Guidance on ESSER Funding

One of the pressing questions regarding ESSER money is when it will be allocated. The common logic of the money being 2.4 times the original ESSER money has not been established yet but is causing anticipation. It is important to remember that until we see the actual amount of revenue per school, this is all supposition and should not be included in budgeting decisions.

And then another twist occurred on the road to ESSER. The Biden administration recently promulgated an interim rule that requires reopening plans address mask use and appropriate social distancing for schools to receive any form of revenue. The attention to learning loss will continue to be a major issue as we reopen schools. The template being used for states to apply for the funds is listed below:

• Current status and needs: The state must outline successful strategies it has identified, priorities for future spending along with the data to support them and priorities for supporting “underserved students”--those who are homeless, students with disabilities and English language learners.
• Assessing the pandemic’s impact: States must describe what data and strategies they will use to assess the impact of the pandemic— and resulting lost instructional time— on students’ academics, social and emotional well-being and mental health. They must also detail how they will measure progress in meeting new goals related to pandemic relief.
• Tracking operating status: States must explain what data they track on enrollment and attendance and whether or not schools are operating in person. They must also detail, to the extent possible, what instructional model schools in their state plan to use in the 2021-22 school year.
• Coordinated use of funds: Plans must detail how states and districts have used or plan to use previous relief aid provided through the CARES Act and how they will coordinate it with new aid and other federal funds.
• Supporting targeted uses: State plans must detail how they will meet the ARP’s requirements to target portions of aid to address lost learning time, support summer learning & after-school programs and address emergency needs.
• Workforce issues: Plans must explain how funds will be used to support educators, address teaching shortages and hire staff to address students’ social and emotional needs.

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Our guidance remains as before:

• Carefully evaluate the number and necessity of both professional and support employees.
• Complete a student census and determine the number of students who will most likely attend the LEA in FY 2022.
• Determine the grade weights available from the projected student census number.
• Move professional and support staff to the appropriate levels prior to budgeting ESSER funds.
• Be transparent about future policies and precautions related to COVID infections.  
• Prepare a list of prioritized spending for ESSER money to maintain budget discipline.

The long-term implications of learning loss and other areas affecting student instruction will require extra revenue, and ESSER will help with this. But remember, this is not an endless pot of money. Once it is gone, it cannot be replaced. Be overly cautious to protect the LEA budget from future shortfalls in State Aid. We listed the source documents for this article in the links below:

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American Rescue Plan Elementary and Secondary School Emergency Relief: Office of Elementary and Secondary Education

Federal Register: American Rescue Plan Act Elementary and Secondary School Emergency Relief Fund

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I've built the areas below from discussions, questions and work within our team. Our goal is to give you areas to start your budgeting for the next round of ESSER. Since the rules for ESSER money have been promulgated in the federal register, we could see the allocations coming out sooner rather than later.  

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1. Building and other equipment upgrades

ESSR and FEMA funding can be used for modifications to building systems and transportation systems to alleviate concerns about virus transmission through close contact or a closed-loop air system. Be cautious here: this portion of the funds can cause an issue with capital improvements and may require permission from the State Board of Education to displace other funds used for building maintenance.

Remember, any major change we make to a building may legally require the services of architects on the project's fundamental design and safety requirements to satisfy the fire marshal. You do not want to find yourself having to change items due to an oversight the fire marshal finds. ESSER money is not designed to flow through the building fund like impact aid; you have to spend this money out of the General Fund. If you are doing a project using your building funds to accomplish, the building fund money is not reimbursable.

2. Careful salary funding

With the passing of HB2078, there is the natural inclination to count on the ESSER money to allow for the current LEA staffing.  If an LEA has lost population, we advise you to determine if current salary and burdens are appropriate for the student population. Using a population census system to determine an LEA's overall needs is the only method to determine if the district is properly staffed. If an LEA is spending over 80% of its expenditure budget on salary and burdens, there could be a future financial issue looming. If the total expenditures are over 90% of revenues, there could be a problem looming. We advise you adjust staffing through a RIF or discontinuation of temporary staffing or at-will staffing to properly size the salary and burden load on the budget.  

ESSER money should not replace Title I, Title II or IDEA funding. If you are already using Title funds to pay salaries, examine where you may be able to strategically place the ESSER funds to allow you to most effectively use the ESSER funding. It is a good idea to deploy ESSER funds to address learning loss. The documentation on ESSER may require you prove why you are using ESSER funds in the manner the LEA has chosen.

One final point in this area is to determine your ADM and what grades have been lost and probably won’t be recovered. If an LEA is aware of students who have left the LEA due to COVID, we strongly encourage visiting with parents about their future intentions. Don’t assume when FY22 starts, the students who have left the district for outside education services will automatically return. There are several studies indicating 30% to 40% of students who left their LEAs of origin may not return. It is in the LEA’s best interest to determine the number of students who do not intend to return. These are hard contacts to make, but it is the only way the LEA will know for certain what ADM to plan for in the coming fiscal year.

3. Maintenance of Effort does apply

• Under the CARES Act (section 18008), there is a state MOE requirement for each fiscal year (2020 and 2021) based on dollar levels of state support for education. If the MOE is not maintained, there could be harmful effects on future federal funding.
• Under the CRRSA Act (section 317), there is a state MOE requirement for FY22 (based on percentages of the state’s overall spending used to support education).
• Under the ARP (section 2004(a)), there is a state MOE requirement for FY22 and 23 (based on percentages of the state’s overall spending used to support education).
• Source: https://oese.ed.gov/files/2021/03/FINAL_ARP-ESSER-FACT-SHEET.pdf

4. Addressing learning loss

One of the primary areas of focus in ESSER is to mitigate learning loss. The restart of school, protection of staff salaries, the mitigation of virus supplies and services for a safe learning environment will all ultimately resolve around mitigating learning loss. The only way to determine this is through a progressive and consistent benchmarking system like NWEA or comparable benchmark.
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ESSER money does not have an academic accountability component yet, but you should prepare documentation showing you used the funds to diagnose and correct learning loss. The older forms of benchmarking tools won’t give a progressive learning curve in each quarter. We are in a position that will require us to examine our education delivery systems, and the only way an LEA can accomplish this is to have valid benchmarks moving forward. Our position has also changed in that we see the public beginning to demand more out of our teachers and their instructional patterns. Carefully evaluate learning loss, but don’t depend on pre-pandemic methods to accomplish desired results unless you were already using a progressive benchmark. Whatever you are using, set the program’s parameters and be consistent in your
use of the benchmarking tool. Benchmarking does not work without fidelity in use.