Liquidation Extension Requests for CARES-ESSER and CARES-GEER Webinar
Summary
Slides for a Department of Education webinar titled Liquidation Extension Requests for CARES-ESSER and CARES-GEER, presented by program staff of the Office of State and Grantee Relations, including Laura Jimenez, Director. The topics are liquidation and obligation requirements, the extension request process, completing and submitting a request, and questions. The slides recall that on March 27, 2020 Congress set aside about $13.2 billion of the $30.75 billion Education Stabilization Fund for ESSER and about $3 billion for GEER, and show that CARES ESSER I and GEER I had a September 30, 2022 obligation deadline, a January 28, 2023 statutory liquidation deadline and an extension deadline of April 1, 2024.
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Cite this document
“Liquidation Extension Requests for CARES-ESSER and CARES-GEER Webinar.”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-powerpoint-www-ed-gov-284b01907e/
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Liquidation Extension
Requests for CARES-ESSER
and CARES-GEER
WEBINAR
Jennifer Timmons, Program Officer and Late Liquidation Lead, Office of State and Grantee Relations
Christopher Tate, Group Leader, Office of State and Grantee Relations
Laura Jimenez, Director, Office of State and Grantee Relations
1
Presentation Topics
Liquidation Extension of CARES ESSER and GEER funds
1. Liquidation and Obligation Requirements
2. Liquidation Extension Request Process Overview
3. Completing and Submitting a Request
4. Q&A
A recording of the presentation and accompanying slides will be made available on
the Department’s State and Grantee Relations announcements webpage.
U.S. Department of Education 2
CARES Act Background
On March 27, 2020, Congress set aside approximately $13.2 billion of the $30.75
billion allotted to the Education Stabilization Fund through the Coronavirus Aid
Relief, and Economic Security (CARES) Act for the Elementary and Secondary
School Emergency Relief Fund (ESSER) Fund. The Department awarded these
grants to State educational agencies (SEAs) for the purpose of providing local
educational agencies (LEAs), including charter schools that are LEAs, with
emergency relief funds to address the impact that COVID-19 has had, and
continues to have, on elementary and secondary schools across the Nation.
In 2020, Congress set aside approximately $3 billion of the $30.75 billion allotted
to the Education Stabilization Fund through the Coronavirus Aid, Relief, and
Economic Security (CARES) Act for the Governor’s Emergency Education Relief
Fund (GEER) Fund.
ESSER FAQs GEER FAQs ESSER-GEER FAQs
U.S. Department of Education 3
Liquidation and Obligation Requirements
Program Obligation Liquidation Liquidation
Deadline Deadline Extension
Deadline
(Statutory 120 days) (Up to 14-months)
CARES - ESSER I Sep. 30, 2022 Jan. 28, 2023 Apr. 1, 2024
CARES - GEER I Sep. 30, 2022 Jan. 28, 2023 Apr 1, 2024
The process for submitting CRRSA and ARP liquidation extension requests will be
released at a later date.
Liquidation Extension Resources
• Liquidation Extension Letter
• Liquidation Extension Request Template
U.S. Department of Education 44
Liquidation and Obligation Requirements
What does it mean to “Obligate” Funds?
The regulations at 34 C.F.R. § 76.707 govern when an obligation of Federal
funds by a State or subgrantee such as an LEA occurs. Specifically, for services
or assistance provided through a contract, the obligation is made on the date
that the State or subgrantee makes a binding written commitment to obtain
the services, work, or products. For rental or lease of real or personal
property, the obligation is made when the property is used.
ESSER FAQs GEER FAQs ESSER-GEER FAQs
CARES Act Equitable Services FAQs U.S. Department of Education 5
Liquidation and Obligation Requirements
If the obligation is for - The obligation is made
a) Acquisition of real or personal property On the date on which the State or subgrantee makes a
binding written commitment to acquire the property.
b) Personal services by an employee of the State or subgrantee When the services are performed.
c) Personal services by a contractor who is not an employee of On the date on which the State or subgrantee makes a
the State or subgrantee binding written commitment to obtain the services.
d) Performance of work other than personal services. On the date on which the State or subgrantee makes a
binding written commitment to obtain the work.
e) Public utility services When the State or subgrantee receives the services
f) Travel When the travel is taken
g) Rental of real or personal property When the State or subgrantee uses the property
h) A pre-agreement cost that was properly approved by the On the first day of the grant or subgrant performance period
Secretary under the cost principles in 2 CFR part 200, Subpart E -
Cost Principles
The regulations at 34 C.F.R. § 76.707 govern when an obligation of Federal
U.S. Department of Education 6
funds by a State or subgrantee such as an LEA occurs.
Liquidation and Obligation Requirements
What does it mean to “Liquidate” Funds?
The drawing down and expenditure of funds by a grantee for obligations
incurred during the grant’s legal obligation period. Timely liquidation occurs
during the project performance period and through the first 120 days after
the final day of that period or an extension of that period authorized by ED,
pursuant to 2 C.F.R. § 200.344(b).
U.S. Department of Education 7
Liquidation and Obligation Requirements
May grantees carry out grant activities during
liquidation?
Yes, for contracted activities.
The period for delivery of goods and services and the associated payments
for those goods and services can extend to the end of the liquidation period,
so long as a timely and valid obligation had been made pursuant to 34 C.F.R.
§ 76.707.
Liquidation Extension Resources
U.S. Department of Education 8
Liquidation Extension Request Process Overview
The Department has the authority to approve liquidation extension requests for
properly obligated funds upon review of written requests made by the grantee on
behalf of itself and its subrecipients. Should funds be properly and timely obligated
by September 30, 2022, 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 a grantee, in accordance with 2 CFR §
200.344(b).
During the development of the CARES ESSER and CARES GEER liquidation extension
request process, the Office of State and Grantee Relations received feedback from
various groups regarding grantee and subrecipient needs for a late liquidation
• Representative group of State Education Agencies and Local Education Agencies
• Chief Counsel of State School Officers
• Association of Latino Administrators and Superintendents
• National Association of State Auditors, Comptrollers, and Treasurers 9
U.S. Department of Education
Liquidation Extension Request Process Overview
Overview of Feedback from Outreach
• Greater need for liquidation extensions under CRRSA and ARP as opposed to CARES
• Timely communication of a request process
• Single request structure from SEA to incorporate requests from LEAs
• Single date of extension rather than individual by LEA or SEA for grants management
capabilities
• Preference for LEAs to request of SEA and not directly to the Department
• SEA discretion for LEA approval
• Clear description of process, requirements, and approval criteria such that SEA need for
interpretation is minimal
• Provision of notes or descriptions of allowable situations
• Concerns regarding capacity and state-level personnel for oversight
• Timely communication of approval/denial with clear documentation for auditing
purposes
• Continued focus on intent of legislation/funding and the compliance required
U.S. Department of Education 10
Liquidation Extension Request Process Overview
Resulting Process for Liquidation Extensions
• Grantees will submit one comprehensive Excel document to represent an
extension at the grantee and subrecipient levels as appropriate with a single
date for the extension
• Notes, resources, and FAQ links have been embedded within the request
template
• Responsibilities for grantees and subrecipients are clearly outlined within the
attestations
• Single request process for grantees and subrecipients will expedite the
approval process
• Grantees maintain autonomy for subrecipient process, documentation, and
oversight
U.S. Department of Education 11
Liquidation Extension Request Process Overview
Liquidation Extension Request: Components
• Title Page – Informational Only
• Table of Contents and Instructions – Informational Only
• Grantee Request Overview – To be Completed/Submitted by Grantee
• Grantee Attestation - To be Completed/Submitted by Grantee
• Grantee Information - To be Completed/Submitted by Grantee
• Subrecipient Information - To be Completed/Submitted by Grantee
• Definitions and Additional Resources – Informational Only
Liquidation Extension Resources
• Suggested submission prior to December 31, 2022
• Requests submitted after December 31, 2022 may experience a lapse in G5 access
but will still be reviewed
U.S. Department of Education 12
Completing and Submitting a
Request
Title Page (Information Only)
• Grantees and subgrantees of the CARES Act must obligate
funds by September 30, 2022
• Grantees may submit liquidation extension requests on
behalf of itself and its subrecipients/LEAs
• Once approved, grantees and subrecipients/LEAs may have
up to 18 months to liquidate the funds
• Completed requests, using the Excel request template,
should be submitted as an Excel document to the state
mailbox (e.g., Alabama.OESE@ed.gov) and assigned
program officer
• Submission may occur when data is available and is
recommended prior to December 31, 2022 U.S. Department of Education 13
Completing and Submitting a Request
Table of Contents and
Instructions (Information Only)
• Grantees must complete the requested information on
the Grantee Request Overview, Grantee Attestation,
Grantee Information, and Subrecipient Information
• The request template and signed attestation should be
remitted to the state’s program officer and state mailbox
(e.g., State.OESE@ed.gov)
• Submissions can be made once data is available and are
recommended by December 31, 2022 to ensure access
to G5; data verification will be necessary
• Submissions provided after December 31, 2022 will also
be reviewed
• Only subrecipients in need of a liquidation extension
should be included
U.S. Department of Education
• CARES ESSER and CARES GEER requests must be submitted separately 14
Completing and Submitting a Request
Table of Contents and
Instructions (Information Only)
• Grantees must provide a signed attestation as part of
the liquidation extension request
• Grantees should use both discretion and oversight when
including a subrecipient/LEA within the request.
• It is incumbent upon the grantee to collect sufficient
documentation to support the liquidation extensions of
the subrecipients included in the request.
• Provision of this documentation may be requested for
monitoring or auditing purposes
• Data verification of September 30 obligations and
January 28 liquidations will be required
• Attestations must be signed by the appropriate official
U.S. Department of Education 15
Completing and Submitting
a Request
Grantee Request Overview
(Complete and Submit)
• ALN = Assistance Listing Number (formerly CFDA)
• GEER Requests = 84.425C
• ESSER Requests – 84.425D
• Date of Submission vs Date of Data Finalization
• Data finalization represents the date by which the
data has been included for subrecipients.
• Several data fields are populated by formulas within the
template (amounts) or are prepopulated dates
• Grantee vs Subgrantee Requested Extension Dates
• Cannot exceed 04/01/2024
• May be the same date
• Subrecipient date may be adjusted for
U.S. Department of Education 16
administrative purposes at the grantee level
Completing and Submitting
a Request
Grantee Attestation
(Complete and Submit)
• All information at the top of the page will be populated from
information previously entered on the Grantee Overview tab
• The attestation must be signed by an Authorizing Official. The
page may be printed, signed, and submitted along with the
request template or an official digital signature may be used.
• Attestations for Grantees include –
• Accuracy and completeness of included information
• Proper and timely obligations
• Continued applicability of the Certifications and
Assurances
• Continued monitoring and oversight of subrecipients
• Verification of data
• Collection of sufficient supporting documentation
• Grantee review of subrecipients included in request U.S. Department of Education 17
Completing and Submitting a Request
Grantee Information (Complete and Submit)
• Information in Columns A, B, F, and G will either populate from information on the Grantee
Request Overview tab or from embedded formulas
• Grantees should complete the information for Columns C-E and H-K
• It may be necessary and adequate to only include 1 line of data for the grantee’s information.
Additional lines are included for optional use should the grantee have need for additional lines.
• Examples of supporting documentation should be included in column K but will not be submitted
to the Department. Supporting documentation should be available upon request.
U.S. Department of Education 18
Completing and Submitting a Request
Grantee Information (Example)
U.S. Department of Education 19
Completing and Submitting a Request
Subrecipient Information (Complete and Submit)
• Information included should represent only the subrecipients/LEAs in need of an extension
• Data should be valid as of September 30, 2022, or the Date of Data Finalization indicated on the
Grantee Request Overview tab
• Columns F, G, and H should calculate automatically once data is entered for the allocation total,
amount obligated, and amount liquidated
• Selections for Uses of Funds might include construction contracts, HVAC contracts, instructional
services contracts, delayed resources, or other allowable uses of funds.
• Columns J & K should
represent LEA-specific
justifications currently
available and may also
include any other
relevant subrecipient
data notes
U.S. Department of Education 20
Completing and Submitting a Request
Subrecipient Information (Example)
U.S. Department of Education 21
Completing and Submitting
a Request
Definitions and Additional
Resources (Information Only)
• Includes definitions and associated reference links for
obligations and liquidations
• FAQs for the ESSER and GEER programs are included
• Certification and Assurances for ESSER and GEER are
included
U.S. Department of Education 22
QUESTIONS
23
Thank You
Additional Office Hours for liquidation
extensions will be offered later in October and
November. Dates/times to be announced
through G5.
24
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