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21st Century Community Learning Center

Frequently Asked Questions

The following guidance addresses Nita M. Lowey 21st Century Community Learning Centers (21st CCLC) program operations during school closures resulting from the COVID-19 pandemic.  Please note that this guidance may be updated and revised based upon any additional direction provided by the U.S. Department of Education (USDE).

Topics: Data and Reporting |Fiscal Questions |Professional Development | Programming and Recruitment | Staff Coverage

Page last updated: 8:30am on April 22, 2020

Staff Coverage

How will PDE provide guidance to grantees during the COVID-19 response effort?

The Pennsylvania Department of Education (PDE) will hold Zoom sessions to provide grantees with updated guidance as new information becomes available. Grantees will be notified via email when these Zoom sessions are scheduled.

Can the 21st CCLC programs pay staff, including part-time staff, while the program/schools are closed due to the COVID-19 response effort?

Yes. Programs may continue to pay staff from 21st CCLC funds during any pandemic related closure, provided the following conditions are met:

  • Grantee policies and procedures regarding payment of staff from all funding sources, federal and non-federal, during "extenuating or unprecedented" circumstances permit such payment. Records and documentation must be maintained to substantiate costs.

  • If a grantee or subgrantee does not currently have a policy that addresses staff compensation during "extenuating or unprecedented" circumstances, the grantee or subgrantee may amend or create a policy in order to put emergency contingencies in place, so long as the policy is consistent for all funding sources.

  • Staff who are teleworking in accordance with established written policies must maintain time and effort records to document time spent working on cost objectives related to federal grants. 

    • A grantee and subgrantee must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 (financial management), 2 CFR § 200.430(i) (standards for documenting personnel expenses), and 2 CFR § 200.333 (retention requirements for records) to substantiate the charging of any compensation costs related to interruption of operations or services.

    • 21st CCLC grants may only be used to support activities and cost objectives related to the intent of the 21st CCLC grant program. If an employee's job duties have temporarily changed or shifted due to COVID-19 response efforts, their salary may not be allowable or allocable to a federal grant.

  • Employees who are teleworking and who had former permanent set schedules may no longer be working those same schedules. If current work and time schedules have changed, time and effort records should indicate such changes during the closure to document proper use of federal dollars.

Allowable work may include:

  • Virtual staff/student meetings (telephonic conference calls, Zoom meetings, Skype, etc.);
  • Virtual educational group work and curriculum work (must be specific to the 21st CCLC program);
  • Online professional development specific to the 21st CCLC program;
  • Systems work (e.g. summer program planning, evaluation, sustainability, safety, budgeting);
  • 21st CCLC data entry/validation; and
  • Other expectations and associated job tasks listed in job descriptions that are reasonable and necessary during the closure period.

Programming and Recruitment

Can grantees offer programs virtually, while schools are closed due to the COVID-19 response effort?

Yes. Grantees may offer programming virtually in accordance with established written policies consistently applied to federal and non-federal activities.  Programs must continue to keep time and effort records and properly document the use of federal dollars for services provided virtually. Any 21st CCLC program services provided must be supplemental and cannot supplant regular school instruction.

As further closure announcements are made, this question will be revisited an updated if necessary. 

Under the 21st CCLC program, can grantees provide services during the school day if schools are closed?

The Nita M. Lowey 21st CCLC program provides students attending low-performing schools opportunities for academic enrichment through a broad array of additional services during “non-school hours or periods when school is not in session (such as before and after school or during summer recess)” per section 4201(b)(1)(A) of the Elementary and Secondary Education Act of 1965 (ESEA). Therefore, a 21st CCLC program may provide services to students before school, evenings, weekends, holidays, summers, or other school vacation periods.

While schools are closed due to the COVID-19 pandemic, a grantee could offer programs that supplement the local education agency’s continuity of education plan, as long as the 21st CCLC programming is offered outside of the schedules outlined in the local continuity of education plan(s). If the subgrantee chooses to proceed with programming during the COVID-19 school closures, there may be a need to amend the approved application to account for this change. In order to make this amendment, please contact your PDE program officer.

Does online programming count toward required attendance, and if so, how should it be calculated?

Yes, as long as the grantee establishes an attendance protocol and discusses how to proceed with their PDE program officer prior to implementing the online programming.

Can grantees extend virtual programming to students who are currently not registered but meet the registration requirements?

No. During the COVID-19 response effort, virtual programming is limited to currently registered students.

Can programs enroll new students during this closure period?

No. Student recruitment cannot occur for the current programming period until after the COVID-19 response effort and normal program operations resume. Programs should be serving the number of unduplicated students outlined in your approved narrative.

Can programs recruit for upcoming summer programming?

Yes. Programs may continue to recruit for the upcoming summer programming. Further guidance on summer programming will be provided if the pandemic response should extend into the summer.

Are grantees allowed to distribute educational materials supporting virtual activities to students so that they can participate in programming?

Yes. Grantees may distribute educational materials to students so that they can participate in virtual programming. However, for the safety of staff and students, grantees must follow COVID-19 safety protocols. Grantees may distribute educational materials for virtual programming at approved food distribution sites. 

May grantees use 21st CCLC transportation funds to distribute educational materials to students’ homes? 

Yes. Grantees may use transportation funds to deliver educational materials to participating students’ homes if the 21st CCLC grantee allows its employees to make deliveries to students. Any decision to permit delivery must be made following COVID-19 protocols and in keeping with any order of the Governor. Grantees must get prior approval from the PDE program officer because a budget revision must be completed prior to any such use of transportation funds. 

Some students enrolled in credit recovery do not have personal laptops. Can these students use laptops purchased by the 21st CCLC program to complete coursework while schools are closed due to the COVID-19 response effort?

No. Laptops may only be used at the 21st CCLC location and not loaned to students. Programs should develop alternative methods for students to access and complete credit recovery coursework consistent with available options for credit recovery.

Can programs extend summer camp hours and/or weeks to supplement the time students were out of school, due to the COVID-19 response effort?

Yes. However, this would constitute a program change, which would require approval and should be discussed with your PDE program officer.

If a program does not offer summer camp (it was not written into the grant), can the program be extended to the weeks after the school year concludes to supplement the time out of school?

Possibly. In order to consider this as an option, you would need to work with the school district. Additionally, since this is a program change it would need to be discussed and approved with your PDE program officer.

Data and Reporting

How will the COVID-19 closure affect data collection, particularly testing score requirements (PSSA scores) and evaluator reports? 

The General Assembly passed legislation that allowed the Secretary of Education to waive all state assessments for the 2019-20 school year. Therefore, grantees will only be required to report the information that is available. PDE will make reasonable and fair accommodations regarding 21st CCLC goals and evaluator reports.

Will there be any kind of adjustment on the quarterly report period or expectations for attendance for the quarter?

No. Quarterly reporting requirements remain the same. 

Should teacher surveys be revised, and if so, how?

There are no changes to teacher surveys.

Professional Development

What online professional development opportunities are available to grantees?

Below are online resources and professional development opportunities available for 21st CCLC staff:

Please be aware this is not intended to be an exhaustive list. Grantees should pursue the professional development opportunities based on the needs of program staff. Grantees should submit their selected professional development opportunity to their PDE Program Officer for review using the professional development form, prior to participating.

What is You for Youth (Y4Y) and how does it pertain to 21st CCLC programming?

Y4Y is the entity that provides technical assistance and professional development to the 21st CCLC programs across the nation. Please go to the You for Youth (Y4Y) website where you will find multiple trainings online.

Can programs submit budget revisions that allocate more money to professional development?  Will this negatively impact the Risk Assessment?

Yes, programs can submit budget revisions. However, grantees must submit their budget proposal to their PDE Program Officer and receive approval, before proceeding. If approved, this will not impact the Risk Assessment.

Fiscal Questions

May grantees revise their budgets to reallocate funds to other areas, due to the COVID-19 response effort?

Yes. Grantees may submit budget revisions. Grantees should continue to follow the existing budget revision guidelines.

What are the allowable costs during the closures? Can budget revisions be submitted to align with any new guidance?

The only allowable costs are those identified in your approved budget. Grantees may submit budget revisions to match current needs. 

Should programs continue to submit monthly expenditure reports? If the business office is closed and unable to run payroll, how long can programs extend expenditure reports?

Grantees are expected to continue to submit monthly expenditure reports. Extensions may be provided considering office closures. Any request for an extension should be submitted to your program officer.

Will the end date for Cohort 10 year 1 (C10Y1) be extended past June 30, 2020? Will budget revisions and continuation deadlines for C10Y2 be extended?

No. Budget years and deadlines will remain the same.

Are funds able to carry over?

No. Funds will not carry over. Unused funds must be returned. 

Is there a penalty for not expending grant money by the end of the current cohort year?

No. There is no penalty for unused funds. However, any unused funds must be returned.

Can programs purchase supplies for summer programs that are being planned for after the June 30, 2020 Year 1 end date?

Yes. Grantees may purchase supplies prior to June 30, 2020 for Cohort 10 year 1.

Can programs use funding to cover the cost of training(s) for teachers and staff to learn how to utilize online platforms? 

Yes. Funds can be used to train teachers and staff on existing virtual platforms owned by the entity.

Is there a form/template to document staff hours and work? 

Grantees should continue to utilize the same forms and templates used prior to the pandemic to document time and effort for staff hours and activities in order to demonstrate compliance with federal law. 

Are teachers who are being paid by the school district during the closing expected to continue to work and receive payment through 21st CCLC? 

Teachers may not be required to or may be unable to work while schools are closed due to the COVID-19 response effort. However, teachers may be utilized and paid for additional 21st CCLC work conducted outside of the normal school day via telework or online in accordance with established policies. 21st CCLC funding may not be used to supplant regular school hours or activities.

Are community partners and external evaluators able to continue their work virtually and receive compensation?

Yes. Community partners and external evaluator may be compensated for doing 21st CCLC work remotely. Partners must continue to maintain time and effort records.

Will there be any kind of adjustment on quarterly spending requirements? 

Report expenditures as they are incurred. The requirement for quarterly spending will be waived while programs are not in session.

If rent is paid from the grant, can we continue the payment?

Yes, payment can continue for payment of rent.

If a conference, training, or other activity related to a grant from the Department is cancelled due to COVID-19, may grant funds be used to reimburse nonrefundable travel (e.g., conveyance or lodging) or registration costs that were properly chargeable to the grant at the time of booking?

Yes, provided that a grantee or subgrantee first seeks to recover nonrefundable costs (e.g., travel, registration fees) associated with a grant from the Department from the relevant entity that charged the fee (e.g., airline, hotel, conference organizer). Some businesses are offering flexibility with regards to refunds, credits, and other remedies for losses due to the pandemic. Moreover, many agreements or contracts for conferences, training, or other activities related to a grant contain an emergency or “act of God” provision; the grantee and its subgrantees must seek to exercise those clauses to the extent possible.

If a grantee or subgrantee is unable to recover the costs, the grantee or subgrantee may charge the appropriate grant for the cancellation costs, provided the costs were reasonable and incurred in order to carry out an allowable activity under the grant, consistent with the Federal cost principles described in 2 CFR Part 200 Subpart E of the Uniform Administrative Requirements, Cost Principles, And Audit Requirements For Federal Awards (Uniform Guidance).

Grantees and subgrantees should not assume additional funds will be available if the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel. Grantees and subgrantees must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 (financial management) and 2 CFR § 200.333 (retention requirements for records) to substantiate the charging of any cancellation or other fees related to the interruption of operations or services.

If a grantee or subgrantee is planning future travel under a grant from the Department, may it purchase travel insurance with grant funds?

Due to health concerns related to COVID-19, grant-supported travel generally should not be occurring. However, if travel is permitted by Federal, State, and local directives and is the only means to carry out an essential grant function that must be undertaken on a time-sensitive basis during the COVID-19 pandemic, consistent with the grantee’s or subgrantee’s travel policy, travel insurance is allowable provided the cost is reasonable and allocable to the grant consistent with the Federal cost principles described in 2 CFR Part 200 Subpart E of the Uniform Guidance.