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ESSER/GEER Extra, Volume 8

This week's volume of ESSER/GEER Extra includes: the top 10 most common allowable uses of ESSER I and ESSER II funds; information from the U.S. Department of Education (USDE) concerning the use of ESSER funds to directly pay cyber charter school tuition costs; USDE guidance on school facility upgrades, renovation, and construction; clarification about when prior approval is needed for certain purchases; hiring incentives as allowable uses of ARP ESSER funds; and a reminder that ARP Homeless Children and Youth funds are available to eligible LEAs.

All editions of ESSER/GEER Extra are archived on PDE's website.

REMINDER: ARP ESSER Application Deadlines
There are three separate ARP ESSER applications, and their titles in eGrants, as well as the applicable deadlines, are below:

  1. 90% of the total ARP ESSER allocation. eGrants application titled: American Rescue Plan—Elementary and Secondary School Emergency Relief Fund (ARP-ESSER)); no deadline for application
  2. School district and charter school ARP ESSER set-aside. eGrants application titled: ESSER Fund ARP ESSER 7% Consolidated; LEA deadline for application is November 29, 2021.
  3. Other LEA ARP ESSER set-aside. eGrants application titled: ARP ESSER Set Asides Consolidated; no deadline for application

Top Ten Uses of ESSER I and ESSER II Funds
With nearly all eligible LEAs approved to receive their ESSER I and II funds, PDE has compiled the most common planned fund uses. While there are similarities in the most common approved uses across both funds, the progression of the pandemic, and the differences in allowable uses between funds, generated some distinctions.

ESSER I ESSER II
1. Purchasing educational technology1. Purchasing educational technology
2.  Purchasing supplies to sanitize and clean
2. Other activities that are necessary to maintain operations
3. Other activities that are necessary to maintain operations3. Planning and implementing activities related to summer learning
4. Any activity authorized by the ESEA of 19654. Addressing learning loss among students
5. Planning for and coordinating during long-term closures5. Purchasing supplies to sanitize and clean
6. Providing principals and others school leaders with the resources they need6. Projects to improve the indoor air quality in school facilities
7. Providing mental health services and supports for students and staff7. Providing mental health services and supports for students and staff
8. Planning and implementing activities related to summer learning8. School facility repairs and improvements
9. Training and professional development9. Providing principals and others school leaders with the resources they need
10. Activities to address the unique needs of low-income children10. Planning for and coordinating during long-term closures

ARP ESSER Funds Cannot Be Used to Cover Increased Cyber Charter School Tuition
Many school districts have asked PDE if ARP ESSER funds could be used to pay cyber charter school tuition increases resulting from the pandemic. USDE has informed PDE that ESSER funds may not be used to directly pay charter school tuition, because it is not an allowable use of funds under the ARP Act and does not constitute an obligation under 34 CFR § 76.707. Notably, however, USDE advised that school districts facing shortfalls in other budget areas due to increases in charter school tuition, ARP ESSER funds can be used to cover those shortfalls where they represent an allowable use under section 2001(e)(2) and the expenditure meets all components of the three-part test for allowability (i.e., an allowable use under the ARP Act; the expenditure assists the LEA with preventing, preparing for, or responding to COVID-19; and the expenditure is reasonable and necessary under Uniform Guidance). For example, if an LEA commits to paying a certain number of staff but then, due to the number of students who enroll in a cyber charter school due to COVID-19, the LEA has insufficient State funds to pay those staff, the LEA may use ESSER funds to meet that obligation.

USDE Provides Guidance on Facility Upgrades, Renovations, Construction
Earlier in September, USDE released guidance for LEAs on the use of ARP ESSER funds for school facility upgrades, renovation, and construction. The guidance discusses the available facility-related allowable uses, walks through the USDE FAQs on renovation and construction, and highlights the prior approval process. The guidance also includes information about achieving energy efficiency on projects to improve indoor air quality. Access the USDE facility guidance. Access a recording of the USDE presentation on facility guidance. 

Is prior approval needed if the total amount for several pieces of equipment exceeds $5,000?
No. The prior approval requirement applies to capital expenditures and equipment purchases that exceed a per unit cost of $5,000 (see 2 C.F.R. § 200.439 (b)(2)). Therefore, if an LEA is purchasing multiple pieces of equipment that cost less than $5,000 each, prior approval is not required. 

Can an LEA use ARP ESSER funds to provide hiring incentives for positions for which they are experiencing shortages?
Yes. Hiring of teachers (including substitutes), principals, aides, bus drivers, food service workers, school nurses, school social workers, school psychologists, school counselors, and many other positions have become significantly more difficult due to the pandemic. An LEA could include hiring or retention incentives as an allowable ARP ESSER expenditure, provided the LEA can show that the expense meets the three-part test for allowability of ARP ESSER funds (i.e., an allowable use under the ARP Act; the expenditure assists the LEA with preventing, preparing for, or responding to COVID-19; and the expenditure is reasonable and necessary under Uniform Guidance.)
 
ARP Homeless Children and Youth Funds
The ARP Act provided Pennsylvania with $24 million through the ARP Homeless Children and Youth (HCY) program to support both LEAs and the state's McKinney-Vento funded regional offices that serve homeless children and youth. Funds will be used to identify homeless children and youth, provide wraparound services due to the impact of the pandemic, and make it easier for homeless students to participate in school activities like in-person instruction and extracurricular activities. HCY funds are available for use from July 1, 2021, through September 30, 2024.

Seventy-five percent of these ARP-HCY funds will be distributed to LEAs based on an LEA's Title I-A allocation and the number of identified homeless children and youth served during the 2018-19 school year. The remaining 25 percent will be allocated to the state's eight regional McKinney-Vento offices. Access the list of eligible ARP-HCY grantees.

Applications are due October 16, 2021. For more information, including a Request for Application, visit PDE's ARP-HCY webpage.

Send Us Your Feedback!
Is ESSER/GEER Extra useful and responsive to your needs? Please send feedback, questions, and ideas for future editions to us via email: ra-edarpesser@pa.gov. And don't forget to send us your school entity's ESSER/GEER implementation successes so we can highlight them.