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 Title IV, Part B 21st Century Community Learning Centers (21st CCLC) - School Closures

1.     If 21st CCLC programs are closed, can staff continue to be paid? If so, under what conditions?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 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. 
2.     Can 21st CCLC programs operate virtually or other at-home enrichment programming in an effort to continue to serve students? Grantees may offer alternative enrichment programming in the absence of onsite programming. Note that sites must be able to document assigned staff time and effort, as well as ensure that such alternative programming is allowable under the terms and conditions of the existing approved grant. Consistent with grant regulations, such programming must operate outside of day school hours (if the school is offering virtual learning) and available to all participating children, to the best extent practicable. 

3.     Are subgrantees permitted to operate 21st CCLC programs during times that schools are closed?


All 21st CCLC subgrantees should adhere to internal guidelines established by their Local Educational Agency (LEA) or parent agency (non-LEAs) when establishing procedures for 21st CCLC program operation.


4.     Will 21st CCLC programs be required to implement make-up days as a result of extended school and program closures?21st Century Programs are encouraged to schedule make-up days to account for disruptions in program operations related to closures or schedule changes. We ask that programs make a good faith effort to reschedule hours that may be lost; however, GaDOE will not establish a requirement for make-up days given the potential impact of extended program closures.  
5.     How will school and program closures impact the federal and state reporting requirements for the 21st CCLC grant (US ED 21APR Data Collection, Teacher and Student surveys, Summative Evaluation Requirements)?Answer pending from US ED regarding 21APR data collection requirements. The timeline for other data collected by GADOE has not yet been updated, but flexibility is available for data that is not linked to federal reporting requirements. 

6.     Will 21st CCLC subgrantees be allowed to pay staff during the time that schools and programs are closed?


Yes. Georgia 21st CCLC programs may continue to pay staff for their efforts during program closures. All subgrantees should exercise good-faith efforts for developing alternate work strategies for staff during extended program closures. Staff should be assigned projects and activities related to program planning and aligned with approved grant objectives.  Subgrantees must maintain detailed work logs to document staff activity and should continue to pay employees in a manner consistent with established LEA or agency (Non-LEA) policies for program operation and employee compensation. Examples of allowable staff activities include:

·      Virtual Professional Development Sessions

·       Data Entry for Administrative Purposes 

·       Virtual Program Management Duties

·       Virtual Programming for Students

·       Lesson, Curriculum, or Evaluation Planning

·       Tasks deemed reasonable and necessary as associated with 21st CCLC job duties

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. However, there will not be additional 21st CCLC funds allocated to support additional staff requirements.



7.     May subgrantees conduct virtual 21st CCLC learning activities for students outside of normally scheduled hours of operation during extended periods of program closure?


All 21st CCLC subgrantees should adhere to the hours of operation detailed within the approved grant application. If, however, subgrantees are able to add additional hours to those in the approved grant, they may only add hours to make up those that have been lost due to the extended periods of program closure.  Any such additional hours should address the approved program goals and objectives and not overlap with or otherwise interrupt local school programming occurring during the regular school day.


8.     Do lesson plans developed by 21st CCLC staff count as "detailed work logs" for the purpose of providing documentation for compensation?

·      No. Lesson plans are not considered detailed work logs.                Detailed work logs provide an hour by hour breakdown of tasks that an employee completed in planning for, or delivering services to students, or participating in virtual professional development.

·      Lesson plans may be used to supplement time documentation. Another example of supplemental documentation includes detailed agendas outlining an hour by hour breakdown of professional development activities.


9.     How should 21st CCLC subgrantees plan to complete annual program evaluation requirements?

The Georgia Department of Education (GaDOE) recognizes that extended program closures have impacted the ability of 21st CCLC subgrantees to adhere to data collection deadlines. At this time, the US Department of Education has not waived data reporting requirements for 21st CCLC programs.


The GaDOE is still awaiting guidance regarding annual 21APR data reporting guidelines. 21st CCLC subgrantees currently operating virtual learning programs are requested to enter student program attendance data into the Cayen Data System.


Annual 21st CCLC Survey Data:

Where feasible, subgrantees are encouraged to administer annual 21st CCLC teacher, parent, and student surveys; however, additional guidance is pending regarding annual reporting requirements for survey data. 


21st CCLC Subgrantee External Evaluation Procedures: Guidelines have not yet been amended for annual external evaluation requirements. Additional guidance regarding procedures for external program evaluation is forthcoming. Extended program closures will likely impact timelines for external evaluations. Subgrantees are encouraged to maintain communication with designated 21st CCLC External Evaluators to ensure that updated guidance is shared when available.


10.  How should 21st CCLC subgrantees document attendance for virtual program activities?


Program sites that are serving students virtually should keep attendance records in the Cayen Data System. Subgrantees providing virtual programming should set up new sessions for each activity being offered and label each session “Virtual-Activity". Days missed due to extended program closures and lower average daily attendance totals will not negatively impact 21st CCLC subgrantees.


11.  Will modifications of program hours be considered for 21st CCLC subgrantees who provide virtual programming?Yes. Subgrantees may modify the number of hours provided to students engaged in virtual programming. Subgrantees are encouraged to contact their designated Education Research and Evaluation Specialist to discuss proposed modifications to program hours. Modified program hours should be consistent with 21st CCLC grant administration guidelines and should occur outside of day school hours.

12.  Are 21st CCLC subgrantees required to offer virtual programming for students?


21st CCLC subgrantees should adhere to established internal Local Educational Agency (LEAs) and agency (non-LEAs) guidelines for program operation when establishing schedules for virtual learning opportunities. Virtual learning activities should align with objectives outlined in the subgrantee's approved 21st CCLC grant application.


13.  Will onsite 21st CCLC summer programming be allowed?Due to the statewide school closures guidance regarding the allowability of onsite summer programming for 21st CCLC subgrantees has not yet been established. Subgrantees are encouraged to plan for virtual summer learning activities in accordance with approved internal agency policies when developing plans for 21st CCLC programming. (Please reference FAQ #3 above for additional guidance).
14.  Will the annual 21st CCLC subgrantee conference take place in July 2020?The annual 21st CCLC subgrantee conference will be held via virtual professional development sessions. Additional details regarding professional development sessions for subgrantees are forthcoming.
15.  Will carryover of FY20 funds be allowed?

The GaDOE will waive the annual 15% carryover percentage limitation for FY20 Title, IV, Part B – 21st Century Community Learning Centers (CCLC) subgrants.  21st CCLC subgrantees are permitted to carryover all unexpended funds from FY20 into FY21.