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 Overarching ESSA and IDEA Programs - School Closures

1.     We have regular, full-time employees paid with federal funds, e.g., Title I (teachers and paraprofessionals), Title II (2 teachers), IDEA, and School Nutrition.  May we continue to pay these employees their monthly salaries and benefits through federal funds? Grantees may continue to charge salaries and benefits to currently active Federal awards consistent with the grantees' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Grantees 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 requirement of records to substantiate the charging of any salaries and benefit costs related to interruption of operations or services.  At the same time, recipients should consider ways that employees paid with grant funds can support continuing activities, including distance learning opportunities for students served by the grant. 
2.     Will all hours have to be made up in order to use federal funds? (If the closures extend for a long time, this is going to be difficult with the fiscal year ending June 30. Though grant periods of performance end on September 30, we have found that most systems, like ours, conclude federal expenditures at the June 30 mark to align with the Georgia DOAA reporting requirements.)

The process for making up time for your non-federally funded employees should be followed for the federally funded employees.


3.     Besides the time log signed by the supervisor, is there any other documentation needed for the teachers or other staff to illustrate that they are working their mandated number of hours for payment with federal funds?Grantees must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 -Financial management and 2 CFR § 200.333 -Retention requirement of records to substantiate the charging of any salaries and benefit costs related to interruption of operations or services. 
4.     Do you know if there are plans to extend the grant funding period of availability given that the school closures impact our ability to carry out services and supports under ESSA and IDEA?GaDOE will extend awards which were active as of March 31, 2020 and scheduled to expire prior or up to December 31, 2020 (FY19 funding), automatically at no cost for a period up to twelve (12) months. This will allow time for grantee assessments, the resumption of many individual projects, and a report on program progress and financial status to be completed and submitted. Project-specific financial and performance reports will be due 90 days following the end date of the extension.  FY20 funds will continue to be available for the duration of the 27-month period of availability (July 1, 2019 to September 30, 2021). 
5.     How should districts handle situations in which travel arrangements, using federal funds, had been finalized to attend conferences and other events that are now canceled, and refunds are not provided for the registration fees, air fares, or hotels?  What do we do if refunds were provided but are in the form of vouchers for future use in the employee's name?GaDOE, using the guidance outlined in the Office of Management and Budget's memorandum dated March 19, 2020, will allow districts that incur costs related to the cancellation of events or related travel to charge these costs to their award.  Provided that a grantee or subgrantee first seeks to recover nonrefundable costs (e.g. travel, registration fees) associated with an ESEA grant from the relevant entity that charged the fee (e.g., airline, hotel, conference organizer).  Districts should not assume, however, that additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel.   Districts must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 -Financial management and 2 CFR § 200.333 Retention requirement of records, to substantiate the charging of any cancellation or other fees related to interrupted events or associated travel.  Also, Districts must follow 2 CFR Part 200 Subpart E of the Uniform Administrative Requirements, Cost Principles, And Audit Requirements for Federal Awards. 
6.     How should LEAs handle Time and Effort documentation?For annual or semi-annual certification, Time and Effort may be reported after the fact by someone with knowledge of the work performed. Therefore, Time and Effort may still be reported. If LEAs certify work performed on federal grants later than it would normally occur, at an appropriate time, ensure that local procedures reflect the change. 
7.     When may LEAs submit the last budget amendment?Budget amendments may be submitted until the end of the grant period which is September 30th for ESSA and IDEA, unless an extension is provided (see #4 in this section). See page 58 of the Federal Programs Handbook. 
8.     If LEAs are seeking additional flexibility to support students through internet services, hotspots, and remote learning, and wish to transfer Title II, Part A and/or Title IV, Part A in order to do so, can they?

Yes. ESSA section 5103 allows LEAs to transfer Title II, Part A and Title IV, Part A into other grants that may extend to LEAs increased flexibility.


In LEAs where equitable services are currently being provided through Title II, Part A and Title IV, Part A, LEAs should be reminded that ESSA Section 8501 requires LEAs to consult with private schools on the amount of funds available for equitable services. If a district should choose to transfer mid-year, this would impact the amount of funds available for equitable services and would thus require LEAs to notify private school officials.


As per USDE guidance and the Title IV, Part A Handbook, infrastructure can be budgeted in conjunction with activities supporting well-rounded educational opportunities, safe and healthy students and professional development for the effective use of technology if the device(s) is clearly and directly connected to and required to facilitate the explicitly identified program/intervention/activity and does not address inventory and/or readiness shortfalls. Details conveying this information must be included in the description narrative box on the budget form in the Consolidated Application portal.  For example, in the event that the LEA identifies and prioritizes needs to provide internet access to rural, remote and underserved students that do not have access to direct instructional content required to meet performance standards, such required resources/materials may be identified under the focus area of providing well-rounded educational opportunities (WR).

9.     What are the inventory management procedures we should follow now that we have purchased equipment to support online learning?Chapter 6 of the Federal Programs Handbook addresses inventory management.  In the section on equipment management, you will find information for LEAs aligned to the Code of Federal Regulations (2 CFR 200.313 and 34 CFR 81.31c).  LEAs should review their procedures to ensure they are following what is written.  If changes are needed, now is a good time for revisions.  See chapter 6 of the Federal Programs Handbook. 
10.  What is required if online learning equipment purchased with federal funds is lost, damaged, or stolen?

·      LEAs should follow their written procedures.

·      State requirements are established by DOAS. Federal requirements are set by 2 CFR 200.313 and 34 CFR 81.31. GaDOE provides further guidance in chapter 6 of the Federal Programs Handbook.

·      LEAs should review their procedures to ensure they are following what is written.  If changes are needed, now is a good time for revisions. 

·      At a minimum, an investigation (which may be formal or informal) needs to occur and the results must be included on the LEA's inventory management document/ log.  (A police report for items reported as stolen is not required unless the LEA's written procedures require it.)

11.  If a grantee or subgrantee is planning future travel under an ESEA grant, 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. 
12.  Under the new flexibilities GaDOE said that the Title I, Part A 15% carryover limit was waived. Does this flexibility include 21st CCLC funds?Yes, this flexibility will apply to 21st CCLC FY20 funds only. 
13.  Do you know when our FY21 preliminary state and federal budgets and allocations will be given to LEAs?The general assembly session has not reopened so we do not have FY 2021 QBE estimates.  We do not have a timeframe of when to expect those estimates. FY21 ESSA allocation projections should be available in the coming months. 
14.  If an LEA chooses CLIP option 1, will LEAs receive a FY21 allocation of funds to combine with FY20 carryover funds?Regardless of CLIP Options, all LEAs will have access to FY20 funds and FY21 funds. 
15.  Is there a cutoff date for FY20 budget amendments in the Con App?While we ask LEAs to make amendment updates throughout the year and as early as possible, there is not currently a hard and fast deadline for amendments. 
16.  Since FY20 funds will be available through September 2021, will the Ed-Flex waivers apply to FY20 funds through then?There are flexibilities granted outside of the EdFlex waivers through the CARES Act and flexibilities afforded through EdFlex waivers. Both flexibilities will be granted for the length of the availability of applicable funds:  CARES Act applies to FY20; EdFlex will apply to FY21 and moving forward. 
17.  What is the definition of professional development now that the definition under ESSA has been waived?The original definition of PD required 'sustained, job-embedded, classroom focused.... PD', however, at this time we recognize the value of stand-alone PD for needs like online instruction or sanitation practices for schools. GaDOE recommends that, whenever possible, LEAs provide high quality PD aligned to student and staff needs and follow best practices for monitoring the effectiveness of the PD. 
18.  What would be the advantage of extending fiscal year with funding if we can carry over any unused funds?This flexibility extends the total period of availability of current funding including FY19 which was originally set to expire on 12.31.2020.  Now, these FY19 funds (LEA's current carryover in FY20) will be available through 12.31.2021. 
19.  Will carryover limitations be relaxed?Most federal funds do not restrict carryover. You can reference the Federal Programs Handbook for a comprehensive list of carryover restrictions. Title I, Part A carryover limits have been waived for 2019-2020 under recently granted flexibilities. FY20 21st CCLC carryover fund limits have been waived.  In addition, we anticipate the ability to waive carryover limits under Georgia's Ed Flex application for FY21 and moving forward. 
20.  Will FY21 monitoring be affected (postponed, canceled, etc.)?At this time, we do not anticipate that FY21 cross-functional monitoring will be impacted. 
21.  If being monitored in FY21, would a LEA need to use the FY21 CLIP instead of cloning?No. All LEAs have the option to clone the FY20 CLIP or create a new FY21 CLIP. The selection of either option is at the LEA's discretion. 
22.  Do we have to pay for contracts for work that has not been completed?Section 18006 of the CARES Act requires entities that receive Elementary and Secondary School Emergency Relief Funds to continue to pay contractors to the greatest extent practicable. GaDOE encourages LEAs to consult with their General Counsel and ensure their local emergency plan is followed and that appropriate documentation is maintained. 
23.  Will LEAs submit a new prayer certification and GEPA documents in ConApp for FY21?Yes  
24.  Is Consolidation of Funds still an option for Cohort 5?Absolutely! We know that the flexibility afforded by Consolidation of Funds will be even more critical in the coming school year. Please reach out to Carly Ambler 
25.  Will there be an opportunity for consolidated districts to discuss next steps or should we contact the Consolidation of Funds program office directly?Right now, we do not have any update sessions planned for Cohorts 1-3. We will have a virtual session with Cohort 4 and more than likely have a virtual session with Cohort 5. 2020-2021 CoF participation forms were sent to LEAs a couple of weeks ago with instructions for referencing updated templates. Any consolidating LEA is welcome to reach out to Carly Ambler to discuss next steps. 404-623-9599 
26.  Will LEAs receiving Title I Section 1003 School Improvement funds be allowed to amend their current justification of expense to meet their changing needs?

Yes. School and District Effectiveness will provide an updated timeline for when justification of expenses are due based on the extension of funds.










27.  Can an LEA use federal funds to purchase hotspots and access to wireless internet for students?

Purchase of internet hotspots and wireless internet access is an allowable use of federal funds with the following considerations:

·       The LEA has determined that the purchase is connected to the needs identified in the Consolidated LEA Improvement Plan (CLIP).

·       The LEA has determined that the purchase directly benefits the purpose of the grant (allocable) and only the eligible participants served by the grant.

·       The LEA has determined that the purchase is cost effective (reasonable and necessary).

·       The LEA has a plan for monitoring the dissemination of the equipment and ensuring the internet access is secured with passwords or other safety features to ensure use adheres to purpose of the grant, to the extent practicable.

·       The LEA has included these items on the inventory log.

The LEA should maintain this documentation on file for monitoring purposes.


·       When budgeting, the equipment and wireless internet access must be separated by these budget codes:  equipment 1000;615 or 1000;611 and access 1000;530.

·       When budgeting, add general narrative explaining purpose.