Idaho Higher Education Maintenance of Effort Waiver Request

Summary

A form titled Idaho Higher Education Maintenance of Effort Waiver Request, dated 12/16/2021 and naming Matt Freeman, Executive Director, State Board of Education, as the printed name. It states a request for a waiver of the FY 2022 MOE requirement for higher education under section 317(a) of the CRRSA Act and section 2004(a) of the ARP Act. Attachment 1 states that Fiscal Year 2022 saw a $28,000,000 increase in state appropriation for higher education and that the percentage of overall state spending decreased because of a voter initiative that expanded Medicaid coverage. It gives higher education support of $344,903,700 (average for Fiscal Years 2017, 2018 and 2019), $356,941,400 (Fiscal Year 2021) and $385,341,600 (Fiscal Year 2022).

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

   Idaho Higher Education Maintenance of Effort Waiver Request
This form must be used for the submission of a request for a waiver of the requirements noted below. For
assistance please contact your State mailbox, which is [State].oese@ed.gov .

State IDAHO

On behalf of my State, I request a waiver of the following State maintenance of
effort (MOE) requirements for the following fiscal years: FY 2022

  Please check all that apply:

  FY 2020 MOE requirement for elementary and secondary education under section 18008
of the CARES Act.

  FY 2020 MOE requirement for higher education under section 18008 of the CARES Act.
  FY 2021 MOE requirement for elementary and secondary education under section 18008
        of the CARES Act.

  FY 2021 MOE requirement for higher education under section 18008 of the CARES Act.
  FY 2022 MOE requirement for elementary and secondary education under section 317(a)
        of the CRRSA Act and section 2004(a) of the ARP Act.

 XX FY 2022 MOE requirement for higher education under section 317(a) of the CRRSA Act
        and section 2004(a) of the ARP Act.

  FY 2023 MOE requirement for elementary and secondary education under section 2004(a)
        of the ARP Act.

  FY 2023 MOE requirement for higher education under section 2004(a) of the ARP Act.
Data for State support and overall State spending

A State must resubmit the baseline data for FYs 2017, 2018, and 2019 (baseline years) as part of this
MOE waiver request. If these baseline data differ from a State’s previously submitted data, please provide
a description of the reason for the change. Additionally, a State must submit MOE data for the years in
which it is requesting this waiver.
                           State support for          State support for higher Overall State spending *
                           elementary and             education
                           secondary education

        FY 2017             $                          $332,684,000                $4,192,335,900

        FY 2018             $                          $342,894,100                $4,596,791,900

        FY 2019             $                          $359,133,000                $4,838,836,800

        FY 2020            $                          $                          $

        FY 2021            $                          $                          $

        FY 2022            $                          $385,341,600               $5,445,589,000

        FY 2023            $                          $                          $

*For overall State spending, a State may request a waiver based on final allocations or
appropriations. For more information, see FAQ 10.

Additional submission requirements

In an attachment, please provide:

    1. A description of the extent to which the State experienced fiscal burdens in preventing, preparing
        for, and responding to the coronavirus and an explanation of how those fiscal burdens affected the
        State’s ability to maintain fiscal effort (e.g., the status of and any changes to the State’s rainy
        day fund, whether the State experienced a decline in revenues, or an increase in other
        emergency expenses resulting from the pandemic, such as expenses related to health care,
        unemployment insurance, or support for small businesses); and

    2. Documentation and data supporting the description of the State’s fiscal burdens (e.g., revenue
        data, appropriation tables, unemployment statistics, etc.) including any State action that
        impacted State revenue (e.g., tax increases or decreases).

    3. In determining whether to grant a State an MOE waiver, the Secretary may consider
       factors such as:

        Has the State increased support for education?
        The Department understands that it is possible that a State has maintained or increased
        overall funding for education and the proportion of the State budget for education has still
        declined because of increases in other areas of the budget (e.g., public health). In these
        cases, the Secretary may consider:
   o   Has total State funding for K-12 education and for higher education (calculated
       separately) increased from the prior fiscal year?

   o   Has total State funding for K-12 education and for higher education (calculated
       separately) increased over time (e.g., since baseline years)?

   o   Has per-pupil State funding for K-12 education and for higher education
       (calculated separately) increased from the prior fiscal year?

   o   Has per-pupil State funding for K-12 education and for higher education
       (calculated separately) increased over time (e.g., since baseline years)?

   o   Has the State appropriated an increase in State funding for K-12 education and for
       higher education for future fiscal years?

Are there exceptional circumstances that caused the State to be unable to maintain
support for education?
If a State’s support for education declined, the Secretary may consider:
   o   Are there specific severe effects of the COVID-19 pandemic on the State’s
       economy that necessitated reductions in support for elementary and secondary
       education and for higher education?

   o   What steps did the State take to avoid and/or minimize such reductions?

   o   Did the State use Coronavirus State and Local Fiscal Recovery Funds awarded by
       the U.S. Department of the Treasury under section 9901 of the ARP Act to
       support elementary and secondary education and higher education?

   o   How did reductions in support for elementary and secondary education and for
       higher education compare to other budget categories?

   o   Did the State take steps that reduced or will it take steps to proactively reduce its
       financial resources in a way that impacted or will impact its ability to meet MOE
       requirements (e.g., tax changes (and in what context), additional contributions to
       rainy day funds)? If so, what was the impact of the reduction (e.g., to what extent
       were its resources reduced or will its resources be reduced)?

Has the State used or will it use ESSER, GEER, or Higher Education Emergency
Relief (HEER) funding to replace State funding for education?
It is important for the Department to understand the State’s use of pandemic-related
Federal funds when reviewing a request for a waiver. The Secretary may therefore
consider:
           o   Will all unallocated ESSER or GEER funds relevant to the waiver be used to
               provide net new resources to K-12 schools and to higher education and not be
               used to replace existing State commitments to K-12 education and to higher
               education?

           o   Will all unallocated HEER funds be used to provide net new resources to higher
               education and not be used to replace existing State commitments to higher
               education?

           o   Has the State previously used any ESSER, GEER, or HEER funds to replace State
               funding for education?

       In addition, in its waiver request, a State should submit information on the relevant
       factors listed below to support its request. The Secretary may ask States for additional
       information after States submit the MOE waiver request form.

To the best of my knowledge and belief, all of the information in this MOE data submission are
true and correct and the failure to submit accurate data may result in liability under the False
Claims Act, 31 U.S.C. § 3729 et seq.; OMB Guidelines to Agencies on Governmentwide
Debarment and Suspension (Nonprocurement) in 2 CFR part 180, as adopted and amended as
regulations of the Department in 2 CFR part 3485; and 18 USC § 1001, as appropriate, and other
enforcement actions.

_Matt Freeman, Executive Director, State Board of Education (208) 332-1570

Governor or Chief State School Officer or Authorized Representative (Typed or Printed Name)
Telephone


(b) (6)                             _________________________________________________
                                       12/16/2021

Signature of Governor or Chief State School Officer or Authorized Representative Date
Attachment 1: Idaho Maintenance of Effort Form
Idaho herewith provides the following information:

   1. A description of the extent to which the State experienced fiscal burdens in preventing, preparing
      for, and responding to the coronavirus and an explanation of how those fiscal burdens affected the
      State’s ability to maintain fiscal effort (e.g., the status of and any changes to the State’s rainy
       day fund, whether the State experienced a decline in revenues, or an increase in other
       emergency expenses resulting from the pandemic, such as expenses related to health care,
       unemployment insurance, or support for small businesses)

       Although there was a 5% reduction in Fiscal Year 2021, Fiscal Year 2022 saw a
       $28,000,000 increase in state appropriation for higher education. The percentage of the
       Overall State Spending decreased, however, because of the effects of a voter initiative
       that expanded Medicaid coverage that took effect on January 1, 2020, as shown in the
       chart below from the Idaho Division of Financial Management’s Fiscal Year 2022
       Executive Budget publication
       (https://dfm.idaho.gov/publications/exec/budget/fy2022/summary/section-A/history.pdf).
       Idaho did not replace state funding for higher education with funds from the Governor’s
       Emergency Education Relief Fund; spending was increased.

   2. Documentation and data supporting the description of the State’s fiscal burdens (e.g., revenue
       data, appropriation tables, unemployment statistics, etc.) including any State action that
       impacted State revenue (e.g., tax increases or decreases).

       A spreadsheet supporting this information is attached with this document.

   3. In determining whether to grant a State an MOE waiver, the Secretary may consider
       factors such as:

          Has the State increased support for education?
           Yes. The average support for higher education for Fiscal Years 2017, 2018 and 2019
           was $344,903,700, and the support for higher education in Fiscal Year 2021 was
           $356,941,400. Both the average for the baseline years and state spending for Fiscal
           Year 2021 were less than the state spending for fiscal year 2022, which was
           $385,341,600. Funds for Fiscal Year 2023 have not yet been appropriated by the
           Governor and Legislature.

          Are there exceptional circumstances that caused the State to be unable to maintain
           support for education?
           No. As noted, the State of Idaho did more than maintain its level of support for higher
           education; the State increased its support. Only the percentage changed, and that
           percentage drop can be attributed to the increased costs of Medicaid expansion.

          Has the State used or will it use ESSER, GEER, or Higher Education Emergency
           Relief (HEER) funding to replace State funding for education?
           No. No GEER funds are being used to replace state funding for education, not have
           they ever been used to replace state funding for education.


Based on this information, Idaho seeks to demonstrate compliance with both the letter and the
spirit of the requirement, and respectfully requests a waiver based on the evidence that funding
for higher education increased and the percentage only changed due to Medicaid expansion.


File and source

File

department-of-education-pdf-www-ed-gov-5a37655ee6.pdf

Size

411,095 bytes

SHA-256

1e5e0dabf14f1eb5324f966876da84e09ba6f69d649ca5887cd71fe890c70893

Our copy

department-of-education-pdf-www-ed-gov-5a37655ee6.pdf

Original

www.ed.gov