CARES ESSER I, CARES Incentive Grants, CRRSA ESSER II, ESSER II Statewide Set-Aside, ARP ESSER III, ARP E-Rate! ……..OH, MY!

CARES ESSER I, CARES Incentive Grants, CRRSA ESSER II, ESSER II Statewide Set-Aside, ARP ESSER III, ARP E-Rate! ……..OH, MY!

A compilation of the most frequently asked questions and the best answers available at this time

By Kathy Dunn, CCOSA Federal Programs Consultant

Since March of 2020, Oklahoma public schools have been called upon to deliver instruction inperson, in a blended learning model, and in a fully virtual model. Schools have also been called upon to deliver meals in-person, in a bag, and on-wheels. Fortunately, Congress has realized what an unprecedented feat the nation’s schools have been asked to accomplish, and money has been appropriated to help schools meet the challenges of educating during a pandemic, meet the social and emotional needs of students and staff, and continue to provide the student supports needed, all while weathering the economic downturn the pandemic has created.

The graph below gives a timeline for the use of the federal COVID relief funds that have been appropriated, with the exception of the American Relief Program (ARP) E-Rate funds which are held until final guidance has been written on the use of those funds.

Normally in a grant program months or years might be spent writing specific guidance for the use of the funds; however, in the midst of the pandemic Congress wisely appropriated the funds to meet the immediate needs of schools, students and staff. It has at times felt like we are building the airplane while in flight!

Consortium Q&A

The compilation of questions and answers in this article represent the most commonly asked questions received at CCOSA and the best-known answers available at this time while the airplane is still in flight. Guidance could change, and Oklahoma educators will adjust our “turn and bank” instruments to right the flight when more guidance is released!

1. What are the allowable uses of ESSER II funds?

The allowable uses of ESSER I, II, and III are the same with the exception of the CARES Incentive Grants which are a bit more prescriptive.

2. Can you pay for employees’ salaries with ESSER funds? Yes and No.

- You can pay existing employees from CARES I (788) and from ESSER II (793) funds.

- You cannot pay existing employees from CARES Incentive Grant funds (789).

-You can pay for new positions that are hired in response to the pandemic from all coronavirus relief funds within the guidance of each grant to prepare, prevent, or respond to COVID-19.

3. Must an employee paid by ESSER funds be listed in the School Personnel Report (SPR)?

Yes, before a district can claim a salary or stipend in ESSER funds the employee must be listed in SPR and coded to the ESSER project code 788, 789, 793, 794, or 795.

4. If paying employee salaries from ESSER funds, is the Federal Matching Contribution required for Oklahoma Teacher Retirement?

Salaries with funds through either the FFCRA or ESSERs I, II and III are required to remit the statutory retirement contributions to TRS on these salaries (if you pay teacher retirement for that employee). This includes the Federal Matching contribution due for salaries paid by federal funds or external sources such as grants. OAC 715:10-13- 7. Matching funds.

5. Can we pay teachers a stipend from ESSER funds?

Yes, stipends may be paid to compensate teachers for additional duties that are a result of the pandemic, or stipends may be paid to recruit and retain staff as a response to COVID-19. Considerations:

1. The stipend would go through payroll, and it would be subject to the Federal Matching Contribution.

2. An established plan for the additional compensation must accompany the claim for stipends stating what employees will receive it and what amount of compensation will be paid.

3. Keep documentation and justification for all expenditures.

4. OCAS Coding: All of the stipends for these additional pay purposes would be coded like their individual salary lines except for the Object Code. Stipends for certified staff would be coded to 170 and non-certified would be 180.

5. Make sure employees understand this is onetime money, not to count on the increase in the salary schedule, if that is true.

6. Are ESSER-paid employees required to keep Time and Effort records?

Yes, time and effort records are required; however, there is new guidance for federal programs. Now if an employee works in a single cost objective, for example a paraprofessional who works full-time as a paraprofessional, that employee may be listed on a spreadsheet with other single cost objective employees and kept with the federal programs records. The spreadsheet does not require signatures, nor is it turned in, except in a federal monitoring. For ESSER stipends, a printed report from SPR records would document the stipends.

7. If salaries for substitute teachers and tutors, or stipends for professional development are paid from ESSER, does the district need Time and Effort records?

No, Time and Effort documents would not be required for substitutes, tutors, or professional development stipends. The district would send the typical documentation with the claim such as timesheets, sign-in sheets, and agendas with notation that the activity was either to prepare, prevent, or respond to COVID-19.

8. Can ESSER funds be used to replace old, outdated computers? Are there procedures that must be followed to dispose of outdated computers or other technology that was purchased with federal funds?

Yes, ESSER funds can be used to replace outdated technology as needed to respond to COVID-19 by mitigating the learning loss, delivering instruction in distance learning, and responding to instructional challenges caused by COVID-19.

-Basically, follow your district’s policy for disposition of supplies and equipment when you can show that supplies and equipment are no longer needed in the program for which it was purchased.

-Keep records of the disposition for 3 years or more until any audit of the purchases or program would be completed

-Know your EDGAR Section 200.313 and 200.314 for specific information about disposition of supplies and equipment, less than and more than $5,000.

9. Is Maintenance of Effort (MoE) required for the ESSER funds?

No, but MoE is still required under IDEA and ESSA laws at the time of this writing. See the information on page 13 in the full issue of Better Schools for more detailed information about the MoE and the new requirement for Maintenance of Equity in ESSER III.

10. Can we use ESSER funds to create an outdoor classroom space?

Yes, creating an outdoor classroom prevents the spread of the virus by increasing the space for social distancing, and there is research that an outdoor environment reduces the transmission of the virus.

11. Should school districts expect a monitoring process or audit of these ESSER funds?

Yes, the ESSER funds are subject to the Single Audit Act requirements if a district’s total expenditures in all federal programs meet or exceed $750,000.00 for a single year. The ESSER funds may place some districts above $750,000.00 for the first time. Contact your auditor to discuss the difference in cost and manpower involved in the single audit process. Audits/monitoring by USDE and OSDE are also a possibility.

12. Can buses be purchased with ESSER funds?

-Yes, yellow route buses - full-size school buses, handicapped-equipped buses, and compact buses are allowable to prevent the spread of COVID-19.

-Activity buses are NOT allowable in these funds.

-Vehicles for 10 passengers or less are allowable for running Homeless routes and for delivery of meals and learning packets into neighborhoods in response to COVID-19.

13. Can we pay off our two “lease to own” agreements for buses leased to provide more social distancing on bus routes?

Yes, lease payments for buses that are an approved expenditure in the current fiscal year may be paid with ESSER funds for continuity of services in response to COVID-19 and to prevent the spread of COVID-19.

14. May we repair a leaking roof with ESSER II funds?

Yes, roofs may be repaired to improve the air quality and create a healthy learning environment in response to COVID-19.

15. May we repair or replace HVAC systems with ESSER II funds?

Yes, HVAC systems are allowable to improve the air quality and create a healthy learning environment in response to COVID-19.

16. May we replace or repair broken windows and doors with ESSER II funds?

Yes, new windows and doors are allowable to improve the air circulation and create a healthy learning environment to prevent the spread of COVID-19.

17. Can districts continue to pay Verizon for our students’ Hotspot connectivity after the contract is expired?

Yes, enabling students to have internet access at home to close the homework gap is allowable in response to COVID-19.

18. Can districts claim Administrative Costs and IDC in ESSER II?

Yes, districts may claim both, but you cannot claim administrative salaries in both. IDC would be reduced by the amount of administrative salaries claimed in Administrative Costs. You also cannot claim equipment or capital expenses over $5,000 in IDC.

19. In general, what documentation should we keep for the ESSER II claims?

-Function Code

-Object Code

-Site (Prek-8=Elementary; 9th-12th=Secondary)

-Detailed Expenditure Description

-Amount Claimed

-Upload Local Expenditure Report with Supporting Documentation

20. Do we contact our program specialist for questions about ESSER II?

No, the contact person for ESSER II is: Michelle Dunn, Executive Director of ESSER Funds Michelle.Dunn@sde.ok.gov 405-521-4514

21. Will paying teachers out of ESSER funds affect comparability?

No, ESSER funds will not impact a district’s Title I Comparability Report.

22. Do salaries and equipment have to be preapproved?

2 CFR 200.439 requires preapproval from the pass-through agency before purchasing Capital Expenditures & Equipment over $5,000.

23. What items that might be over $5,000 already have preapproval from OSDE?

Preapproved ESSER List for single items over $5,000:

-Yellow Route Bus for social distancing

-Sanitization equipment for cleaning

-School building sound system

-Industrial Floor Cleaning Machine

-HVAC Unit replacement for better air quality

-Air purification system for better air quality

-Server upgrade due to distance learning

-Copier due to distance learning packets

-Security Camera systems for contact tracing

-Suburban, Pickup Truck, or Car for delivery of meals, distance learning packets, books, computers to students

-Window replacement for better air quality

-Utilities such as electricity and water due toCOVID-19

-Property/Liability insurance due to COVID-19

-Replacing carpet with tile for better cleaning

24. What are some tips for preparing an ESSER claim?

-Claim dates must begin with the first day of the first month claimed and end with the last day of the last month claimed.

-Claims may be submitted no more than 10 days prior to the end of the month.

-A Purchase Order must pre-date a purchase or service, and an invoice date must be on or after the date of the purchase or service. The warrant (check) must be paid after the purchase or service is complete.

25. What are some unique and dynamic uses of ESSER funds that have been approved?

-One district is repurposing space to prevent the spread of COVID-19 by social-distancing and upgrading flooring to prevent the spread of COVID-19 with a better surface for sanitizing. The cafeteria seating was expanded into the remodeled library with greater room to spread tables apart. The library is being moved into the previous STEM Lab which is the next largest room in the building. The STEM Lab is being placed in an available classroom.

-Lockers were purchased to prevent the spread of COVID-19 by increasing available space for PE classes to social distance while dressing before and after class.

-Hallways were widened to prevent the spread of COVID-19 by increasing air flow and socialdistancing. Unneeded lockers were removed, and walls repaired. All textbooks were purchased in the online version for students’ Chromebooks to mitigate the learning loss in response to COVID-19; thus, eliminating the need for lockers.

-Outdoor learning spaces have been created with covered areas and walk-ways, greenhouses, fitness stations and playground equipment to prevent the spread of COVID-19.

-Magnificent summer programs have been planned with programming to mitigate the learning loss, accelerate learning, provide social emotional learning activities, and reclaim the school culture in response to COVID-19.

-Band instruments have been purchased to prevent the spread of COVID-19 by not sharing instruments.

For any questions on ESSER funding, contact Kathy Dunn at federalprograms@ccosa.org.