The Education Stabilization Fund and Governor’s Emergency Education Relief (GEER) Fund have provided funding to help with challenges faced by districts across the nation. When these funds were distributed and obligation dates were set, every district leader got to work creating a plan for these dollars. The biggest issue was the tight timeline to spend—with little time to plan. Now, district leaders are running across even more issues with spending down the dollars, some of which are required to be obligated by September of this year.
The Department of Education has given some grace in terms of liquidation, writing to AASA that “The Department has the authority to approve liquidation extension requests for properly obligated funds upon review of written requests made by the state educational agency (SEA). Should funds be properly and timely obligated—including the requirement a construction project meets the COVID-related purposes stated above—and liquidation becomes an issue closer to the obligation deadline, the Department has the authority to approve liquidation extension requests based upon the specific facts and circumstances of a given obligation and upon written request of an SEA grantee. If approved, grantees may have up to 18 months beyond the end of the obligation period, although requests for longer may be considered related to extraordinary circumstances. Under a liquidation extension, the delivery of goods and services may continue to be provided through the end of the liquidation period, so long as a timely and valid obligation had been made.”
Essentially, the Department of Education will allow funding to be spent past the original spend date; however, obligation dates have not changed. This means that obligation still has to follow the timeline, and there are more than a few challenges districts face as they race against the clock to get the dollars obligated on time.
Strict Spending Regulations
Michigan districts claim that the United States Department of Education has put strict spending regulations on their funds, while the Department stated that “the agency has not placed any restrictions on Michigan’s ARP funds other than the statutory and regulatory requirements placed upon all states as required by this legislation.” Whether the spending regulations are real or perceived, the uncertainty creates challenges.
Changing Funding Formulas
Because the stimulus funds weren’t already complex enough, the state of Tennessee also decided to change its funding formula entirely. In the 2022 legislative session, the governor signed a bill that would completely change the funding formula in the state. It will be very difficult for districts to understand how much they are getting and the amount of ESSER funds that will need to be obligated to which initiatives.
ESSER and GEER funds were not the only stimulus funds that could go toward education purposes and goals. The stimulus also includes city agreements and reimbursements to FEMA and other agencies that cause district decision-makers to wonder if they will get reimbursed in time to reallocate those funds for other uses.
Additionally, EdWeek also reported that the process for requesting those reimbursements is “full of thorns,” said Katie Gourley, business manager for the Bucksport schools in Maine. “Districts can only have one open request for reimbursement in the state’s online portal at a time. Each set of ESSER funds has a separate form that must be filled out.” On top of the slow reimbursement, the amount of paperwork is also a challenge when it comes to the obligation of funds.
Obstacles in Procurement
The GEER and ESSER funds have fairly loose guidelines on procurement processes, but it’s clear that district leaders will err on the side of caution when it comes to spending any federal funding. Many believe that a request for proposal is required when it technically is not. Given the especially close obligation deadline of the ESSER I funds, it simply is not doable to go through standard procurement procedures without risking losing all the funds allocated to the district.
What Should We Do?
With so many challenges when it comes to these funds, it’s important to think of things that make sense to spend the dollars on quickly. For many, this means investing in people. One of the best ways to help our leaders, educators, and students is to invest in their mental health needs. This is a high priority and a way to ensure that all available funds are obligated on time while providing support to your district.
Want to learn how you can maximize financial assistance for students’ mental health, SEL, and safety? Watch the recent Unmasking Funding Opportunities webinar recording to gain clarity on available funding opportunities, key deadlines and processes, and strategic guidance to use each source with the most impact for your district.