Grantee Learning Series for COVID-19 Relief Programs: Maintenance of Effort & Maintenance of Equity
Summary
This is a slide presentation titled Grantee Learning Series for COVID-19 Relief Programs: Maintenance of Effort & Maintenance of Equity from the Office of State and Grantee Relations at the U.S. Department of Education. Its stated purpose is for participants to understand the maintenance of effort requirements, the State maintenance of equity requirements, and the local maintenance of equity requirements, with related policy guidance and reporting deadlines. A comparison table says maintenance of effort applies to fiscal years 2020, 2021, 2022 and 2023 with a baseline of the average of 2017, 2018, and 2019, while maintenance of equity applies to 2022 and 2023 and covers the ARP ESSER program. It also says the Secretary can waive the effort requirements but cannot waive the equity requirements.
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“Grantee Learning Series for COVID-19 Relief Programs: Maintenance of Effort & Maintenance of Equity.”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-presentation-www-ed-gov-d516e22d3a/
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Grantee Learning Series for
COVID-19 Relief Programs:
Maintenance of Effort &
Maintenance of Equity
The Office of State and Grantee Relations
Laura Jimenez, Director, Office of State and Grantee Relations
1
Purpose
Participants in this meeting will:
1. Understand the maintenance of effort requirements, related
policy guidance, and reporting deadlines.
2. Understand the State maintenance of
equity requirements, related policy guidance, and reporting
deadlines.
3. Understand the local maintenance of equity
requirements, related policy guidance, and reporting deadlines.
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
MOE and MOEquity
1. Overview of MOE and MOEquity Requirements
2. Data Reporting Deadlines
3. Q&A
U.S. Department of Education 3
Maintenance of Effort Maintenance of Equity
Applicable Fiscal Years 2020, 2021, 2022, 2023 2022, 2023
Baseline Fiscal Years Average 2017, 2018, and 2019 SEA Requirement
• High-Need LEAs – 2021 and 2022
• Highest-Poverty LEAs – 2019
LEA Requirement
• 2021 and 2022
Responsible Entity States SEAs and LEAs
Applies To Funding for all public K-12 schools Funding for LEAs and schools that serve
and Institutions of Higher Education the largest shares of students from low-
income backgrounds
Type of Funding Total State Funds State and Local Per-Pupil Funding,
FTE Staff (LEA Requirement Only)
COVID Relief Programs ESSER, GEER, EANS ARP ESSER
Waiver Authority Secretary can waive requirements to Secretary cannot waive the requirements,
relieve fiscal burdens but LEAs can be excepted from LEA
requirement U.S. Department of Education 4
Maintenance of Effort
(MOE)
5
Maintenance of Effort
CARES Act Requirement
• A State must separately maintain support for elementary and secondary
education and higher education in FYs 2020 and 2021 at a level equal to
or greater than the average of State support for elementary and
secondary education and higher education for FYs 2017, 2018, and 2019.
CRRSA and ARP Act Requirements
• Under the CRRSA Act in FY 2022 and the ARP Act in FY 2022 and FY 2023, a
State must separately maintain support for both elementary and secondary
education and higher education at least at the proportional level of support
for elementary and secondary education and higher education relative to
overall state spending averaged over FY 2017, FY 2018, and FY
2019, the baseline years.
States have already submitted final MOE data for FYs 2020, 2021, and 2022 as
well as interim FY 2023 data. Final FY 2023 data will be due March 15, 2024.
• How much did the State spend on K-12 before the
CARES Act pandemic? (Average of FY17, 18, 19)
• How much did the State spending on K-12 during
the pandemic? (FY2020 and FY2021)
CARES Act becomes law
Elementary and
Average: $150 March 2020 Secondary Education
$100 $150 $200 $175 $185
FY17 FY18 FY19 FY20 FY21 FY22 FY23
$50 $60 $100 $60 $80
Higher
Average: $70
Education
• How much did the State spend on higher education
before the pandemic? (Average of FY17, 18, 19)
• How much did the State spending on higher education
during the pandemic? (FY2020 and FY2021)
• What percentage of the State budget was allocated
for K-12 education before the pandemic? (Average of
CRRSA Act FY17, 18, 19)
• What percentage of the State budget was allocated
for K-12 education during the pandemic? (FY2022)
CRRSA Act became law
Elementary and
Average: 27% December 2020 Secondary Education
18% 27% 36% 28.5%
FY17 FY18 FY19 FY20 FY21 FY22 FY23
9% 11% 18% 12.8%
Higher
Average: 12.6%
Education
• How much did the State spend on higher education
before the pandemic? (Average of FY17, 18, 19)
• How much did the State spending on higher education
during the pandemic? (FY2022)
• What percentage of the State budget was allocated for K-12
ARP Act education before the pandemic? (Average of FY17, 18, 19)
• What percentage of the State budget was allocated for K-12
education during the pandemic? (FY2022 and FY2023)
ARP Act became law
Elementary and
Average: 27% March 2021 Secondary Education
18% 27% 36% 28.5% 26.5%
FY17 FY18 FY19 FY20 FY21 FY22 FY23
9% 11% 18% 12.8% 13%
Higher
Average: 12.6%
Education
• How much did the State spend on higher education
before the pandemic? (Average of FY17, 18, 19)
• How much did the State spending on higher education
during the pandemic? (FY2022 and FY2023)
Maintenance of Effort
• In reviewing State requests for a waiver of the MOE requirements, we
noticed that some States compare the proportional levels in FY 2022 or
FY 2023 and the baseline years using several decimal places.
• We advised States that when comparing the FY 2022 and FY 2023
proportional levels of support to the baseline years, the State, at its
discretion, may round the difference to the nearest whole number using
standard rounding procedures.
• For example, a difference between
proportions of less than 0.5% could
be rounded down to 0%, and a
difference of 0.5% or greater would
be rounded up to 1%.
Maintenance of Effort
Waiver Requests
• The Secretary can waive the MOE requirement to relieve a fiscal burden a
State endured as a result of the COVID-19 pandemic.
• The information regarding MOE waiver submission materials is available in
the MOE FAQs
• The Department has received 22 maintenance of effort waiver requests:
• 13 requests were withdrawn by the State after receiving technical
assistance from the Department
• 4 requests were approved
• CNMI (FYs 2020, 2021 – K-12 and higher education)
• NH, NY, WV (FY 2022 – K-12)
• 7 requests are pending
Maintenance of Equity
(MOEquity)
12
Maintenance of Equity
• Maintenance of Equity (MOEquity) requirements were enacted for the first time
in the American Rescue Plan (ARP) Act.
• MOEquity is a two-part requirement, one that applies to State educational
agencies (SEAs) and another for local educational agencies (LEAs), in fiscal years
(FY) 2022 and 2023 (i.e., school years 2021-2022 and 2022-2023).
SEA-Level Requirements
• These requirements safeguard school districts that serve a large share of
students from low-income backgrounds (high-need LEAs) against experiencing a
disproportionate reduction in per-pupil funding in FYs 2022 and 2023.
• These requirements also ensure that school districts serving the largest shares of
students from low-income backgrounds (highest-poverty LEAs) do not receive a
decrease in State per-pupil funding below their FY 2019 level.
• The Secretary has no maintenance of equity waiver authority and there are no
exceptions to this requirement.
U.S. Department of Education 1
3
How does an SEA identify high-need and high-poverty
LEAs?
• A “high-need LEA” has the highest percentages of economically disadvantaged students in the and collectively serves not less than 50
percent of the State’s total enrollment of students served by all LEAs in the State.
• A highest-poverty LEA has the highest percentages of economically disadvantaged students in the and collectively serves not less than
20 percent of the State’s total enrollment of students served by all LEAs in the State.
LEA Name Enrollment % of economically High-Need or Highest-Poverty?
Total: 250 disadvantaged students
Ella Fitzgerald ISD 25 90% Highest-Poverty
High-Need
In this example, 50% of
Billie Holiday ISD 25 87% Highest-Poverty
High-Need total enrollment (250)
Nina Simone ISD 10 82% High-Need is 125, so 4 high-need
Anita Baker ISD 40 80% High-Need LEAs (100 students) is
rounded up to 5.
Norah Jones ISD 40 74% High-Need
Sarah Vaughan ISD 10 72%
Diana Krall ISD 20 70%
Dinah Washington ISD 20 68%
Etta James ISD 45 65%
Eliane Elias ISD 15 62%
1
4
Maintenance of Equity
SEAs Maintaining Equity in High-Need LEAs
Under section 2004(d)(3) of the ARP Act,
a “high-need LEA” is one that has the
highest percentages of economically
disadvantaged students in the State on
the basis of the most recent satisfactory
data available from the U.S. Department
of Commerce (i.e., Small Area Income
and Poverty Estimates (SAIPE) data
provided by the U.S. Census Bureau);
and collectively serve not less than 50
percent of the State’s total enrollment of
students served by all LEAs in the State.
Source: Frequently Asked Questions, ARP Elementary and Secondary School Emergency Relief (ESSER)
Program Maintenance of Equity Requirements U.S. Department of Education 1
5
Maintenance of Equity
SEAs Maintaining Equity in Highest-Poverty LEAs
Under section 2004(d)(2) of the
ARP Act, a “highest-poverty LEA
is one that has the highest
percentages of economically
disadvantaged students in the
State on the basis of the most
recent SAIPE data and
collectively serve not less than
20 percent of the State’s total
enrollment of students served
by all LEAs in the State.
Source: Frequently Asked Questions, ARP Elementary and Secondary School Emergency Relief (ESSER)
Program Maintenance of Equity Requirements U.S. Department of Education 1
6
Maintenance of Equity
SEA-Level Reporting Requirements
1. A list of the State’s high-need LEAs including NCES LEA/district ID;
2. The statewide per-pupil amount of State funds provided to all LEAs in the State in FYs 2021,
2022, 2023
3. The per-pupil amount of State funds provided to each high-need LEA in the State in FYs 2021,
2022, 2023
4. A list of the State’s highest-poverty LEAs including NCES LEA/district ID;
5. The per-pupil amount of State funding provided for each highest-poverty LEA in FY 2019,
2022, 2023
6. A list of the high-poverty schools in each LEA in the State (including the NCES school ID) for
which it must maintain equity in FYs 2022 and 2023
U.S. Department of Education 1
7
Maintenance of Equity
SEA-Level Reporting Deadlines
July 30, 2021 – SEAs were required to report interim FY 2022 data with extensions offered to October 15
July 15, 2022 – SEAs report final FY 2022 data on Annual Performance Report
July 30, 2022 – SEAs report interim FY23 data with extensions offered to October 15
March 15, 2023 – Deadline to submit small LEA tolerance proposals for FY 2022
July 31, 2023 – SEAs submit final FY 2023 data to SGR directly
U.S. Department of Education 1
8
LEA-Level Maintenance of Equity Requirements
• Under section 2004(c) of the American Rescue Act, LEAs must maintain equity for
high-poverty schools by ensuring:
• There is no disproportionate reduction in combined State and local per-pupil
funding compared to all schools served by the LEA in that fiscal year
• There is no disproportionate reduction in the number of FTE staff per-pupil
compared to all schools served by the LEA in that fiscal year
• These requirements apply to fiscal years (FY) 2022 and 2023 (i.e., 2021-2022 and
2022-2023 school years).
• LEAs may choose to evaluate whether they have maintained fiscal and staffing
equity by grade span or in the LEA as a whole.
• A “high-poverty school” is a school in the highest quartile of schools served by the
LEA based on the percentage of economically disadvantaged students in the
school. An LEA may determine its high-poverty schools on a districtwide basis or by
grade span. See FAQ 25 1
U.S. Department of Education
9
How does an LEA identify high-poverty schools across
the LEA as a whole?
• A “high-poverty school” is a school in the highest quartile of schools served by the LEA based on the
percentage of economically disadvantaged students in the school.
Step 1: Rank each school in the
LEA by its percentage of
economically disadvantaged
students
Step 2: Divide the total number
of schools in the LEA by 4 to
determine the number of
schools in the highest quartile. If
the result is not a whole number,
round up.
In this example, 9 schools divided by 4 equals 2.25
schools, so 2.25 is rounded up to 3 schools. 2
0
How does an LEA identify high-poverty schools using
the grade span method?
• A “high-poverty school” is a school in the highest quartile of schools served by the LEA based on the
percentage of economically disadvantaged students in the school.
Step 1: Rank each school in each
grade span by its percentage of
economically disadvantaged
students.
Step 2: Divide the total number
of schools in the LEA by 4 to
determine the number of
schools in the highest quartile. If
the result is not a whole number,
round up.
Step 3: Select the highest-poverty
school in each grade span. Just like before, 9 schools divided by 4 equals 2.25
schools, so 2.25 is rounded up to 3 schools.
2
1
LEA-Level Maintenance of Equity Exceptions
• The ARP Act excepts an LEA from the local maintenance of equity requirements if
the LEA:
• Has a total enrollment of less than 1,000 students
• Operates a single school
• Serves all students within each grade span with a single school
• Demonstrates an exceptional or uncontrollable circumstance, such as
unpredictable changes in student enrollment or a precipitous decline in the
financial resources of the LEA, as determined by the Secretary of the U.S.
Department of Education
• The Secretary has determined that an LEA that did not have an aggregate reduction
in combined State and local per-pupil funding in FY 2022 compared to FY 2021, or
in FY 2023 compared to FY 2022, has demonstrated an exceptional or
uncontrollable circumstance to warrant an exception from maintaining equity for
that fiscal year. U.S. Department of Education 2
2
Submitting a request for an “Exceptional or
Uncontrollable Circumstance” to the Department
• If an LEA believes it qualifies for an exception due to an exceptional or
uncontrollable circumstance, the LEA must submit a written request for
exception to the Department via the State’s mailbox (i.e.,
alabama.oese@ed.gov) and copy the appropriate SEA official for awareness.
• The request should provide detailed information on the exceptional or
uncontrollable circumstance, including how it prevents the LEA from maintaining
equity in its high-poverty schools.
• The Department has approved four FY 2022 LEA exception requests, which are
publicly available here.
2
4
U.S. Department of Education
Additional LEA-Level Maintenance of Equity
Exceptions
• An LEA may also be excepted from local maintenance of equity
requirements for the 2021-2022 and 2022-2023 school years if the LEA
is not facing overall budget reductions. See FAQ 32
• If an LEA did not have an aggregate reduction in combined State and
local per-pupil funding in FY 2022 or FY 2023, then the Department has
determined that the LEA has demonstrated an “exceptional or
uncontrollable circumstance.”
• To be excepted, the LEA must complete the Certification of Exception of
Local Maintenance of Equity Requirements in Appendix B of the
updated FAQs and submit the certification to its SEA.
• The LEA does not need to submit this form to the Department.
U.S. Department of Education 2
5
Demonstrating LEA-Level Maintenance of Equity
• For the purpose of demonstrating compliance with the maintenance of equity
requirements, an LEA may use:
• allocations or budget data, or
• per-pupil expenditure data from Title I, Part A report cards
• In deciding whether or not to use per-pupil expenditure data, an LEA may review
prior-year per-pupil expenditure data to inform its approach to monitoring and
assess the likelihood of a maintenance of equity violation.
• The Department acknowledges that LEAs using per-pupil expenditures will not
know whether they maintained equity until after the school year ends and, thus,
will not be able to remedy a maintenance of equity violation for that school year.
• If an LEA does not maintain equity and cannot make adjustments in that year, the
LEA may make adjustments to funding and FTE staffing in the next year to ensure
that high-poverty schools in the LEA are treated equitably.
U.S. Department of Education 26
Requirements for Publishing LEA-Level
Maintenance of Equity Data
• On June 8, 2022, the Department published a Notice of Final Requirements in the
Federal Register that outlined the following requirements for SEAs to publish, on
an SEA’s website, LEA-level maintenance of equity data for FYs 2022 and 2023:
July 8, 2022 – SEAs publish LEA exceptions, identify high-poverty schools for FY 2022, and describe
how the SEA will ensure that each LEA that is not excepted from the LEA-level maintenance of
equity requirements is maintaining equity in its high-poverty schools.
November 1, 2022 – SEAs publish LEA exceptions and identify high-poverty schools for FY 2023
December 31, 2022 – SEAs publish applicable LEA high-poverty school data for FY 2022
December 31, 2023 – SEAs publish applicable LEA high-poverty school data for FY 2023
U.S. Department of Education 2
7
Maintenance of Equity
Announcements and Resources
• A list of deadlines related to MOEquity and other grants managed by
the Office of State and Grantee Relations is available here
• The Department’s maintenance of equity webpage is available here
• Maintenance of Equity FAQs
• More information regarding the local maintenance of equity exception
process can be found here
U.S. Department of Education 28
QUESTIONS
29
Thank You
30
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