Assessing Commerce’s Management of the Digital Navigator Program

During outreach interviews, many people involved in digital equity work in Washington, including legislators and those at organizations involved in digital equity work, expressed concerns about the sudden funding surge and grants going to groups lacking digital equity expertise. They stressed the need for digital access and skills and called for better oversight of spending.

The Digital Navigators program ceased operations at the end of July 1, 2025, after Gov. Bob Ferguson vetoed its funding from the 2025-27 Operating Budget passed by the Legislature. The veto acknowledged that digital navigator services are worthwhile while citing fiscal constraints.

Monitoring and oversight are essential for ensuring grantees deliver on program objectives. Strong performance management helps agencies hold grantees accountable and measure whether programs achieve intended outcomes. Washington’s Department of Enterprise Services (DES) emphasizes such practices in its statewide training and guidance for agency contracts; the state’s Office of Financial Management (OFM) also offers more grant-specific advice that addresses similar areas. The leading practices they and other experts in grant management recommend include five essential components that formed part of our review of the Digital Navigator program’s agreements with grantees:

1. Develop and use competitive processes to award or expand grants, and require agency staff to follow them
2. Ensure direct grantees and subgrantees are properly vetted and managed to ensure proper accounting for/spending of grant money
3. Develop clear contracts that specify, among other things, the grant recipient’s timelines and deliverables, and ensure staff monitor grantee compliance with the contract
4. Include performance goals and measures that grantees and subrecipients must meet, and ensure agency staff have tools to measure performance appropriately
5. Spell out terms for reimbursement in contracts, and require agency staff to follow internal rules concerning payment

State law (RCW 43.330.040) allows agencies to develop and adopt their own rules for awarding grants and entering into grant agreements. However, despite the availability of resources from DES and OFM, and the requirements of state law, Commerce had in many cases not established its own grant management rules, procedures or guidance. Furthermore, where it did formulate set procedures, staff were not necessarily required to follow them. As a consequence, the agency lacked many elements of the five practices needed to support effective grantee oversight.

Given the lack of internal rules and guidance, our efforts to assess the agency’s Digital Navigator grants against specific criteria was difficult. In their absence, we instead relied on leading practices and existing OFM or DES state guidance to compare our expectations to what we found at Commerce.

The problems we found in the Digital Navigator program were tightly interconnected, sharing the same root cause: the failure at many levels of Commerce’s leadership in place at the time to establish grant management rules for agency staff to follow and to ensure those rules were enforced.

Faulty grant award processes

At the time Commerce conducted the grant application solicitation, review and selection processes, the agency lacked policies and procedures related to competitive processes for grants. The process used when selecting grantees was unclear. Of the 18 qualified applications for FY 2024, agency managers chose those ranked 1st, 8th and 18th. Although the score sheet contained explanations for why the applications ranked 2nd through 7th were not selected, it gave no explanation for why seven of the other nine rejected applications were not selected or why the one ranked 18th of 18 received a grant award.

Grants expanded without a competitive process

Commerce did not – and still did not as of November 2025 – have a standard in place for when and by how much existing grant-related contracts may be expanded without using the competitive process. While the agency lacked internal policies, staff were aware of state contracting rules that prohibited amending contracts without competition and increasing awards outside of the original scope. Yet we found at least one contract was amended without a competitive process. Furthermore, some grant amounts were expanded in ways the agency’s own contracts office flagged as violations. Despite a warning from a Broadband Office manager, senior executives approved the changes.

From July 2022 to June 2023, Commerce approved multiple grant applications despite applicants failing to meet established eligibility criteria. Commerce leadership and the program manager at the time ignored instances in which applicants had not specified whether any previous contracts had been terminated within the past five years or provided an insufficient amount of references required for either the business or its lead staff.

Critically, Commerce lacked a formal procedure for determining subgrantee eligibility. This oversight significantly increased the risk that grant funds intended to promote digital equity might be misallocated or misused. For FY 2024 and 2025, Commerce awarded Digital Navigator program grants to three consortiums, with each consortium run by one of the direct grantees. However, program contracts did not require consortium leaders to assess the eligibility of subgrantees receiving program funds.

Notably, one subgrantee – awarded $500,000 – closed down after its internal investigation into suspected financial mismanagement. At the time of our audit, the agency still lacked a procedure for addressing subgrantee eligibility.

According to 2024–25 state budget provisions, the Digital Navigator program was required to provide one-on-one assistance to underserved populations, including job seekers, students, families, English language learners, Medicaid clients, people experiencing poverty and older people. Grantees were expected to collect demographic data – such as age, race and household status – to help Commerce assess whether services reached these groups. Without meaningful performance data, Commerce would not be able to demonstrate whether the program met its goals or benefited the people it aimed to serve.

In examining the Digital Navigator program, we found that Commerce did not carry out steps for effective performance management, which limited its ability to evaluate grantee performance, ensure data quality and monitor the program effectively.

Incomplete and inconsistent data management contributed to ineffective oversight 

Commerce’s data collection was inconsistent and incomplete. We identified multiple failures around data, some of which can again be traced to inadequate contract provisions. For example:

• Lack of access to complete data: One of the three direct grantees stopped submitting data to the primary reporting grantee in mid-2024 due to concerns about data security and methodology.
• Unclear reporting requirements: Because Commerce never provided am an approved format for submitting data, grantees used varying and inconsistent data collection methods, making it difficult to analyze or compare their performance.
• No data validation: Neither Commerce nor the direct grantee validated the submitted data to ensure accuracy. Categories changed from year to year, and agency staff expressed concerns about how data was entered and interpreted.

We made a series of recommendations to the Department of Commerce to strengthen grant management practices, including establishing clearer procedures around contract expansion, reimbursement, eligibility verification, data collection and performance management. We also recommended the agency make improvements in staff training, oversight and leadership responsibilities. Additionally, we reenforced recommendations issued in our 2025 accountability audit to improve controls and oversight within the Digital Navigator and similar programs.