly comply with the New Jersey Prevailing Wage Act and the Public Works Contractor Registration Act.

1.1 Statutory Authority & Definitions

• The New Jersey Prevailing Wage Act (N.J.S.A. 34:11-56.25 et seq.): This Act mandates the payment of prevailing wage rates to workers employed in the performance of any construction undertaken in connection with Board of Public Utilities (BPU) financial assistance.
• The Public Works Contractor Registration Act (N.J.S.A. 34:11-56.48 et seq.): This Act requires all contractors, subcontractors, or lower-tier subcontractors who bid on or engage in the performance of prevailing wage work to register with the Department of Labor and Workforce Development (NJDOL). The Contractor Registration Certificate is issued to both the company and its responsible representatives.

1.2 Contractor Registration & Labor Integrity

• Mandatory Registration: Subgrantees must ensure that all vendors and subcontractors hold a valid Public Works Contractor Registration (PWCR) certificate at the time of the bid and maintain it throughout the duration of the contract.
• The Workplace Accountability in Labor & Debarment Lists (N.J.S.A. 34:1A-1.16): You are strictly prohibited from contracting with any entity listed on the NJDOL Debarment List or the Workplace Accountability in Labor List.
• Low Bid Certification: A written prevailing wage certification is required for any bid that is 10% or more below the next lowest bid.

Before any onsite work begins or any reimbursement for subcontracted labor is processed, the Subgrantees must submit a comprehensive list of all subcontractors involved in the project.

• Retrospective Disclosure for Active Projects: Subgrantees who have already commenced construction or infrastructure work prior to the issuance of this handbook must submit a complete list of all subcontractors utilized to date. This catch-up disclosure is due within 10 business days of receipt of this handbook.
• Required Data Points: Legal Business Name/DBA, 9-digit FEIN, PWCR Number, Scope of Work, and Estimated Contract Value. To submit this information, use the following form: “Retrospective Disclosure for Active Projects”.

Under New Jersey law, the submission of certified payroll is a digital-first requirement. All contractors and subcontractors working on NJBIDE-funded projects must use the official state portal to report wages.

• Portal Name: New Jersey Wage Hub
• Submission Deadline: Payroll records (Form MW-562) must be uploaded to the Wage Hub for every week in which work is performed.
• Dual Submission for Reimbursement: While the Wage Hub is the state's central database, Subgrantees must also provide a copy of the certified payroll directly to the BPU within 10 business days of the payment of wages to remain eligible for grant reimbursement. Submit copies to broadband@bpu.nj.gov and copy elena.thaxton@bpu.nj.gov . 

Registration Requirements: To use the NJ Wage Hub, contractors need: a) A 9-digit FEIN. b) A valid Public Works Contractor Registration Number. c) A myNewJersey account linked to Employer Access.

Direct Resources for Contractors:

• Official Guide: NJ Wage Hub Contractor User Guide (PDF)
• Quick Reference: NJ Wage Hub FAQ & Updates

Pro-Tip for Subgrantees: We recommend using the CSV Upload feature in the Wage Hub if you have more than 10 employees, as it significantly reduces manual entry errors that could delay your reimbursement.

Subgrantees must navigate two primary reporting cycles. Please refer to your Executed Grant Agreement regarding your specific milestone schedule and opening dates.

Monthly Status Report

• Due: 5th business day of every month.
• Submission: Use Monthly Form
• Focus: High-level project updates and immediate risks.

Quarterly Performance Report

• Due: 10 business days after quarter-end.
• Submission: Use Quarterly Performance Form
• Focus: Progress against specific grant milestones.

Quarterly Expenditure Report

• Due: 60 days after quarter-end.
• Portal: Use NJBPU IGX Grant Management Portal

Rule: You must initiate a report even if you have $0 expenditure to report.

*  IMPORTANT NOTE: To ensure sufficient BPU processing time, all final reimbursement requests must be submitted no later than November 30, 2026. In strict adherence to U.S. Treasury guidelines, no grant disbursements will be made beyond the December 31, 2026 Period of Performance expiration date.

To receive payment, you must provide "Substantiating Evidence" as required by 2 CFR § 200.302 and § 200.403.

1. Invoices: Detailed vendor invoices showing dates, services, and costs.
2. Proof of Payment (Cleared Funds):
   Note: Subgrantees must have already disbursed funds to a vendor before seeking reimbursement from the State.
   1. Standard Requirement: Copies of bank statements or the front and back of cleared checks.
   2. Local Government Units (LGUs): For municipalities, counties, and authorities, your Chief Financial Officer (CFO) may submit a Certified General Ledger (GL) report as an allowable form of evidence. The GL must clearly show the date of the transaction, the vendor’s name, the check/wire number, and the specific NJBIDE budget line item to which the expense was charged.
   3. Electronic Funds Transfer (EFT): For payments made via ACH or wire, please provide the electronic confirmation receipt or a bank statement highlighting the transaction.
3. Certified Payroll: Required for all construction/infrastructure labor. Use the Prevailing Wage Hub for certified payroll submissions. Submissions to the BPU (“Public Body”) send to broadband@bpu.nj.gov and copy elena.thaxton@bpu.nj.gov.
4. U.S. Treasury BSL Template: On a quarterly basis and as you pass the required number of Broadband Serviceable Locations, you must submit via email the OBC CPF Application Location Data Template to broadband@bpu.nj.gov and elena.thaxton@bpu.nj.gov

Subgrantees are subrecipients of federal funds from the U.S. Department of the Treasury Capital Projects Fund (CPF). All costs must be allowable, allocable, and reasonable under 2 CFR Part 200. Failure to maintain proper source documentation or comply with NJ Prevailing Wage standards may result in the denial of reimbursement or the "claw back" of previously disbursed funds.

Triggered by project progression.

Following mobilization, subgrantees will be paid on a percentage completion milestone basis. As your project advances, you are required to report on specific Broadband Serviceable Location (BSL) milestones to validate your deployment.

• Mobilization Milestone: The initial 10% payment milestone is triggered upon the mobilization of equipment and personnel to the construction site, which must occur within 60 days of the agreement execution date.
• Deployment Milestones: You must submit formal location data proving deployment as you hit the remaining completion targets: 10%, 35%, 60%, 85%, and 100% of locations passed. Specific milestone targets can be found in your executed grant agreement.
• Engineer's Certification: Payment for completed milestones requires an Engineer's Certification that verifies both the project's percentage of completion and the delivered broadband speeds.
• CPF Location Data Upload: Submit the mandatory Location Data Template, detailing Fabric IDs, technology types, and delivered speeds for all passed locations.
• Monthly Site Inspections: Subgrantees must submit inspection locations via our GIS data collection tool.
• Submission Method: Access the Survey123 Site Inspection Portal

NJBIDE Deployment Map: [Coming Soon] An interactive GIS map will be available here to display completed and in-progress BSLs across the state for awardee reference.

• Important notice regarding grant disbursements and final obligations.

  The Office of Broadband Connectivity (OBC) actively monitors compliance. Timely reporting is a mandatory requirement of your grant agreement, regardless of expenditure activity.

  • Drawdown Holds: If a Subgrantees fails to submit required monthly/quarterly reports, or if there is a significant discrepancy between forecasted and actual expenditures without justification, BPU may place a hold on all financial drawdowns.
  • Single Audit & Risk Assessments: Local Government Unit (LGU) Subgrantees that expend $1,000,000 or more in Federal awards during their fiscal year must conduct a Single Audit. For-profit contractors are exempt from the Single Audit requirement but remain subject to BPU risk assessments, continuous monitoring, and post-award closeout processes as outlined by U.S. Treasury guidance.
  • Federal Interest & Affordability: The Federal Interest Period lasts until December 31, 2034. During this time, the Subgrantees must maintain the infrastructure and participate in federal programs (like the ACP or equivalents) that provide low-income consumers with broadband subsidies.
  • Project Closeout:
  • The entire project must be completed no later than December 31, 2026. All final requests for reimbursement must be submitted no later than November 30, 2026. No reimbursements will be processed or paid beyond December 31, 2026.
  • A Close-out Project Performance Report, including final documentation, is due no later than 60 calendar days after project completion (template to follow).
  • Upon completion of NJBIDE projects, Subgrantees are required to provide data on speed tiers offered and corresponding non-promotional prices, including associated fees, for each speed tier of broadband service. Data should be uploaded to the project using the Speed and Pricing Template.

Under standard federal Uniform Guidance (2 CFR § 200.313), the rules for managing equipment and capital assets acquired with federal funds are highly prescriptive. However, recognizing the unique scale of broadband infrastructure, the U.S. Treasury issued Supplemental Guidance on May 17, 2023, providing significant flexibilities for Capital Projects Fund (CPF) Subgrantees.

All NJBIDE subgrantees (both LGUs and ISP Contractors) must adhere to the following property management standards regarding the U.S. Treasury's "Federal Interest."

10.1 The "Commercial Practices" Exception

Treating a massive fiber-optic network like standard federal equipment (which typically requires a biennial physical inventory of every asset) is impractical. Therefore, subgrantees are permitted to satisfy the federal equipment management requirements by applying their own standard commercial practices in the normal course of business.

• Allowable Systems: You may use your existing commercial inventory controls, tracking software, and loss prevention procedures to manage the network assets. You are not required to adopt federally specific inventory software.

10.2 The "Federal Interest" Tag (Mandatory)

The major condition for using your own commercial practices is that your inventory controls and real property records must clearly indicate the applicable federal interest.

• Requirement: Your internal asset tracking system must have a mechanism to legally tag, label, or categorize all NJBIDE-funded infrastructure (e.g., fiber lines, huts, routers) as possessing a U.S. Treasury Federal Interest.

10.3 Federal Interest Period & Trust Relationship

While you hold title to the property, the federal government retains a legal interest in the infrastructure to ensure it continues to serve its intended public purpose.

• Duration: For the NJBIDE program, the Federal Interest Period lasts until December 31, 2034.
• Trust Requirement: Pursuant to 2 CFR 200.316, you must hold the agreement property in trust for the beneficiaries of the broadband infrastructure project for the entire duration of the Federal Interest Period.

10.4 Upgrades and Disposition

During the Federal Interest Period, the U.S. Treasury allows for the modernization of the network without requiring complex federal approval processes for every equipment change.

• Routine Upgrades: You may dispose of property in the ordinary course of business (e.g., replacing out-of-date equipment to upgrade the network) provided that the same level of service is maintained without material interruption.
• Inherited Interest: Any new or upgraded property that replaces the original NJBIDE-funded equipment automatically becomes subject to the same Federal Interest requirements through December 31, 2034.

10.5 Encumbering Grant-Funded Property

Subgrantees (including ISPs and LGUs) may not pledge, lien, or otherwise encumber NJBIDE-funded broadband infrastructure as collateral for a loan without prior federal approval. If a subgrantee intends to encumber project property, they must immediately notify the BPU. Specific legal documents (such as an Intercreditor Agreement and UCC-1 filings) must be drafted to protect the U.S. Treasury's Federal Interest and must be submitted to the BPU for U.S. Treasury approval prior to execution by the subgrantee or their lending institution.

The OBC Project Management Team is here to support you in delivering high-speed, equitable broadband to all New Jerseyans.

If you require technical assistance with the IGX/SAGE portals, have questions regarding the reporting templates, or need to schedule a consultation with the compliance team, please contact us:

• Primary Email: broadband@bpu.nj.gov
• CC: elena.thaxton@bpu.nj.gov

Note: For official site inspections and compliance meetings, our team will coordinate directly with your designated Project Manager