American Rescue Plan (ARP) Liquidation Extensions Office Hours (U.S. Department of Education, May 21, 2024)
Summary
U.S. Department of Education slide presentation, American Rescue Plan (ARP) Liquidation Extensions Office Hours, May 21, 2024, from program officers in the Office of State and Grantee Relations. The slides report, as of May 15, CARES Act extensions with ESSER requests approved totaling $15.7M and GEER totaling $11.2M, and CRRSA Act extensions with ESSER totaling $316M, GEER $22M and EANS $205M. They say liquidation extension requests are recommended by December 31, 2024, may include any allowable costs but all costs must be obligated by September 30, 2024, and that review may take 3-4 weeks. They describe the request template, the required cover letter and oversight of approved requests.
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“American Rescue Plan (ARP) Liquidation Extensions Office Hours (U.S. Department of Education, May 21, 2024).”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-presentation-www-ed-gov-074292f456/
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American Rescue Plan (ARP)
Liquidation Extensions
Office Hours
May 21, 2024
Mary Khan, Program Officer, Office of State and Grantee Relations
Jennifer Timmons, Program Officer and Liquidation Extensions Lead, Office of State and Grantee Relations
Christopher Tate, Group Leader, Office of State and Grantee Relations
1
Topics
1. CARES Act and CRRSA Act ESSER, GEER, and EANS Updates
2. ARP Act Liquidation Extension Submission
3. Considerations for Request Development
4. Oversight of Approved Requests
5. Tydings Waiver Request
6. 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 and CRRSA Act Extension Updates
(As of May 15)
CARES Act Extensions
• ESSER Requests Approved: 12 totaling $15.7M
• GEER Requests Approved: 9 totaling $11.2M
• Extensions ended March 29, 2024.
CRRSA Act Extensions
• ESSER Requests Approved: 21 totaling $316M
• GEER Requests Approved: 10 totaling $22M
• EANS Requests Approved: 11 totaling $205M
• Extensions end March 31, 2025
U.S. Department of Education 33
American Rescue Plan (ARP) Liquidation Extensions
Resources • Requests can be submitted when
data is available/complete
ARP Liquidation Extension LETTER
• Submission is recommended by
ARP ESSER/EANS Extension Request December 31, 2024
TEMPLATE
• Requests submitted after December
Liquidation Extension Updated FAQs 31, 2024, may experience a lapse in
G6 access while an approval
decision is pending
APR ESSER and ARP EANS Liquidation
Extension Webinar (1.18.2024) • Requests may include any allowable
costs but ALL costs must be
• Recording – English obligated by September 30, 2024
• Presentation
• Approval will be based on the
submission of a complete request
U.S. Department of Education 4
Liquidation Extension Request Process Overview
• Grantees collect the liquidation extension information noted on the template on
behalf of themselves and their subgrantees. Prior to submitting that information,
this information must be verified that it represents timely and valid obligations.
• Note that each subgrantee is a row, that is, all the requests for a single
subgrantee are entered into one row.
• Grantees submit one comprehensive Excel document to represent an extension
at the grantee and subgrantee levels (as appropriate) with a single date for the
extension.
• Grantees must include a cover letter that explains how the ARP ESSER and/or
ARP EANS liquidation extension request contributes to the acceleration of
academic success for students, including those furthest from opportunity and
with the greatest need
• Review and approval may take 3-4 weeks and depends on completeness and
accuracy of submitted information
U.S. Department of Education 5
Liquidation Extension Request Process Overview
Cover Letter
• Grantees must provide a cover letter, on letterhead, that explains how the ARP ESSER and/or
EANS liquidation extension request contributes to the acceleration of academic success for
students, including those furthest from opportunity and with the greatest need
• Examples might include -
• Describe projects (e.g., parent communications initiatives, adoption of early warning intervention systems, home visiting
programs, and interagency data-sharing investments) that promote regular student attendance and reduce chronic
absenteeism.
• Indicate how many subgrantees are requesting liquidation extension to support contracted evidence-based tutoring services
throughout the 2024-25 school year, and the approximate number and percentage of students to be served;
• Identify uses of funds to provide summer learning opportunities and to provide afterschool and extended learning time during
the regular school year, and the number of students served;
• Providing counseling services to address mental health needs;
• Offering professional development and coaching to educators to build math and literacy instructional capacity; or
• Making targeted improvements to school infrastructure, including HVAC investments, to enhance indoor air quality and
environmental safety that keep students healthy in school U.S. Department of Education 6
Considerations During Request Development
Approval is a function of completeness of the information and timeliness/validity of the
obligation.
Goal is to receive requests that are approvable, i.e., requests are complete and reflect timely
and valid obligations.
Grantee and Subrecipient Information
• Provide enough specificity to clearly indicate proper and timely obligations
• Additional detail is necessary when referencing costs related to personal services
• Avoid having the same Use of Funds or Justification copied/pasted for each subrecipient
• Use of the data notes column is not required; however, its completion may be helpful to
produce a high-quality request
U.S. Department of Education 7
Considerations During Request Development
Incomplete/Incorrect Information on the Grantee Overview
• ALN Number often left blank
• PR Number often incorrect (e.g., adding PR for EANS instead of ESSER, wrong year of funds)
• Award Amount often incorrect (typos, not inclusive of entire award)
• Requested dates left blank or requesting a subrecipient date that is later than the grantee’s
date instead of earlier
• Incorrect information here will place incorrect information on the Attestation Form
Considerations During Request Development
Clarifications Needed
Questions for Grantee/Subrecipient
• How were the "temp staffing costs" obligated?
• Phrasing of "will be able to spend these funds with more time" implies funds have not yet been obligated.
Were the funds listed for supplies, materials, and temp staffing costs properly obligated?
Stronger Request
U.S. Department of Education 9
Considerations During Request Development
Complete requests include signed attestations from an authorized grant official
attesting that -
1. All information is complete and accurate;
2. Activities and services included are allowable and have been properly obligated by
September 30, 2024;
3. Certifications and assurance included in the award documents and approved State plan
remain in effect;
4. Grantees will provide continued monitoring and oversight of subrecipients in the extended
liquidation period;
5. Data verification will be provided as requested;
6. Sufficient documentation to support the request is available with the grantee or subrecipient;
and
7. Subrecipients have been assessed for risk using relevant data.
U.S. Department of Education 10
Considerations During Request Development
Liquidation and Obligation Requirements 34 CFR 76.707
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 the On the date on which the State or subgrantee makes a
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
U.S. Department of Education 11
Considerations During Request Development
May grantees carry out grant activities during liquidation?
ESSER FAQs: Question E-3.d. How long may ESSER or GEER funded activities
continue after the liquidation period?
EANS Communication: EANS Services and Assistance After the End of the
Period of Performance
ARP ESSER Liquidation Extension Letter
There are limited circumstances where an SEA or subgrantee timely obligates
ARP ESSER or ARP EANS funds, such services or activities may continue for a
reasonable time beyond the liquidation period.
U.S. Department of Education 12
Oversight of Approved Requests
Drawdown Monitoring
• Grantees are placed on route payment during the period of extension.
• Grantees must submit a summary of entities to be reimbursed associated with each drawdown
during the period of extension.
• SGR monitors each drawdown against the grantee’s approved request before approving a payment
to ensure that:
• Funds associated with a specific subrecipient are available consistent with the approved
amounts requested for extension;
• A drawdown is only for funds/subrecipients included in the approved extension, and;
• An amendment to the grantee’s request isn’t needed.
Formal Reviews
• Ongoing data verification and review of grantee oversight activities at least twice during
implementation.
• Monitoring of the grantee’s process for seeking an extension, subrecipient monitoring, and request
closeout activities, in addition to formally reviewing status of liquidations to date.
• Monitoring includes a review of grantee reimbursement request packages, and associated
documentation, from subrecipients and internal processes for approving grantee drawdowns for 1
their own use of funds. 3
Tydings Waiver Request Details
• States are invited to seek a waiver of section 421(b) of the General
Education Provisions Act, to extend the period of availability for ARP
administrative funds and fiscal year (FY) 2022 ESEA program
administrative funds that they choose to consolidate under ESEA
section 8201.
• ARP ESSER, ARP EANS, and ARP-HCY program funds may not be
extended beyond September 30, 2024.
• States can request a Tydings waiver for consolidated administrative
funds through March 31, 2026.
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4
Tydings Waiver Request Details
• A State may submit a single-page request to waive, pursuant to section 8401 of the ESEA of
1965, the period of availability of consolidated administrative funds in section 421(b) of GEPA until
March 31, 2026.
• An SEA must consolidate at least one program from the ESEA and one program from the ARP
Act.
• Pursuant to section 8401(b)(1), the request must identify the programs (i.e., the administrative
funds from each program) for which the waiver is being requested and may only include
administrative funds consolidated under any of the following programs:
ARP Programs ESEA Programs (FY 2022)
1. ARP EANS 1. Title I, Part A of the ESEA (Improving Basic Programs Operated by LEAs)
2. ARP ESSER 2. Title I, Part C of the ESEA (Education of Migratory Children)
3. ARP-HCY 3. Title I, Part D, Subpart 1 of the ESEA (Prevention and Intervention Programs for Children and
Youth Who Are Neglected, Delinquent, or At Risk)
4. Title II, Part A of the ESEA (Supporting Effective Instruction)
5. Title III, Part A of the ESEA (English Language Acquisition, Language Enhancement, and
Academic Achievement)
6. Title IV, Part A of the ESEA (Student Support and Academic Enrichment Grants)
7. Title IV, Part B of the ESEA (21st Century Community Learning Centers)
8. Title V, Part B, Subpart 2 of the ESEA (Rural and Low-Income School Program) 1
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Tydings Waiver Request Details
• Pursuant to ESEA section 8401(b)(1), the waiver request must
describe:
o How the waiver will advance student academic achievement (e.g.,
the waiver would allow the SEA to use funds reserved for
administration under ESEA section 8201 to address ongoing
administrative costs and avoid diverting funds away from critical
services for LEAs, schools, students, and teachers and other
educational staff), and;
o How schools will continue to provide assistance to the same
populations served by the programs included in the waiver (e.g., the
waiver would allow the SEA to continue to focus its resources on
meetings students’ academic and other needs, including groups of
students most impacted by the pandemic).
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Tydings Waiver Request Details
• The waiver request must also include assurances that the State:
o Will use consolidated administrative funds under the respective
programs in accordance with the provisions of all applicable
statutes, regulations, program plans, and applications not subject to
these waivers, and;
o Has provided the public and all LEAs in the State with notice of, and
the opportunity to comment on, this request by posting information
regarding the waiver request and the process for commenting on the
State website in the manner in which the SEA customarily provides
such notice and opportunity to comment.
• When submitting a waiver request, the SEA must enclose any
comments received from the public and a description of how the SEA
addressed any such comments. 1
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Tydings Waiver Request Details
• Submit:
o The State’s signed waiver request;
o Any comments it received from the public specific to its request, and;
o The State’s description of how it addressed any comments it
received.
• Send complete waiver requests to: StateName.OESE@ed.gov (e.g.,
Alabama.OESE@ed.gov).
• The Department will quickly approve all complete requests.
RESOURCES
Dear Colleague Letter, April 25, 2024: FY 2022 Admin Funds Tydings Waiver
Webinar Presentation April 29, 2024: Consolidated Administrative Funds Tydings Waiver
Consolidated Admin Funds Tydings Waiver Q and A
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QUESTIONS
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