Forfeiting of Federal Grant Funding, Virginia Department of Education (October 31, 2025)
Summary
This October 31, 2025 letter from the Virginia Department of Education, on letterhead naming Emily Anne Gullickson, Superintendent of Public Instruction, is addressed to the chairs of the Senate Finance and Appropriations Committee and the House Appropriations Committee. It states that during State Fiscal Year (SFY) 2025 the Department returned funds to the U.S. Department of Education on behalf of fourteen school divisions that did not fulfill specific requirements under the Individuals with Disabilities Education Act (IDEA) grant, and that the total amount returned to the federal government was $1,063,431.14. It also states that three school divisions received formal communications for not meeting IDEA Maintenance of Effort obligations, resulting in a repayment of non-federal funds.
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Cite this document
“Forfeiting of Federal Grant Funding, Virginia Department of Education (October 31, 2025).”
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COMMONWEALTH of VIRGINIA
Emily Anne Gullickson, M.Ed., J.D. DEPARTMENT OF EDUCATION Office: (804) 225-2057
Superintendent of Public Instruction P.O. BOX 2120 Fax: (804) 371-2099
RICHMOND, VA 23218-2120
October 31, 2025
The Honorable L. Louise Lucas The Honorable Luke E. Torian
Chair, Senate Finance and Chair, House Appropriations Committee
Appropriations Committee Virginia General Assembly
Virginia General Assembly 201 North 9th Street, Room 123
201 North 9th Street, Room 1404 Richmond, VA 23219
Richmond, VA 23219
Dear Chairs Lucas and Torian:
Section 4-8.02.d.,Chapter 725, 2025 Acts of Assembly, contains the following reporting
requirement which states:
d. Any state agency that is required to return federal grant funding as a result of
not fulfilling the specifications of a grant, shall, as soon as practicable but no
later than November 1st, report to the Chairmen of the Senate Finance and
Appropriations and House Appropriations Committees of such forfeiting of
federal grant funding.
During State Fiscal Year (SFY) 2025, the Virginia Department of Education, in its oversight role
for Virginia’s Individuals with Disabilities Education Act (IDEA) special education grant,
returned funds to the U.S. Department of Education (USED) on behalf of fourteen school
divisions that did not fulfill specific requirements under IDEA. The source of the returned funds
was the school divisions’ flow-through IDEA formula subgrant. The total amount returned to the
federal government during SFY 2025 was $1,063,431.14. Each school division and their total
unspent funds are included on the table below.
The Honorable L. Louise Lucas
The Honorable Luke E. Torian
October 31, 2025
Page 2
LEA # LEA Name TYPE Award# Project Code Total Awarded Total Unspent Comment
IDEA-611 Forfeited; Reverted to US
0001 Accomack H027A220107 APE43071 $ 1,205,710.00 $ 8,060.96
Flowthrough Treasury due to expiration
IDEA-611 Forfeited; Reverted to US
0043 Henrico H027A220107 APE43071 $ 9,286,475.20 $ 4,556.73
Flowthrough Treasury due to expiration
IDEA-611 Forfeited; Reverted to US
0046 Isle of Wight H027A220107 APE43071 $ 1,176,276.00 $ 4.81
Flowthrough Treasury due to expiration
IDEA-611 Forfeited; Reverted to US
0115 Lynchburg City H027A220107 APE43071 $ 2,130,826.05 $ 1,000,908.94
Flowthrough Treasury due to expiration
Martinsville IDEA-611 Forfeited; Reverted to US
0116 H027A220107 APE43071 $ 627,197.00 $ 124.22
City Flowthrough Treasury due to expiration
IDEA-611 Forfeited; Reverted to US
0123 Richmond City Flowthrough- H027A220107 APE60033 $ 971,803.05 $ 33,671.63 Treasury due to expiration
CCEIS
Manassas Park IDEA-611 Forfeited; Reverted to US
0144 H027A220107 APE43071 $ 609,859.45 $ 15.35
City Flowthrough Treasury due to expiration
IDEA-619 Forfeited; Reverted to US
0046 Isle of Wight H173A220112 APE62521 $ 17,248.00 $ 3.65
Flowthrough Treasury due to expiration
IDEA-619 Forfeited; Reverted to US
0115 Lynchburg City H173A220112 APE62521 $ 68,390.00 $ 3,032.37
Flowthrough Treasury due to expiration
Martinsville IDEA-619 Forfeited; Reverted to US
0116 H173A220112 APE62521 $ 8,001.00 $ 185.72
City Flowthrough Treasury due to expiration
Portsmouth IDEA-619 Forfeited; Reverted to US
0121 H173A220112 APE62521 $ 190,573.00 $ 5,991.66
City Flowthrough Treasury due to expiration
IDEA-619 Forfeited; Reverted to US
0123 Richmond City H173A220112 APE62521 $ 137,634.00 $ 6,864.92
Flowthrough Treasury due to expiration
Waynesboro IDEA-619 Forfeited; Reverted to US
0130 H173A220112 APE62521 $ 17,877.00 $ 0.70
City Flowthrough Treasury due to expiration
IDEA-619 Forfeited; Reverted to US
0135 Franklin City H173A220112 APE62521 $ 16,077.00 $ 9.48
Flowthrough Treasury due to expiration
Total $ 16,463,946.75 $ 1,063,431.14
The Honorable L. Louise Lucas
The Honorable Luke E. Torian
October 31, 2025
Page 3
In addition, there were three school divisions—Essex County, Loudoun County, and
Northumberland County—that failed to meet the compliance requirements for Maintenance of
Effort identified during the 2024-2025 school year. Each of these divisions was determined to
have failed to comply with Maintenance of Effort requirements during the monitoring conducted
by the Virginia Department of Education. Essex County was determined to have not met the
requirements under Maintenance of Effort for SFY 2024. Loudoun County was determined to
have not met the requirements under Maintenance of Effort for SFY 2023 and SFY 2024.
Northumberland County was determined to have not met the requirements under Maintenance of
Effort for SFY 2024. Each school division has since returned the funds to the Virginia
Department of Education, which in turn returned the funds to the federal government as required.
MOE Compliance Concern Identified During SFY2024-2025 and paid in SFY2025-2026
LEA Name MOE Amount Repaid Comment
Essex $ 451,036.00 Ref: SFY2024
Loudoun $ 15,052,120.00 Ref: SFY2023
Loudoun $ 13,945,013.00 Ref: SFY2024
Northumberland $ 243,607.80 Ref: SFY2024
Total $ 29,691,776.80
The Virginia Department of Education has worked with the school divisions to implement
necessary corrective actions to fulfill the program requirements going forward. Additional details
regarding this forfeiture of funding are attached to this document.
There are no other forfeited federal grant funds resulting from failure to meet grant requirements
to report for SFY 2025.
If you have any questions or require additional information regarding this transmittal, please
contact me or Christina Berta, Chief Operations Officer, at (804) 225-2025.
Sincerely,
Emily Anne Gullickson, M.Ed., J.D.
Superintendent of Public Instruction
EAG/cb
c: The Honorable Aimee Rogstad Guidera
Virginia Secretary of Education
The Honorable Steve Cummings
Virginia Secretary of Finance
The Honorable L. Louise Lucas
The Honorable Luke E. Torian
October 31, 2025
Page 4
Attachment
Multiple School Division Grant Recipients
The information in the table represents school divisions that did not expend funds prior to the
expiration date. The Virginia Department of Education sends reminders throughout the life of the
grant through monthly or quarterly meetings via zoom. In addition, letters are sent to divisions
with unspent balances using a 90-day, 60-day and 30-day timeframe. Additional emails are sent
as the grant year approaches the end of the grant performance period, including phone calls for
those divisions with large unspent balances.
Maintenance of Effort of Local Education Agencies
The Virginia Department of Education is required by federal regulation to ensure all school
divisions in Virginia comply with the requirements of the Individuals with Disabilities Education
Act (IDEA) Part B, §300.203(b), which mandates that school divisions meet a Maintenance of
Effort (MOE) obligation. During SFY 2024-2025, three school divisions received formal
communications for not meeting their IDEA MOE Compliance obligations, resulting in a
repayment of non-federal funds. Prior to the determination of noncompliance, each school
division received extensive technical assistance via email, remote meetings and phone calls.
Additionally, each school division was provided with relevant IDEA regulations to assist with
determining allowable exceptions as defined under 34 CFR 300.204 and 300.205. The three
school divisions will receive either onsite or targeted intensive technical assistance during the
2025-2026 school year to review supporting documentation and to provide support to train
current staff and monitor compliance.
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