Final Report — Allocation of ESSER I Funds at Selected Local Educational Agencies (ED-OIG/F20IT0049)

Summary

A final report, ED-OIG/F20IT0049, dated September 26, 2022, from the U.S. Department of Education Office of Inspector General, Technology Services, on how selected local educational agencies (LEAs) allocated Elementary and Secondary School Emergency Relief funds provided under the CARES Act, referred to as ESSER I funds. It states that the sample covered 48 LEAs, that two were not allocated ESSER I funds, and that as of March 2022 the 46 LEAs spent over $19.2 million, or about 95 percent, of the $20.2 million in ESSER I funds they were awarded. It states that about 26 percent of ESSER I funds were allocated to specific schools, with the majority of that portion allocated to Title I schools. The report states that it is an informational report that does not include any recommendations to the Office of Elementary and Secondary Education.

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Issuer: U.S. Department of Education, Office of Inspector General
Document type: Report
Date: 2022-09-26

Cite this document

“Final Report — Allocation of ESSER I Funds at Selected Local Educational Agencies (ED-OIG/F20IT0049).” U.S. Department of Education, Office of Inspector General, dated 2022-09-26. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/ed-oig-esser-lea-allocation-allocation-of-cares-act-esser-funds-at-selected-local-educational-agencies/, SHA-256 0da918566dde4629b5eedd1fa106572779f8f7f929f5936b46e4e1e4ab833a2d.

Full text

U.S. Department of Education
Office of Inspector General

Allocation of ESSER I Funds at
Selected Local Educational
Agencies
September 26, 2022
ED-OIG/ F20IT0049

ED OIG Oversight of Coronavirus Response Funds
NOTICE
In accordance with Freedom of Information Act (Title 5, United States Code,
Section 552), reports that the Office of Inspector General issues are available to
members of the press and general public to the extent information they contain is not
subject to exemptions in the Act.
UNITED STATES DEPARTMENT OF EDUCATION
OFFICE OF INSPECTOR GENERAL

Technology Services

September 26, 2022

TO: James Lane
Acting Assistant Secretary
Office of Elementary and Secondary Education

FROM: Kevin J. Young /s/
Assistant Inspector General for Technology Services

SUBJECT: Final Report, “Allocation of ESSER I Funds at Selected Local Educational Agencies,” Control
Number ED-OIG/F20IT0049

Attached is the subject final report that consolidates the results of our review of the Allocation of
ESSER I Funds at Selected Local Educational Agencies. We have provided an electronic copy to your audit
liaison officer. We received your comments on the draft of this report and considered them as we
prepared the report.

We appreciate your cooperation during this review. If you have any questions, please contact Rete
Odom at (404) 974-9455 or rete.odom@ed.gov.

400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510

Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
Table of Contents
Results in Brief .................................................................................................................... 1
Introduction ........................................................................................................................ 2
Observations ....................................................................................................................... 6
Appendix A. Scope and Methodology............................................................................... 12
Appendix B. Acronyms and Abbreviations........................................................................ 15
Office of Elementary and Secondary Education Comments ............................................. 16
Results in Brief
What We Did
The objective of our review is to describe how selected local educational agencies (LEA)
allocated Elementary and Secondary School Emergency Relief (ESSER) funds provided
under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). We refer to
ESSER funds provided under the CARES Act as ESSER I funds. LEAs had broad discretion
in their use of ESSER I funds. Several provisions in the law refer to but do not require
using funds for activities that address the needs of low-income students and students
with disabilities. The Department also encouraged LEAs to allocate ESSER I funds to
support remote learning for all students, especially disadvantaged and at-risk students.

We performed this review to identify how funds were allocated at selected LEAs. We
focused on direct allocations to Part A of Title I of the Elementary and Secondary
Education Act schools because those schools have high numbers or high percentages of
children from low-income families and receive funding to provide educational services
to students who are disadvantaged or at risk of failing to meet academic standards.

We also focused on allocations made exclusively for the benefit of children with
disabilities. Specifically, for a randomly selected, nonstatistical sample of 48 LEAs, we
identified whether and to what extent ESSER I funds were allocated to directly support
Title I schools and children with disabilities. Two LEAs in our sample were not allocated
ESSER I funds. For the other 46 LEAs, we determined

• total spending at the local level,
• direct allocations to Title I schools and non-Title l schools and for equitable
services at nonpublic 1 schools, and
• direct spending on children with disabilities. 2
We based our calculations and conclusions on data the 46 LEAs provided to us that
detailed their ESSER I spending from November 2021 through March 2022.

1
Section 18007(6) of the CARES Act defines a nonpublic school as a nonpublic elementary or secondary
school that “(A) is accredited, licensed, or otherwise operates in accordance with State law; and (B) was
in existence prior to the date of the qualifying emergency for the CARES Act programs.”
2
We define child with a disability consistent with section 602(3) of the Individuals with Disabilities
Education Act, as amended.

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What We Found
As of March 2022, the 46 LEAs spent over $19.2 million, or about 95 percent, of the
$20.2 million in ESSER I funds that they were awarded. The majority of these ESSER I
funds were spent on district-wide programs, and about 26 percent of ESSER I funds were
allocated to specific schools, with the majority of that portion allocated to Title I schools
over non-Title I schools. Regardless of whether LEAs spent ESSER I funds at the district
or school level, they may have used the funds for the benefit of all students, including
children with disabilities. Further, LEAs designated a portion of funds to exclusively
serve children with disabilities.

What We Recommend
This is an informational report that does not include any recommendations to the Office
of Elementary and Secondary Education. Our sampling methodology was not designed
to include any projections.

Office of Elementary and Secondary Education Comments and
Our Response
We provided a draft of this report to the Office of Elementary and Secondary Education
for comment. In its response, the Office of Elementary and Secondary Education offered
technical comments reflecting suggested clarifications on the ESSER I appropriation and
uses of funds for students with disabilities. The full text of the Office of Elementary and
Secondary Education’s comments is provided at the end of the report.

We considered and addressed the technical comments provided by the Office of
Elementary and Secondary Education. However, those comments did not result in
making any substantive changes to the report.

Introduction
Background
Funding for Elementary and Secondary School Emergency Relief (ESSER) was authorized
by three laws: the Coronavirus Aid, Relief, and Economic Security Act (CARES Act); the
Coronavirus Response and Relief Supplemental Appropriations Act, 2021; and the
American Rescue Plan Act of 2021. 3 Our review focused on ESSER funds provided under
the CARES Act (referred to as ESSER I).

3
Public Law 116-136, March 27, 2020; Public Law 116-260, December 27, 2020; and Public Law 117-2,
March 11, 2021; respectively.

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In response to the pandemic, Congress appropriated over $13 billion to the
U.S. Department of Education’s (Department) Office of Elementary and Secondary
Education to award ESSER I funds to State educational agencies to provide local
educational agencies (LEA) with emergency relief funds. These funds were intended to
address the impact of the coronavirus pandemic on elementary and secondary schools.
Subgrants to LEAs were to be in proportion to the amount of funds these LEAs (including
charter schools that are LEAs) received in the 2019–2020 school year under Part A of
Title I (Title I) of the Elementary and Secondary Education Act of 1965 (ESEA).

Title I provides financial assistance to LEAs and schools with high numbers or high
percentages of children from low-income families 4 to help ensure that all children meet
challenging State academic standards. Federal funds are allocated through four
statutory formulas that are based primarily on census poverty estimates and the cost of
education in each State. We identified Title I-eligible schools using National Center for
Education Statistics (NCES) data. According to NCES, for the 2019–2020 school year,
over 70,000 schools, or about 71 percent, of the roughly 99,000 schools nationwide
were Title I-eligible.

According to the Department, the purpose of Title I is to provide all children significant
opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps. Importantly, however, ESSER I funds were not Title I
funds and were not limited to Title I requirements. ESSER I funds could be used for a
wider range of potential activities under several Federal education statutes, including
Title I.

Allowable Uses of Funds
Section 18003(d) of the CARES Act lists the broad, allowable (but not required) uses of
program funds, including any ESEA-authorized activity; activities addressing the unique
needs of low-income children or students, children with disabilities, English learners,
racial and ethnic minorities, students experiencing homelessness, and students in foster
care; purchasing educational technology to aid the educational interaction between
students and instructors (which may include assistive technology and adaptive
equipment); mental health services and supports; and planning and implementing
activities related to summer learning and supplemental after-school programs, including

4
The National Center for Education Statistics (NCES) Elementary/Secondary Information System defines
schools as Title I-eligible based on eligibility thresholds for education grants and stores Title I eligibility
information for schools.

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providing classroom instruction or online learning during the summer months and
addressing the needs of the subpopulations of students noted above.

In May 2020, the Department issued answers to frequently asked questions about the
ESSER I funds, which state that LEAs can use funds to support non-Title I schools and
have considerable flexibility in determining how best to use ESSER I funds. LEAs are
encouraged to use funds on activities to support remote learning for all students,
especially disadvantaged or at-risk students and their teachers, but there is no
requirement for them to do so.

Equitable Services at Nonpublic Schools
Under Section 18005(a) of the CARES Act, LEAs receiving CARES Act program funds must
provide equitable services 5 to students and teachers in nonpublic schools in the same
manner as provided under section 1117 of the ESEA, as determined in consultation with
representatives of nonpublic schools. Section 18005(b) of the CARES Act requires that a
public agency (such as an LEA) must maintain control of funds for the services and
assistance provided to nonpublic schools, and title to materials, equipment, and
property purchased with such funds.

In October 2020, the Department issued guidance explaining that the LEA in which a
nonpublic school is located is responsible for providing equitable services to students
and teachers in that school. 6 LEAs must calculate the proportional share for equitable
services at nonpublic schools in accordance with section 1117(a)(4)(A) of the ESEA. The
LEA may use the proportional share calculated for Title I purposes from either school
year 2019–2020 or 2020–2021.

Funding for Children with Disabilities
The CARES Act did not establish any specific requirements for providing funding to
children with disabilities, and the Department did not provide additional guidance
related to using ESSER I funds for this specific subpopulation of students. Other Federal,
State, and local funding sources directly serve children with disabilities.

5
Educational services and other benefits for children attending nonpublic schools must be equitable in
comparison to services and other benefits for public school children.
6
Department guidance, “Providing Equitable Services to Students and Teachers in Non-Public Schools
under the CARES Act Programs,” October 9, 2020.

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Data Collection Process
Our original sample of 48 LEAs was from four strata: urban, suburban, rural, and charter
LEAs. We selected 12 LEAs from each of the stratum. Two of the LEAs from the charter
LEA stratum did not receive ESSER I funding and were not included in our analysis. We
contacted each of the LEAs and requested ESSER I expenditure information at the school
level for information on total spending at the local level; direct allocations to Title I
schools, non-Title l schools, and for equitable services at nonpublic schools within LEA
boundaries; and direct spending on children with disabilities. We collected expenditure
data directly from the LEAs included in our review by asking LEAs to complete a
spreadsheet with ESSER I expenditures and to provide their allocation and spending
totals. For each expenditure in the spreadsheet, the LEAs designated whether a given
expenditure was for a district-wide program that benefited all public schools, a specific
public school, or for equitable services at a nonpublic school. We refer to this
designation as “expenditure type.” Expenditures for district-wide programs could not be
directly linked to specific schools. For expenditures associated with a specific public
school, we determined whether the school was a Title I-eligible school. We conducted a
separate analysis and asked the LEAs to identify ESSER I expenditures allocated to
exclusively serve children with disabilities. If only a portion of the expenditure was used
to serve children with disabilities, then the expenditure would not have been identified
as an expenditure that exclusively served children with disabilities.

Each LEA reported the total LEA allocation, the total amount of ESSER I funds spent at
the time of submission, the specific schools that directly received ESSER I funds, and the
amount of funds spent exclusively on children with disabilities. We used these data to
determine the percentage and amount of funds spent on district-wide programs, public
schools, and equitable services at nonpublic schools. For public schools that directly
received ESSER I funds, we also determined the percentage and amount of those funds
that went directly to Title I and non-Title I schools. Finally, we determined the total
number of Title I schools in the LEA and the number of those schools that directly
received Title I funds. We did not verify the accuracy of the categorizations provided by
LEAs.

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Observations
We summarize the results of our review in three self-reported funding areas: total
spending at the local level; direct allocations to Title I schools, non-Title l schools, and
for equitable services at nonpublic schools; and direct spending on children with
disabilities. The observations below reflect the combined totals for the 46 LEAs in our
review. The observations are not intended to be used for any sort of projection.

We provided LEAs the option to describe what items or services they purchased for a
given expenditure. Many LEAs reported to us that they used ESSER I funds on personal
protective equipment, staff salaries, cleaning and sanitizing, curriculum and classroom
supplies, and for technology purchases, including laptop computers. However, not all
LEAs included this information, and making determinations on the allowability of uses of
funds was outside the scope of our review. The Office of Inspector General has ongoing
work to review selected States’ oversight of LEAs’ use of ESSER funds.

Summary of Overall Trends
The 46 LEAs reported that they had spent most of their ESSER I funds as of the time of
our review. While ESSER I expenditures were predominantly allocated for district-wide
programs, most of the funds that were allocated to a particular school were allocated to
Title I schools. Some ESSER I funds were used specifically to serve children with
disabilities; however, children with disabilities may have also benefited from ESSER I
funds spent at the district level or at the school that they attended.

Funds Spent at the Local Level
As of March 2022, the 46 LEAs spent over $19.2 million, or about 95 percent, of the
$20.2 million in ESSER I funds that they were awarded, as shown in Figure 1. 7 The four
strata did not differ significantly regarding the percentage of the funding that was spent.
The urban stratum spent over 98 percent, while the suburban stratum spent 86 percent.
The rural and charter LEA strata spent around 95 percent.

7
We did not perform any follow up work to determine the status of the unexpended funds.

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Figure 1. Allocation Spent and Unspent

Funds Allocated to Title I Schools, Non-Title I Schools, and for
Equitable Services at Nonpublic Schools
Total ESSER I Funds by Expenditure Type
As noted earlier in this report, we asked LEAs to designate their expenditures by type:
spending on a district-wide program that may have benefited all public schools, a
specific public school, or for equitable services at a nonpublic school. Our selected
sample included 46 LEAs. Of the 46 LEAs, 32 were multi-school LEAs and 14 were single
school LEAs. Because our analysis focused on how LEAs allocated funds between
multiple schools, we excluded from our expenditure type analysis the 14 LEAs that were
single school LEAs. Of those 14 LEAs, 10 were from the charter LEA stratum, 2 were from
the rural stratum, and 2 were from the suburban stratum.

As shown in Figure 2, the 32 multi-school LEAs spent a total of $17.8 million in ESSER I
funds. Of this amount, $12.9 million was spent on district-wide programs, $4.5 million
was spent directly on public schools, and about $400,000 was spent directly for
equitable services at nonpublic schools. LEAs in the rural, suburban, and urban strata did
not differ materially in how they allocated funds by expenditure type.

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Figure 2. Total ESSER I Funds by Expenditure Type

Some of the multi-school LEAs reported spending much of their funds on district-wide
programs for items such as air conditioning filters or curriculum supplies that benefited
all public schools in the LEA. Other LEAs chose to spend much of their funds on
expenditures that directly benefited specific public schools; funds were spent on items
such as teacher salaries or food service management. Other LEAs allocated a portion of
their ESSER I funds for equitable services at nonpublic schools, which were used to pay
for items such as teacher salaries or learning materials.

Total ESSER I Funds Spent Directly on Schools by Title I Status
Although there was no requirement for ESSER I funds to be spent on Title I schools, LEAs
reported that $4 million (89 percent) of the $4.5 million of funds spent directly on
specific public schools went to Title I-eligible schools. All of the ESSER I funding for
specific public schools in the rural stratum went to Title I schools. About 81 percent of
ESSER I funding for specific public schools in suburban strata went to Title I schools and
about 90 percent of the urban strata went to Title I schools.

Of the 32 LEAs with more than one school, 8 LEAs did not allocate any ESSER I funds
directly for specific public schools. Those eight LEAs spent their funds on district-wide
programs that were intended to benefit all public schools or on a combination of
district-wide programs and equitable services at nonpublic schools. For that reason, we
do not include these LEAs in the summary of the number and funding level of Title I and
non-Title I schools (Figure 3) or the summary of the number of Title I and non-Title I
schools that directly received ESSER I funds (Figure 4).

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Figure 3. Total ESSER I Funds Spent Directly on Schools by Title I Status

Title I Schools that Directly Received ESSER I Funds
Among the 32 LEAs that provided some ESSER I funding to specific public schools, there
were 94 Title I schools. Of those 94 Title I schools, LEAs reported that 75 (80 percent)
directly received ESSER I funds. 8 Thirty-nine of the 44 public schools (about 89 percent)
from the rural and suburban strata that directly received ESSER I funding were Title I-
eligible schools. Of the 50 public schools from the urban stratum that directly received
ESSER I funding, 36 (or 72 percent) were Title I-eligible schools. The 19 Title I schools
that did not directly receive ESSER I funding were located in 6 LEAs. Each of the six had
at least one Title I school that directly received ESSER I funding. Additionally, those
Title I schools may have benefited from district-wide programs administered at the LEA
level.

8
The Title I schools that did not directly receive funding may have benefited from ESSER I funds through
district-wide programs.

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Figure 4. Title I Schools that Directly Received ESSER I Funds

Funds Spent Exclusively on Children with Disabilities
LEAs self-reported expenditures spent exclusively on children with disabilities. LEAs
reported that of the $19.2 million in ESSER I funds that had been spent, $1.9 million
(10 percent) was spent exclusively on children with disabilities and $17.3 million
(90 percent) was not spent exclusively on children with disabilities, as shown in
Figure 5. 9 LEAs in the suburban stratum allocated 7 percent of their ESSER I funds
toward serving children with disabilities, specifically, while LEAs in the rural stratum
allocated 17 percent. The urban and charter LEA strata each allocated about 12 percent.
As noted above, LEAs had the option to describe what items or services they purchased
for a given expenditure. Not all LEAs did so. However, some LEAs reported purchasing
items such as tutoring services and lumber to build partitions for coronavirus response
to exclusively benefit children with disabilities.

9
Our analysis of funds spent exclusively on children with disabilities was separate from all other
analyses and applied to all expenditures, regardless of expenditure type.

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Figure 5. Funds Spent Exclusively on Children with Disabilities

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Appendix A. Scope and Methodology
We selected a random, nonstatistical sample of 48 LEAs from a sampling frame of
17,016 LEAs in the 50 States and the District of Columbia that received Title I funding.
Puerto Rico and other outlying territories were not included in the universe. Two of the
48 LEAs in our sample were not allocated ESSER I funding and were not included in any
of our analyses. The results from this review are not projectable to the population of
LEAs. The funding areas reported only represent the results for the 46 LEAs that we
analyzed and should not be used to form a conclusion related to how funds were used
elsewhere. LEAs submitted expenditure data to the Office of Inspector General between
November 2021 and March 2022.

Sampling Methodology
We obtained the universe of LEAs from the NCES website. The universe was based on
the NCES Common Core of Data for the 2019–2020 school year. The Office of Inspector
General was also involved in two other ESSER I reviews concurrent with this one.
Consequently, the LEAs involved in each of those other two reviews were removed from
our universe to avoid overburdening the LEAs with data requests. We stratified the
universe by LEA type using four strata definitions according to the school location and
geo-assignment in NCES: urban, suburban, rural, and charter school LEA. 10 Charter
schools are nonsectarian, publicly funded schools of choice that are intended to be held
accountable for their academic and financial performance in return for reduced
governmental regulation. Charter LEAs receive Title I funds from SEAs based on the
Title I formulae, just like traditional LEAs.

According to NCES data, all of the LEAs within the rural, suburban, and urban strata
received Title I funding during school year 2019–2020. We were unable to determine
whether the LEAs within the charter LEA stratum received Title I funds during that
period because those data were not available. We randomly selected 12 LEAs from each
of the strata for a total of 48 LEAs. The two LEAs that did not receive ESSER I funding
were in the charter school LEA stratum.

10
See “Education Demographic and Geographic Estimates (EDGE) Program—Geocodes: Public Schools
and Local Education Agencies,” for the NCES strata definitions. For the urban stratum, we combined the
city and town classification in NCES. NCES does not include a geographic location for charter schools, so
charter schools were a unique stratum.

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Stratum Characteristics
We pulled a nonstatistical sample of 12 LEAs from each of the 4 strata. We randomly
selected LEAs from each stratum to be representative of the characteristics of the
stratum, as shown in Table 1.

Table 1. Population of LEAs
Sample LEA
Strata Total Sample Size
Percentage

Rural 6983 12 0.17%

Suburban 2965 12 0.40%

Urban 3011 12 0.40%

Charter 4057 12 0.30%

Totals 17,016 48 0.28%

Schools with larger student populations will have a greater effect on the aggregated
totals represented in this report because those schools generally will receive higher
Title I and ESSER I allocations. Table 2 shows the population of sampled students and
the population of the stratum to show the coverage of the samples.

Table 2. Number of Students by Stratum
Number of
Total Number of Percentage of Students in
Strata Students in
Students Sampled LEAs
Sampled LEAs

Rural 7.2 million 5,872 0.08%

Suburban 18 million 33,670 0.19%

Urban 16 million 80,677 0.50%

Charter 2.4 million 6,419 0.27%

Totals 44 million 126,638 0.29%

Use of Computer-Processed Data
The use of computer-processed data for our report was limited to LEA ESSER allocation
tables for the States included in our review that we received directly from the State

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educational agencies and ESSER I expenditure data received from the LEAs included in
our review. We did not assess the reliability of the LEA allocation tables provided by the
State educational agencies. Also, we did not assess the accuracy of the data provided by
LEAs and performed limited data quality procedures on the expenditure data provided
by the LEAs. LEAs provided the team with the total allocation amount, the total amount
spent, and a list of expenditure transactions. The team summed the expenditure
transactions to verify that the individual transactions equaled the total amount spent, as
reported by the LEA.

Compliance with Standards
We conducted our work in accordance with the Office of Inspector General’s quality
control standards and the Council of the Inspectors General on Integrity and Efficiency’s
“Quality Standards for Federal Offices of Inspector General,” which require that we
conduct our work with integrity, objectivity, and independence. We believe that the
information obtained provides a reasonable basis for our conclusions.

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Appendix B. Acronyms and Abbreviations
CARES Act Coronavirus Aid, Relief, and Economic Security Act

Department U.S. Department of Education

ESEA Elementary and Secondary Education Act of 1965

ESSER Elementary and Secondary School Emergency Relief

LEA local educational agency

NCES National Center for Education Statistics

Title I Part A of Title I

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Office of Elementary and Secondary Education Comments

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