; (B) purchase, rent, lease, or otherwise obtain any covered communications equipment or service, using reimbursement funds or any other funds (including funds derived from private sources); or (C) make network upgrades that go beyond the replacement of covered communications equipment or services, as determined by the Commission. (d) Implementation (1) Regulations Not later than 270 days after the date of the enactment of this Act, the Commission shall promulgate regulations to implement the Program. (2) Suggested replacements (A) Development of list The Commission shall develop a list of suggested replacements of both physical and virtual communications equipment, application and management software, and services. (B) Neutrality The list developed under subparagraph (A) shall be technology neutral and may not advantage the use of reimbursement funds for capital expenditures over operational expenditures, to the extent that the Commission determines that communications services can serve as an adequate substitute for the installation of communications equipment. (3) Application process (A) In general The Commission shall develop an application process and related forms and materials for the Program. (B) Cost estimate (i) Initial estimate The Commission shall require an applicant to provide an initial reimbursement cost estimate at the time of application, with supporting materials substantiating the costs. (ii) Updates During and after the application review process, the Commission may require an applicant to— (I) update the initial reimbursement cost estimate submitted under clause (i)