Welcome and Thank You for Joining — Department of Education (April 25, 2024)

Summary

A transcript dated April 25, 2024 of a Department of Education Office Hours session on American Rescue Plan liquidation extensions, introduced by Christopher Tate, group leader of the Office of State and Grantee Relations. The speaker states that a Dear Colleague letter released that day invites a waiver to extend the period of availability for fiscal year 2022 administrative funds that states consolidate, allowing those funds to be extended through March 31st, 2026. It states that the department approved extensions for approximately $26.9 million for CARES Act grants through March, 2024 and that extensions for 44 approved grants run through March, 2025, amounting to $505 million in funds remaining available for liquidation. The transcript is marked by speaker and timestamp and includes a question period.

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Full text

Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice



Speaker 0 00:00:00 Welcome and thank you for joining today's O ice Hours American Rescue
Plan, liquidation Extensions. Please note this conference is being recorded and all audio
connections are muted at this time. If you require technical assistance, please open chat with the
associated icon at the bottom of your screen and send a message to the event producer. You may
also submit written questions throughout the conference by selecting all panelists from the
dropdown menu in the chat panel. With that, I'll turn the conference over to Christopher Tate, group
Leader, o ice of State and Grantee Relations.

Speaker 1 00:00:34 Thank you. Before we get started with today's O ice Hour focused on
seeking American Rescue Plan, SR. And E'S grant liquidation extensions, I want to note a Dear
Colleague letter that was released by the department just an hour or so ago. The department will be
inviting a tidings waiver to extend the period of availability for fiscal year 2022 administrative funds
that states choose to consolidate under the Elementary and Secondary Education Act, section 82 0
1. That means that states with remaining arp, Esser, arp, eams, and ARP HCY program
administration funds may consolidate those funds with fiscal year 2022 ESEA program
administration funds. This waiver will allow states to extend these administrative funds through
March 31st, 2026. More information about how to seek a request will be shared on Monday, April
29th. You may register for that webinar at the link being shared in the chat at this, at that time,
rather, OSCs leadership will also take any questions that you might have. So we ask that you take a
moment to review the letter and come prepared for Monday's webinar to ask any questions that you
might have. Next slide, please.

Speaker 1 00:01:58 Today I'm joined by my colleague Jennifer Timmons. Jennifer is the lead for
implementing the Liquidation extension process in the O ice of State and Grantee relations. Our
goal for today is to ensure that we share out information about the process for seeking and approval
to extend the period of liquidation for our act, ER and RPAC teams grants. Today's presentation was
developed using responses to questions that we have received from grantees since the department
announced the opportunity to request an extension for a ACT grants back in January. We'll move
quickly through the prepared material today, so there's ample time to address questions at the end
as we move along, though please don't hesitate to place questions in the chat. Next slide please.

Speaker 1 00:02:48 First, an update on extensions for CARES ESSER N Gear. In addition to
Carissa Esser gear and eams, 2023 states requested and were approved to extend the period of
liquidation for CARES Act SER and Gear grants combined the department approved extensions for
approximately $26.9 million for liquidation through March, 2024. Additionally, the department has
to date extended the liquidation period for Carissa approved grants, 44 of them to extend the
liquidation period for Esser year and EAMS through March, 2025. This amounts to $505 million in
funds remaining available for liquidation for services, and continued support for pandemic recovery
for students and educators. While the time for seeking an extension to the period of liquidation for
CARES Act grants has passed, grantees that have not yet sought an extension may still do so for
Carissa Act grants through the remainder of this year. Next slide, please.

Speaker 1 00:04:01 That brings us to the current opportunity to request an extension to the
period of liquidation for ARP funded Esser and S grants. As you know, on January 9th, 2024 to
department released its process for submitting an ARP Esser and ARP E'S liquidation extension
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

request and provided an explanatory letter outlining the process, an updated request template, and
updated technical FAQ's document. These resources are available on the department's program
website and SG r's deadlines and announcements webpage. Additionally, we will provide the links
to these documents in today's chat. For your convenience, the opportunity to seek an extension
was provided well in in advance of the September 30th deadline for obligation for obligating these
ARC funds, excuse me, so that grantees and other sub-recipients had adequate time to consider
their needs and make adjustments to their plans when continuing to implement ARC funded
activities through March of 2026. The request process for ARC funds is the same process
implemented by the Department for CARES and Karissa, as with Cares and Karissa requests may
be submitted when data is available, and grantees have already three grantees, excuse me, have
already submitted requests that are currently under review. The review of these requests happening
well in advance of September 30th requires grantees to submit a complete request, and I'll speak
more on that in just a moment. Grantees may submit, an ex may submit a request to extend the
liquidation for our funds at any time, but submission is recommended by December 31st, 2024, as
requests submitted after December 31st may experience a lapse in G six access while an approval
decision is pending. Next slide please.

Speaker 1 00:06:07 I touched briefly on the submission process a moment ago, and I want to
come back to it now. The process to submit an A liquidation extension mirrors the process
employed for cares and ISSA with a minor edition of a cover letter. Grantees still collect the
liquidation extension information noted in the template on behalf of themselves and their sub-
grantees 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 a single row. We are not requesting a line by line accounting of each
subgrant recipient uses of funds. Grantees then submit one comprehensive Excel document to
represent an extension at the grantee and sub-grantee levels as appropriate with a single date for
the extension, new for the ARC request process, grantees must include a cover letter that explains
how the ARP Esser and or ARP E'S liquidation extension request contributes to the acceleration of
academic success for students, including those furthest from opportunity and demonstrating the
greatest need provide a grantee, a grantee pro must provide our o ice with a complete request
review and approval on average has taken about three to four weeks, and the approval depends on
the completeness and accuracy of submitted information.

Speaker 1 00:07:48 And again, I'll touch more on that in just a moment. Before I review the cover
letter requirements, I want to pause and answer a question that we've received multiple times. Do
grantees and subrecipients have to pause obligations or liquidations while waiting for the
department to complete its review? Once a complete request is received from state, the
department will work quickly to complete its review, complete any follow up required with the
grantee for any necessary clarifications, and notify the state of its determination. Depending on the
time of the year at which the grantee submits its request, grantees and subrecipients should
continue to complete obligations up to the end of the obligation period, meaning September 30th,
2024. If you submit a request during the statutory liquidation period, grantees and subrecipients
should also continue to liquidate those funds up to the end of the regulatory liquidation period.
January 28th, 2025. Next slide please.
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

Speaker 1 00:09:01 As a reminder, reminded folks a moment ago, new to the process for ARP
SER and Ian's extensions requests is the requirement that grantees seeking a request submit a
cover letter along with the state's completed request template. In the cover letter, grantees are
encouraged to highlight investments in three, three evidence-based strategies that significantly
contribute to improved student performance. Note that you may limit your cover letters to no more
than two pages and should feel, should feel comfortable keeping examples concise without the
need for providing data analysis at any great depth. The information provided will be followed up on
after the approval of a grantee's request during the period in which the department provides
oversight for the grantee's implementation of its approved request. This includes during ongoing
discussions about progress towards student academic and other goals when monitoring of ARP SR.
State plans. Information provided in the cover letter may additionally be further reviewed for the
provision of future technical assistance or shared with the Department's Institute for Education
Statistics. I do want to note that a grantee's cover letter has no bearing on the department's
approval decision. Next slide, please.

Speaker 1 00:10:27 Finally, before I turn the presentation over to my colleague Jennifer, I want to
reiterate, as some grantees have asked, that approval of a request is a function of completeness of
the information and the timeliness and validity of an obligation. A complete request includes a
reliable estimate of the funds to be liquidated during the period of extension for both the grantee
and any included sub-recipients. The estimate of funds to be extended will be monitored during
implementation, and a truer accounting of funds is determined closer to the end of the liquidation
period. It is expected then that the grantee and any sub-recipients will provide an accurate
forecasting of funds to be extended. A partial request, one that only includes the state's forecast or
a request that only includes subrecipient information will not be reviewed when the state submits
its request for review. It is assuring the department that its, its request is complete and that the
included information is reliable.

Speaker 1 00:11:38 During implementation, the department will continue to review the data and
work with grantees to amend their requests as the financial landscape changes. For example, a
subrecipient may estimate in June for the purpose of seeking an, uh, for the purpose of having an
approved extension in hand, that $300,000 is needed for a project, and then after September 30th
report that only 250,000 needs to be liquidated during the extended period. In this example, the
other 50,000, uh, was timely, obligated and liquidated for another purpose. After the original
project's cost changed, this will not trigger any need for a formal approval. Instead, SGR will work
with the grantee to amend its request and continue to monitor the liquidation of the amount of
funds for that subrecipient through the end of the liquidation period. An amendment is not about
seeking formal approval from the department to continue to implement the state's extension.

Speaker 1 00:12:45 It is a process by which the department and the grantee are in agreement
about the amount of funds to be liquidated as the data changes. Our goal is to work with you to
ensure that we receive requests that are approvable, IE we have requests that are complete and
reflect timely and valid obligations, so you can more quickly move, you can more quickly move
forward, rather with an approval in hand to date. As a reminder, the department has not
disapproved any state's requests for an extension. Now I will turn the presentation over to Jennifer
to advise you on the development of approvable requests. Jenny.
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

Speaker 2 00:13:28 Thank you, Christopher. Uh, next slide please. We'll spend some time now a
bit on the request document itself and some considerations for states as they prepare liquidation
extension requests. There are some common revisions that can be addressed pretty quickly by
grantees, but do require follow up from, uh, the o ice of state and grantee relations. And so if states
can ensure that the personnel who are familiar with the ARP SER and e programs are reviewing the
request prior to submission, uh, we can cut down on that back and forth from the program o ice.
Uh, some easy things that, uh, sometimes involve a lot of typos or perhaps wrong references to
years are the a LN number, the PRN number or the PR number and the award amount. Uh, the a LN
number is what used to be referred to as the CFDA and the numbers that you're going to utilize for
arp, esser, or aines are included on the tab for the grantee information.

Speaker 2 00:14:32 Additionally, sometimes we'll see a grantee has submitted a PR number that
may reference a di erent iteration of the funds or, uh, perhaps, uh, a di erent program. And so
double checking that can be very helpful as well. We also want to ensure that the award amount is
inclusive of the entire state's award and, uh, including any supplemental awards that might have
been, uh, might have been awarded. An additional area to double check is the dates that are
requested for the grantee, as well as the dates that are requested for the sub-recipient. Uh, often
what we'll see is that a grantee might leave the grantee date blank because they aren't requesting
any state level funds. Uh, and that is, that is fine, but ultimately the grantee is the one who is
drawing down those funds on behalf of those subrecipients who might be included in an, in an
approved extension.

Speaker 2 00:15:27 And so what we would suggest is that grantees insert a date that is either the
same as the subrecipient or allows for some additional time for administrative processes to take
place at the state level to close out those liquidations. It's also good to note that this tab is where
you do want to start entering your information for the request template as it does feed information
and sells on the other tabs. However, that also means that if there is some incorrect information
inserted on this tab, it will also carry over to the other tabs, most notably to the grantees at a
station. And submission of these complete requests without some of these minor revisions will
result in a more expedient review. Next slide please.

Speaker 2 00:16:20 Another area where a program o icer in SGR might need to reach out to a
grantee after submission relates to the information that's included on the grantee or the
subrecipient information, particularly in the use of funds, the justification and the data notes
columns. In general, Mo almost all follow up questions are related to clarity around the timing of the
obligation. As previously stated, all obligations must be completed within the program's
performance period or by September 30th, 2024. So let's take a look at the example that's listed at
the top of the slide for a state request that might need some additional clarification. In this
example, the sub-recipient has listed supplies, materials, and temp sta ing costs. And in its
justification, it references that the school district experienced sta ing issues and will be able to
spend the funds with more time in general references to sta ing or salaries and personnel typically
raise more questions, particularly if the information included in the use of funds or the justification
lacks some specificity or detail, or if it's unclear to the obligation of the personal services through a
third party.
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

Speaker 2 00:17:37 And also in general, references to needing more time to spend the funds or
finalize contracts. Usually also raise questions for grantees or sub-recipients about when and or if
those funds were properly obligated. A stronger request like the one that's shown at the bottom will
include that level of specificity, uh, around these matters and provide enough information to clearly
indicate proper and timely obligations or, uh, information that's related to personal services.
Grantees want to avoid having the same use of funds or justification just copied and pasted for
each sub-recipient. So that really there's an indication of, uh, what kinds of funds are needed for
the extended period, as well as why those funds were in particular were needed. Additional
examples that are, uh, requests for arp, SER and arp EAMS are included in the technical assistance
slides that were presented in January of this year, and those are available on the department's
program resources website for both Esser and for E Ns. A question that we have received quite a bit
from grantees is, can a state separate out the grantee funds by projects or does all of it have to be
included in one line of cost on that grantee information tab? And certainly if that would, uh, help the
state be a more complete request, states may separate out their specific costs, projects,
administrative costs, or the required reservations on the grantee tab only, and should indicate
enough detail within the use of funds or justification or notes column to delineate why those costs
have been separated.

Speaker 2 00:19:30 Next slide, please. Additional considerations for states as they're preparing
their liquidation extension requests really can be grounded in the attestations found on the
attestation tab. And as a reminder, complete requests will include the signed attestations from an
authorized grant individual, and we have those attestations listed here. So let's take a closer look
and we'll discuss some of the questions that we've received in relation to these. But the first
attestation is that all information is complete and accurate, and as Christopher has already
referenced, a state's complete request should reflect a reasonably accurate forecast of funds to be
liquidated during the period of extension for both the state and its sub-recipients. And then during
implementation, as better data becomes available after the obligation period and liquidation
period have concluded, states may either amend their approved requests or provide updated data
during the data verification process. A second attestation is that activities and services included
are allowable and have been properly obligated by September 30th, 2024. Uh, we have referenced
those dates multiple times, uh, and just want to remind uh, everyone about those obligation
requirements. And that is a attestation that works right along with the third attestation that
certifications and assurances included in the award documents, uh, and approved state plan do
remain in e ect, which would include any required reservations or administrative cost limits.

Speaker 2 00:21:04 The next attestation will take a look at is that grantees will provide continued
monitoring and oversight of sub-recipients in the extended period. Uh, approved liquidation
extensions will be monitored in a manner consistent with the department's oversight of its
grantees, and will also include evidence of the grantees oversight of the extension process, and its
monitoring of sub-recipient expenses for timeliness and allowability. And so it's incumbent upon
the grantee to determine the state's particular processes for providing this oversight. Uh, additional
information related to program monitoring specific to liquidations is available on the esser gear and
e liquidation extension monitoring protocol, and that might be a useful resource as the state is
preparing its own processes. And I see that my volume keeps going out. Hopefully you can still hear
me. Uh, so I will,
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

Speaker 3 00:22:04 You're good now.

Speaker 2 00:22:06 Okay. I will try to turn my volume up and make sure I'm closer to the mic.
Thank you, Christopher. Data verification is also an attestation that will be provided as requested.
Uh, if a grantee finds out after receiving, uh, approval that other subrecipients have extended
liquidation needs or approved sub recipients need additional funding, a question that we've often
received is, is the grantee able to include those sub recipients or those di erent costs? And so, as
we've mentioned, a complete request should reflect a reasonably accurate forecast of funds.
However, if a state does realize that a subrecipient needs to be included that wasn't initially
included, they can reach out to their program o icer through the state mailbox and inquire about
the amendment process. Uh, an amendment will include submitting just an updated request
template with the changes that are clearly noted and the provision of an updated attestation.

Speaker 2 00:23:09 We've also received a, uh, several questions about what happens if sub-
recipients are no longer in need of an extension. So let's say, for example, that a sub-recipient
anticipates in June that they are likely going to need an extension because of a delayed project that
has been properly obligated, but it turns out they're actually able to liquidate before the end of the
liquidation, the regular liquidation period. And if that is the case, that's certainly not a problem.
We'd, again, encourage, uh, grantees and subrecipients to continue with their liquidations in a
timely fashion, and that's something that can be updated with the program o icer through the data
verification process. Or if the grantee finds a need for an amendment for other, uh, other needs or
other sub-recipients, they can update the data at that time.

Speaker 2 00:24:04 An additional attestation is that su icient documentation to support the
request as available with the grantee or sub-recipient. And a question that we've received, uh, from
grantees is, is there a need for a grantee to change its payment processes to gather additional
documentation for liquidations during that extended period? And just as it's incumbent on the state
to develop its processes for the collection of the information to develop the request, it's also
incumbent on the state to develop its, uh, processes for continued monitoring and oversight of the
associated subrecipient liquidation. So a state might, for example, collect a sampling of that
documentation during monitoring, but it could also choose to collect separate reimbursement
information consistent with the way that it collects information during the regular liquidation
period. There's not a specific need to change the state's processes. We do remind grantees and
sub-recipients that as noted in question seven and eight of the liquidation extension FAQs. Records
do need to be maintained consistent with two CFR 200.

Speaker 2 00:25:15 And the final attestation is that sub-recipients have been assessed for risk
using relevant data and a question. This is an area where we do receive a lot of questions primarily
around the idea of how risk is determined and, uh, if only low risk sub-recipients are allowed to
apply for extensions. We'll, again, point back to the technical FAQs for liquidation extensions,
particularly question 13. Uh, because grantees are required to determine the subrecipients risk or
their capacity for liquidating funds within the extended period. However, grantees have flexibility
consistent with their methodologies for evaluating sub-recipient risks and how that determination
is used. So a grantee may choose to provide extensions only to those subrecipients that are de
determined to be of lower risk, but that would be the grantee's decision. The department provides
grantees with the flexibility to determine its treatment as well of subrecipients as well. So a grantee
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

might also, uh, perhaps include a higher risk sub-recipient, but perhaps provide additional support
to that subrecipient during the extended liquidation period.

Speaker 2 00:26:31 As a reminder, when determining the sub recipient's capacity to timely
implement its extension consistent with program requirements and other federal regulations, a
grantee can exercise discretion in its consideration of risk factors using the data it has available,
including risk assessment data for other federal programs, single audits, a history of, uh,
satisfactory or unsatisfactory performance, uh, the ability of the subrecipient to access
management systems that meet appropriate regulations. Whatever data the grantee determines is,
uh, adequate for this analysis is, uh, is the grantee's prerogative. Next slide, please. As we've
referenced before in our technical assistance, 34 CFR 76, 7 0 7 details, the specific types of
obligations and the date by which those obligations are considered to be made. As a reminder,
everything needs to be obligated by September 30th, 2024, and that does extend to any obligated
costs that are included within the liquidation extension request. And so we encourage states as
well as their sub-recipients to carefully consider these di erentiations when they are reporting their
properly obligated funds to be included in that request.

Speaker 2 00:28:00 And so a particular note is that obligation of personal services, which can be
obligated, um, um, excuse me, services that are provided by an employee of a state or a sub-
grantee such as an LEA, are considered obligated when the services are rendered or the work is
performed. On the other hand, personal services rendered by a contractor who is not an employee
of the state or sub-grantee or LEA, are considered obligated on the date on which the state or sub-
grantee makes that binding written commitment to obtain the work such as through the execution
of a contract. So with those definitions in mind for obligations, payroll expenses for employees of a
state or sub grantee may only be liquidated with RPAC funds for services provided by the end of the
obligation period or September 30th, 2024. If there are expenses related to personal services of
sta members that are obligated through a third party contractor, those may continue through the
liquidation period as long as the associated contract for those services has been executed by the
obligation deadline or September 30th, 2024.

Speaker 2 00:29:15 A reminder that approved liquidation extensions will be monitored in a
manner consistent with the department's oversight of its grantees, and this will include evidence of
the grantees oversight of the extension process and its monitoring of sub-recipient expenses for
timeliness and allowability. So again, we do encourage grantees and their sub-recipients to, uh,
carefully consider the obligation definitions. If there is a particular type of obligation that a grantee
or a subrecipient has a question about, please reach out to your program o icer through the state
mailbox, and we will work with you on the parameters of those obligations. Next slide, please.

Speaker 2 00:30:01 An additional resource that we have referenced several times in our
technical assistance is that grantees and sub-grantees with approved extensions may carry out
grant activities during the period of liquidation of the ex or the extension of that period as approved
by, uh, the department. So long as that timely and valid obligation has been made pursuant to 34
CFR 76, and if the state and local procurement laws allow. And so in seeking an extension, a
grantee might identify activities that will extend beyond the liquidation period. And so the
department has provided some additional guidance on this matter to grantees in both the updated
SER FAQs in question E 3D, as well as the e NS communications, uh, specific to E NS services and
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

assistance after the end of the period of performance. So, in a nutshell, in limited circumstances, it
may be allowable for program funded activities to continue after the obligation and liquidation
period, but there are a number of factors that should be considered when determining whether that
continuation of activities, uh, would be allowable within a particular state's context.

Speaker 2 00:31:17 And so some of those considerations include whether or not those funds
were properly obligated in a timely manner, whether the activities would be allowed to extend
beyond the liquidation period under the applicable state and local procurement rules, whether the
extended activities constitute a reasonable and necessary use of federal funds. And finally, whether
prudent business practices and internal controls would support the continued activities for the
length of time that's proposed in the liquidation extension request. Because Esser and EENs or
state administered programs, the SEA or the Governor determines whether activities extending past
the liquidation period are allowable under the circumstances and should really only do so after
considering each of those factors that we've discussed and how they impact a particular expense, it
should be noted that, uh, an S-E-A-L-E-A or sub-grantee would be responsible for returning to the
federal government the cost of any services that were paid with federal funds but not received. And
under no circumstances may services extend beyond the date on which funds revert to the US
Department of Treasury, which occurs four years after the obligation deadlines. However, nothing
prevents an SEA or an LEA from continuing successful activities or services with non SER or ES
funding. Again, if you do have specific questions about this guidance or specific examples of uh,
activities, when you are preparing your request, please reach out to your program o icer. Next slide,
please.

Speaker 2 00:33:00 We've referenced several times today that the approved liquidation
extensions will be monitored in a manner consistent with the department's oversight of its
grantees, and that will occur primarily through the monitoring of drawdowns during the extended
period and through formal reviews. Drawdown monitoring is an essential internal control, and
during the extended liquidation period, grantees are placed on what is called route payment once
the regular liquidation period has concluded. So grantees would then need to submit a summary of
each drawdown request, which includes the amount that is associated per entity that is included
within that draw. SGR will then ensure that the funds and the entities are aligned to the state's
approved request and any previous draws of funds, and that an amendment is not needed. Formal
reviews will include ongoing data verification and a review of the grantee's oversight activities at
least twice during the implementation of the state's extended liquidation period.

Speaker 2 00:34:05 As we've noted previously, once the regular liquidation period has
concluded, program o icers will work with a state to validate the data that's included within the
state's approved request. And formal monitoring will address the grantees processes for seeking an
extension, their monitoring of, uh, included sub-recipients, their closeout request activities, and
the status of liquidations to date. It will also include a review of grantee reimbursement request
packages and an as the associated documentation, either from subrecipients or the grantee's
internal processes for drawing down funds that were included within an approved request. Again,
additional information related to these formal reviews is available in the SER and e liquidation
extension monitoring protocols, which are posted on the department's program websites. Uh, next
slide please. So we've reached the end of our formal presentation, but we'll certainly open the
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

presentation for questions. Uh, and I know I think we've seen several that have been added into the
chat. So, uh, Christopher, if you want to get us started,

Speaker 1 00:35:21 I'll jump in. Uh, Jenny, we had a, a question early on about, um, asking
whether a liquidation extension requests are required if a grantee seeks a waiver for the
consolidated administrative is administration funds. The, um, the approval of consolidated
administrative, uh, funds request is not dependent on the state, um, seeking a liquidation extension
request, obviously, um, because the only, uh, funds that are being extended for those waivers are
the administrative funds. You know, we as, as a program o ice would continue to, um, monitor any
funds that might be drawn down during that, uh, extended period, but it would not require, um, a
grantee to submit a liquidation extension, um, in order to seek that waiver.

Speaker 2 00:36:31 I'm just scrolling through the comments. Thank you to all of you who
responded to the prompt. Mary put in the chat about whether or not you plan to apply for an
extension. We appreciate that information.

Speaker 1 00:36:52 Do we have any folks who'd like to raise their hand and come o mute and
ask a, a question about either the, the request process or, uh, the department's oversight during the
period of an extension?

Speaker 0 00:37:08 Everyone you can use chat to send questions to all panelists or click the
hand icon at the bottom of your screen to join the queue and ask a verbal question.

Speaker 1 00:37:20 We have another, uh, question that, that came in. Um, and it is whether or
not a state can submit multiple extension requests or submit requests on a, on a rolling basis. A
state can submit a single Arps o request that is complete, meaning it in it, in it includes forecasted
information for funds to be liquidated during a period of extension for both the state and its sub-
recipients. Um, and then it will additionally submit a template for its ARP e ns, uh, program,
including any, uh, funds that are extended for services to non-public schools, but also funding
reverted e ns funds rather, uh, that are being used for any purpose allowable under gear two. What
is not permissible, and I think maybe this might be the root of the question, is you as a state
wouldn't submit to us a request that is only for the state's, uh, the state's portion of funding to be, to
be liquidated during the period of extension.

Speaker 1 00:38:26 Because one of our first questions back is going to be to ask, um, whether or
not you anticipate subrecipients will additionally be included. Um, so when we talk about a
complete request, it is the expectation, much like Janice spoke to the state attesting, that it's its
request is inclusive of all of its sub-recipients. So you, you as a state reached out to your sub sub-
recipients and identified the amounts to be extended. You as a state have, have determined the
amounts to be extended in those two things together are included in a single request. At that time,
we would consider it complete and be able to move it forward for approval.

Speaker 2 00:39:13 Cheryl's going to read another question we've received in the chat. Uh, we
have a question for grow your own types of activities. If a state has made sub-board to LEAs to carry
out the activities with IHEs, would LEAs and sess need to submit these projects for late liquidation
or just the LEAs? Uh, really how that is going to be determined is where the sub-award is. So if the
sub-award was to an LEA, they could be included on the sub-recipient tab. If instead that was an
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

award project out of, let's say the state's, uh, uh, set aside reservation, and the state is really
managing that project, it would be included on the SEA or the grantee side. So it would really deter,
it would really be determined more so where that sub, where if a sub-award exists and where that
sub-award is. Thank you again to everyone for putting your, uh,

Speaker 1 00:40:37 Oh, I'm sorry. Your

Speaker 2 00:40:37 Information in the request.

Speaker 1 00:40:41 Sorry, I, I think I was on,

Speaker 2 00:40:47 Were you addressing a question, Christopher?

Speaker 1 00:40:52 I think I accidentally hit my button, my mute button. Um, the, the, the
question that I wanted to step back and answer is that there was a question about rolling, uh, rolling
requests and what the, um, the state representative was asking is that they have subrecipients
ready to submit a request now, and they want confirmation that it'll be re approved, but they'll also
have subrecipients that may submit later because of unexpected delays. And so what, in a situation
like that, what we would recommend is that you go to those subrecipients that are anticipating
submitting later and ask them, you know, now for, for a realistic expectation for those projects that
may be delayed, that would be, you know, a, a forecast so that the approval that we're providing is a
true, is a true and accurate picture of all of the entities that may need to use those, use those funds
during that period of extension.

Speaker 1 00:41:55 As we monitor during the implementation of that request, and we've seen
this with both Carissa and Cares, some subrecipients will find that the status of some of their
projects have changed. And so by the time at which the extension starts after January 28th, 2025,
they will have either liquidated all of those funds or a portion of those funds. And so the amount
that will actually be extended is smaller. We, as an o ice, go through a process that we call data
validation. And so what that means is, during the implementation of the request, um, not only are
you providing us information about costs that are associated with each, uh, reimbursement that
you seek to draw down from, from G five, we will occasionally reach out to you and walk through
your request. And if we identify with you, or even you proactively identify for us that you have some
sub-recipient data that has changed, that's where it would be an amendment process.

Speaker 1 00:43:02 And that amendment process is very easy. And we've designed that in part
because we understand that better data will become available on somewhat of a rolling basis. This
allows you as a state to come in and seek approval, for example, of an our ESSER program, knowing
that some of the sub-recipients that might have initially been hesitant because they don't have a
complete, and what they would consider accurate picture to seek a request, their information is
initially included. They have done some forecasting on the projects that they think may be delayed,
and they're able to then also receive that approval at the same time all of the other subrecipients in
their cohort receive approval. And what we have found with CARES and Carissa, is that that process
has allowed two things. It has created a comfort level, um, with subrecipients, with making sure
that should they want to make adjustments in this process prior to September 30th, they have that
approval at hand, which I think is what is part of what this question is really about, and can feel
comfort forward planning for what will occur during that period of extension and ensure that all of
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

their obligations and project plans are in place as of September 30th, so that they're maximizing the
opportunity to use these funds during this period of extension.

Speaker 1 00:44:39 Yep, that's exactly right. You can always amend the, the request downward,
um, as that better data becomes available.

Speaker 2 00:45:30 I see we have a request, uh, if our event producer could go back to slide 11,
we have a question about personal services and when they're obligated by a contractor, whether
the date to liquidate funds is set forth in the contract. Uh, so the, the di erence there with, uh,
contracted services, you're really looking at the date that the, uh, that the contract or the obligation
is actually made, and that would be on the date on which the written binding written agreement is
executed. And so if that has been obligated prior to the end of the obligation period, uh, September
30th, 2024, then those services could continue. But again, that's specific to a contract or a third
party, uh, contract, not the employee of a state or the employee of a locality. And I think also your
question is asking whether the date to liquidate funds is set forth in the contract. Uh, I think that
would likely depend on your local practices for what needs to be included in a contract, um, the
obligation date. Again, as long as those obligations have been put into place prior to the end of the
obligation period, those activities could continue.

Speaker 1 00:47:04 We have, um, we have another question that's come in. If the state has a
district that's doing a construction project that's experiencing delays and won't be done until
November, but it was properly obligated by September 30th, if they're approved for a late
liquidation, the construction can still continue in October and November. This is a great question,
and we actually just received a similar question from a, uh, from a grantee in the last week or so. In
the instance where a district has experienced some delays and the funds are properly obligated, if
the work were to be completed and the liquidations were to occur prior to January 28th, 2025, that
district would not need to then seek a liquidation extension. So the, um, the statute that governs
the, um, the requirements related to the administration of funds by a pass through entity allows 120
days beyond the, uh, period of performance to fully liquidate those funds. Now, there are
sometimes state and local rules around when work can continue during that liquidation period. And
so obviously, um, that will depend on, on, on whatever those state and local rules are. From a
federal perspective though, um, if that work is, is completed and the reimbursement occurs prior
to, uh, January 28th of any given, uh, year following the end of a performance period, and the funds
were properly obligated, that district would be able to wrap up that project.

Speaker 0 00:49:07 And just as a reminder, you can click the hand icon at the bottom of the
screen to raise your hand and ask a verbal question.

Speaker 2 00:49:35 Right. We've gotten a little bit of a follow up, uh, in the example of the LEA
with construction, uh, that if the LEA is nervous about potential supplier construction delays,
should they go ahead and submit the extension request just in case and we would amend if they
finished up on time after all? Uh, and yes, that would be, that would be appropriate. Uh, if the LEA
has, uh, you know, based on previous delays that have, uh, been surrounding a particular project
and they think they might need, uh, or an extension, they can certainly be included in the state's
request. We've actually had some states who, uh, have included in their notes, perhaps for an LEA
that a project is anticipated to be finalized in December, which leaves maybe a month to get that,
that liquidation. And so they go ahead and include them on the request. And if it isn't, if it doesn't
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

end up being needed because the LEA is able to liquidate on time, that's certainly not a problem,
but they could be included in that request just so that they have that assurance. If they need just a
little bit more time to finalize liquidations,

Speaker 1 00:50:51 Let's go to the hand that's raised. If you want to go ahead and unmute,
unmute it, and then we'll come back to Colorado's chest question in the chat.

Speaker 0 00:50:59 They put their question in chat, their hand is no longer raised.

Speaker 1 00:51:02 Oh, excellent. Um, and so, um, the question that we received is that the
state, uh, requires requests for reimbursement to be submitted by November 13th to give them
time to make payments and liquidate funds. If we extend that deadline for LEAs to submit requests
for payments, can the SEA request a liquidation extension to finalize payments to its LEAs in an
instant like that? An instance like that? What we would recommend is that, um, rather than seeking
a liquidation extension, which might put the state, um, assumes rather that the state and the
subrecipients will continue to implement their activities, uh, through a given date. Um, we would
just ask that, as with all other federal programs, the state might submit to us, uh, a regular late
liquidation request. And we had a few states that have recently been approved to do this for, for
Carissa. And what that would mean is much like with an extension, it's very much the same, same
policy.

Speaker 1 00:52:11 You would instead just submit a single request with some documentation
that submits why you as a state might need to do one or a series of smaller draws that would last
for, you know, 15 days or 30 days, because you need time to reconcile those, those, um,
reimbursements. So if that were the case, if there were no work from these LEAs that was going to
continue beyond the liquidation period, you know, then we would provide some guidance around
how to submit what, what we internally kind of call the onetime, the traditional late liquidation
request that any state, uh, can request, uh, from the department if they're in a situation where they
need to do a onetime drawdown of funds after the liquidation period is ended. And part of the
reason that, that we do that, it is the, the same policy, the things that we look for in the way that we
monitor and implement those true requests, um, are slightly di erent. Again, because this one time
process for, uh, pandemic relief programs, the extension is really about understanding and
accounting for, in a meaningful way, the work that will continue and ensure that both the grantee
and their sub-recipients have ex have access to funds to continue activities beyond that January
28th date, unlike in a situation like the one, uh, that you're proposing through your question. And
happy to, uh, have your program o icer reach out to you if you have specific questions about that
one time, uh, the late liquidation process for grantees that do not seek extensions.

Speaker 1 00:53:53 Jenny, anything to add there? I feel like I felt like that was a more complicated
answer <laugh> than maybe I thought it would be.

Speaker 2 00:54:01 No, I, I think you caught it all. Um, the only thing I would add is that if you
have a combination of subrecipients, uh, maybe some subrecipients who do truly need an
extension to, uh, continue services, and it's, it's less about finalizing that last drawdown for the
state. If you are going to be, uh, applying for an extension anyway, those costs could be included for
those subrecipients in, uh, in an extension. And again, as Christopher referenced, uh, your program
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

o icer can work with you about the best path forward and how to, how to reiterate that within a
request.

Speaker 1 00:54:46 And we have another question that came in. Jenny, if a subgrantee signs an
executed contract prior to 9 30 24 for professional development, could they have professional
development services after 9 30, 20 24? If so, for how long?

Speaker 2 00:55:06 Right. So there's a couple of questions in there. So again, those, uh,
obligations are for the most part that, uh, binding written commitments. So yes, in theory and
generally speaking, uh, if a contract is executed prior to 9 30 20 24 for professional, uh,
development experiences, yes, those services could continue if that's, if those are included within
the terms of the contract, um, certainly you would want to take care of ensuring that, uh, you're
looking at services that are provided. Um, if you're talking about conferences, which brings up
travel, that is a, those are di erent types of obligations. So, um, but if you're specifically talking
about, let's say, um, you are engaging with a third party contract to provide some instructional
coaching for your brand new teachers for, uh, the 24 25 school year, and you want to continue that,
uh, those series of services through the end of the school year, uh, to June of 2025. That's an
example where if that contract is set up prior to November, prior to September 30th and is executed
by that date, then yes, those services could continue. And you also have, uh, if so, how long can
they continue? Uh, we would, uh, reference you back to the, uh, Esser and Gear FAQ's question E
3D. Uh, some of that will be dependent upon the state and its policies. Uh, the length of the activity
of those continuing services would need to be necessary and reasonable, certainly from the state's
perspective, uh, and would also need to, uh, be within what would be generally accepted, um, as
good internal processes and controls. Anything that you would add to that, Christopher?

Speaker 1 00:57:07 Uh, the one thing that I think is really important here is that, um, depending
on the path that the district takes, we would certainly expect that those services would end, um,
within four years after the, um, the end of the performance period, because that's the time at which
the, any remaining grant funds or return to the treasury. And so we would anticipate that if, for
example, there were an issue with this contract, that there would be a way, a mechanism by which,
um, funds would not be lost and are able to be returned by, uh, to the federal government within
that, within that period.

Speaker 1 00:58:08 So Jenny, I see that we are at the four o'clock hour. Um, I think with that, if
there are no more questions in the chat, we will go ahead and wrap it up for today. But we do
encourage you to please, as you have questions and you're developing your, your requests, um, feel
comfortable reaching out to your state's program o icer, you can do that through your state
mailbox. So it's state name dot oe@ed.gov, for example, Alabama dot oe@ed.gov. Um, and we are
working very quickly to respond to states because we understand that this work is, is timely in both
you and your sub-recipients. Hope to have an approval in hand quickly in order to plan e ectively
for September 30th.

Speaker 2 00:58:54 And I see Mary, thank you. I do see Mary has added that link for Monday's
webinar. Uh, please make sure if you have interest in that resource that you register for that webinar
on Monday, and, uh, you'll receive additional information at that time about that letter that was
posted earlier today. Thank you all.
Date: April 25, 2024
Title: 042524-507528-DeptofEducation-O ice

Speaker 1 00:59:16 Have a good afternoon.

Speaker 0 00:59:18 That concludes our conference. Thank you for using Intel events. You may
now disconnect.


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