Speaker 0 00:00:00 Welcome and thank you for joining American Resource Plan A RP Liquidation extensions. Before we begin, please ensure you have your
Summary
A transcript of a U.S. Department of Education WebEx webinar on liquidation extensions for American Rescue Plan ESSER and EANS funds, presented by Christopher Tate, group leader in the Office of State and Grantee Relations, with Jennifer Timmons, who leads the extension request approval and oversight work. Tate explains that the department cannot extend the statutory obligation deadlines, which the transcript gives as September 30th, 2022 for CARES Act funds, September 30th, 2023 for the second relief act's funds and September 30th, 2024 for ARP funds, but can extend the liquidation period: instead of 120 days after the obligation deadline, an approved request gives an additional 14 months, 18 months in all. In the question period staff say no request has been denied so far.
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Speaker 0 00:00:00 Welcome and thank you for joining American Resource Plan A RP Liquidation extensions. Before we begin, please ensure you have your chat panel open by clicking the chat icon located at the bottom right of your WebEx screen. If you require any technical assistance, please use the chat to send a message to the event producer for all q and a. You can submit your questions through the chat at any time in the dropdown menu. Make sure you select all panelists, then enter your question in the message box and click the send icon. With that, I'll turn the call over to Christopher Tate, group Leader, office of State and Grantee Relations. Speaker 1 00:00:52 Next slide please. Good morning. I'm Christopher Tate, the group leader managing grants administration processes and monitoring for the department's Esser gear and E'S programs. I'm joined today by my colleague Jennifer Timmons. Jennifer leads our office's liquidation extension, request approval and oversight work. Today's webinar will be recorded and made available on the OESE State and Grantee relations deadlines and announcements page. We ask that you hold your questions until the end of the presentation, and at that time we'll address questions that are received in the chat box. As you're aware, in 2021, Congress set aside funding within the American Rescue Plan are backed specifically for the elementary and secondary school Emergency Relief Fund and the emergency assistance to non-public schools programs. These funds are specifically targeted for use by grantees to address the impact that Covid to 19 has had and continues to have on schools across the nation. Speaker 1 00:01:57 While the department does not have the authority to extend the performance period for these funds, it may extend the liquidation period. The department has opted to exercise its authority to allow grantees additional time to liquidate its COVID-19 funds using this unique process that applies only to its pandemic relief programs. Note that the department will release its extensions process for the American Rescue Plan Homeless Children and Youth Program. Soon more information will be shared about the process by the Office of School Support and Accountability in the coming weeks. Today's presentation is divided into two parts. The first part focuses on the liquidation and obligation requirements from which the extension request process and request template are derived. Unlike with other federal formula programs implemented at the department, this one-Time process for COVID-19 Relief, E-S-F-F-F funds is designed to ensure that states can integrate the ongoing oversight of approved requests into their regular grants Management Pro procedures and limits the amount of data gathering necessary to seek the department's approval. The process for ARP SER and ARP ES funds builds upon the implementation of the liquidation extension process for CARES ACT and CSA Act funds. Next slide, please. Speaker 1 00:03:28 As you are aware, the Caress Act funds had to be obligated by September 30th, 2022, and CSSA Act funds were to be obligated by September 30th, 2023. All RPAC funds must be obligated by this September 30th, 2024. These states are determined by statute and the department does not have the authority to extend this period. Each period of obligation for these funds includes the tiding period. Grantees then have 120 days following the end of the liquidate of the end of the obligation period to complete the liquidation of funds that have been properly obligated by the September 30th date. Today we'll be detailing a process by which states may seek a liquidation extension deadline, which will provide grantees an additional 14 months to liquidate their arp, Esser and ARP E funds, providing a total of 18 months to complete the liquidation of these funds, the arp, Esser and ARP E extension application template and frequently asked questions. Speaker 1 00:04:38 Documents are available at the Department of Education's SDRs, deadlines and announcements webpage. It should be noted that a liquidation extension is not extended time for grantees to determine how to spend those funds. It is extended time to spend funds on materials and services that have been properly obligated within the allowable timeframe and for the allowable purposes under the R Act. Because an extension of the liquidation period considers the facts and circumstances impacting a grantee's need for an extension and to ensure proper accounting for the uses of funds by the department and by grantees during the period of an approved extension, grantees must submit the required information and obtain approval from the department to receive an extension to its period of liquidation. Next slide please. Speaker 1 00:05:38 Before we review the process itself, we want to reference the requirements for obligating and liquidating funds. To obligate generally means to make a binding commitment for services work or products as detailed within 34 CFR 76 7 0 7, which stipulates when those obligations are made. Regardless of the state's intention or approval to apply for liquidation extension obligations for the arp, Esser and Arps funds must be completed by September 30th, 2024. It should also be noted that in order to be considered properly obligated, the funding must be obligated for allowable uses as provided by the specific funding requirements and allowances of the SSR and EAMS programs. Additional information regarding allowable uses may be found at the department's F at the departments' published FA FAQs for each of these programs. Next slide please. Speaker 1 00:06:46 34 76 7 0 7. Further details, specific types of obligations and the dates by which those obligations are considered to be. This information also applies to obligated costs included within a liquidation extension. A state or sub-grantee should carefully consider these differences when reporting properly obligated funds. I want to emphasize the obligation of personal services here. First, services provided by an employee of a state or sub-grantee such as an LEA, are considered obligated when the services are rendered or the work is performed. Second, personal services rendered by a contractor who is not an employee of the state or sub-grantee are considered obligated on the date on which the state or subgrantee makes a binding written commitment to obtain that work such as through the execution of a written contract. Thus, payroll expenses for employees of a state or subgrantee may only be liquidated with ARP Act funds for services provided by the end of the associated obligation period or September 30th, 2024. Speaker 1 00:08:03 For arp, Esser and ARP E'S funds payroll expenses for the personal services of staff members that are obligated through a third party contractor may continue through the liquidation period if the associated contract for those services was executed by the obligation deadline for the program. When considering requesting an extension from the department, please note that during the implementation of an approved request, a grant team must retain full responsibility and oversight over the grant consistent with the attestations included in the liquidation extensions request. These continued oversight responsibilities will extend throughout the liquidation period related to the initial request. The state must confirm the allowability and proper and timely obligation of the funds consistent with 34 C FFR 76 7 0 7 and collect review, and maintain all documentation to support the state and sub-recipient liquidation extension request in a manner consistent with the grant requirements approved liquidation extensions will be monitored in a manner consistent with the department's oversight of its grantees and will include evidence of the grantee's oversight of its extension process and its monitoring of sub-recipient expenses for timeliness and allowability. This does not mean that a grantee is expected to collect and maintain additional documentation outside of its normal sub-recipient reimbursement and monitoring processes. If additional documentation is required by the department in its review of a grantee's implementation of its approved request, it is reasonable to assume that certain documentation requested is on file with a grantee or a grantee sub recipient. Speaker 1 00:09:54 Next slide, please. To liquidate means to draw down and spend the funds. A timely liquidation occurs during the period of obligation IE September 30th of the given year for the program and through the first 120 calendar days after the relative September 30th deadline. As long as obligations have been made by the September 30th deadline for the given program for contracted activities, and these obligations are valid, IE, they follow all applicable requirements, then those obligations may be liquidated during the 120 calendar day liquidation period without need for an extension. Next slide please. Grantees and sub-grantees with approved extension requests may carry out grant activities during the period of liquidation or the extension of that period is authorized by the department. So long as the timely and valid obligation has been made and the state and local procurement laws allow in seeking an extension, however, a grant team may identify activities that will extend beyond the liquidation period. Speaker 1 00:11:11 The department has also provided additional guidance on this matter to grantees in both the updated SR FAQs and separate E NS communications, and we will quickly touch on this item here. In limited circumstances, it may be allowable for program funded activities to continue after the obligation and the liquidation period have concluded. There are a number of factors that should be considered when determining whether the continuation of these activities beyond the period of performance would be allowable within a particular state's context. States should consider whether the funds were properly obligated and liquidated in a timely manner, whether the activities would be allowed to extend beyond the liquidation period under applicable state and local procurement rules, whether the extended activities constitute a reasonable and necessary use of federal funds and consider whether prudent business practices and internal controls would support the continued activities for the length of time proposed. Speaker 1 00:12:22 Because Esser and EENs are state administered programs, the SEA or governor determines whether activities extending past the liquidation period are allowable under the circumstances under certain circumstances, and should do so only after considering the factors that impact a particular expense. It should be noted that the 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 under no circumstances may services extend beyond the date on which funds revert to the US Department of Treasury. This occurs approximately four years after the obligation deadlines referenced in the Esser and Deans FAQs. However, nothing prevents an SEA or LEA from continuing successful activities or services with non esser, non ESER or E NS funding. If you have specific questions about this guidance, when preparing your request, please reach out to your program officer. Next slide, please. Speaker 1 00:13:39 While the department does not have the authority to extend the period of obligation, it can approve liquidation extension requests based on written requests and confirmation of properly obligated funds. In response to the increased interest in extending the liquidation of Covid Relief funds, the department's Office of state and grantee relations developed a liquidation extension request process for the CARES funds, which were later updated to include the C ACT programs. This process has resulted in the successful approval of multiple state requests under these programs, and the department is continuing to receive and review grantee requests to extend the period of liquidation for CSA Act funds consistent with the CARES Act and CSA Act liquidation extension process. Grantees requesting liquidation extensions on behalf of sub-grantees will list the requested costs as an aggregate amount for each sub-grantee rather than a transaction by transaction listing. Similarly, grantees are not required to submit supporting documentation with the request. However, grantees should be prepared to provide relevant, relevant documentation as requested for monitoring and auditing purposes. Grantees will submit one comprehensive Excel document for each program, each funded program to represent extension requests for itself and it sub-grantees as applicable. Notes, resources, and links to FAQs have been included within the template for ease of access and oversight. Responsibilities are clearly outlined within the grantees Attestations Speaker 1 00:15:27 Now to the liquidation process under the ARP SER and ARP EANs programs is the new, I'm sorry, excuse me. New to the liquidation extension process Under the ARP SER and ARP EANs programs is the inclusion of a cover letter. Today we will look at each of these components including the cover letter for a state to include in its completed request. It is the intention that the single request process will expedite the approval timeline which the office of State and grantee relations intends to communicate within three weeks of a complete submission. This timeframe may be impacted if the volume of requests is concentrated within a particular timeframe or if additional information is needed from the grantee. However, limiting the requests within a comprehensive approach as opposed to individual sub-grantee requests submitted to the department should result in more expedited communication regarding a grantee's approval. Next slide please. Speaker 1 00:16:34 The only change to the process for seeking a request to extend the liquidation period for ARP Act funds is that a grantee must provide a cover letter explaining how the extension contributes to the acceleration of academic success for students, especially those students with the greatest need, grantees are encouraged to highlight investments in three of the evidence-based strategies that can significantly contribute to improve student performance. But please note that approval of a grantee's request will not be contingent upon the information that a grantee includes in its cover letter. Please also note that the department cannot limit the uses of funds that are included in a liquidation extension request. Grantees may limit their co, may limit cover letters to no more than two pages and should feel comfortable keeping examples concise without the need for providing data analysis at any particular depth. The information provided will be followed up on after the approval of a grantee's request during the department's oversight of a grantee's approved request, including during ongoing discussions with grantees about progress towards student academic and other goals when monitoring ARP Ser state plans. Information provided in a cover letter may additionally be further reviewed for the future provision of technical assistance or shared with the Institute for Education Statistics. At this time, I'll now turn the presentation over to my colleague Jennifer Timmons to further review the liquidation extension request process and request template. Next slide please, Jennifer. Speaker 4 00:18:24 Thank you, Christopher. Good morning everyone. Uh, as Christopher mentioned, we're going to talk through what the request template, uh, comprises and the components and required elements for the liquidation extension requests are included within the Excel request template. You'll see that there are seven tabs of information included within the template that include a title page, a cover, uh, table of contents grantee request overview, the grantee attestation grantee information, sub-recipient information, and a tab for definitions and additional resources. As noted here and within the template, the title page, table of contents and definitions tabs are just for your information. There's nothing for grantees or sub-recipients to include on these three tabs. The grantee request overview, grantee attestation grantee information and sub-recipient information are the four tabs where information should be included for the request to be considered complete and ready for submission and review to the department. Speaker 4 00:19:25 We're suggesting that submissions for ARP Esser, or ARP e ns be made prior to December 31st, 2024, which is one month before the end of the regulatory liquidation period. Once that period has concluded at the end of January, 2025, grantees will lose access to G six if a liquidation extension has not been submitted and approved. Uh, and so in order to avoid disruption to G six access, we've suggested that liquidation extensions be submitted by December 31st, 2024. Be assured though that the department will continue to review requests submitted after that date and will approve with as much expediency as possible. Next slide please. Speaker 4 00:20:12 As noted, the title page is informational only and does not require any data entry on the part of grantees, but there are some items to note within this information. Again, grantees and sub grantees of the R Act must obligate funds by September 30th, 2024. Grantees can submit a liquidation extension request for just themselves or on behalf of their sub-recipients, or can include, uh, funds on both of those levels. Once approved grantees and Subrecipients or LEAs may have up to 18 months to liquidate the funds or an additional 14 months. The completed requests, including the Excel request template, should be submitted as an Excel document to the state mailbox and CC'd to the assigned program officer, and that submission can occur when the data is available. But again, we do recommend by the end of December in 2024. Next slide please. Speaker 4 00:21:14 The second tab of the request template is also for informational purposes only. It doesn't require any data entry Included on this tab are a table of contents that's just provided to navigate throughout the document. It also includes instructions for completion and submission of the request, and then a brief narrative that notes the responsibilities of grantees for sub-recipient oversight within the liquidation period. We'll be reviewing the instructions for each tab as we go through the template today, but there are also some items to note within this section which include just a reminder that grantees should complete the requested information on the overview tab, the attestation tab, grantee information and subrecipient information, how those requests should be remitted to the, uh, department of Education through the state mailbox and the state's program officer, and a reminder of the timeline for submissions. We also want to note that only the sub-recipients who are in need of a liquidation extension should be included, and grantees should use both discretion and oversight when including sub-recipients within the request. By inclusion within the liquidation request, it will be understood that the grantee is able to support for recommendation each sub-recipient that's included, and so grantees may utilize any data at their disposal or at their preference in order to make that recommendation. That might include a sub recipient's prior performance or various risk designations. Speaker 4 00:22:42 Additionally, ARP Esser and ARP e NSS requests must be submitted separately as these are separate grant funding programs. Each does require its own extension request, even if they are administered by the same entity. So for example, if, uh, state Education agency or an SEA administers both the SSR and the E NS grants for the states, it does need to submit two separate requests if extensions are needed for both of those funding programs. In the event that the same agency is administering both programs and extensions are needed for both, the grantee could consolidate its cover letter to address both programs, however, the Excel templates should be completed separately. Speaker 4 00:23:26 Also included on the table of contents tab is, uh, an overview of the grantees responsibilities for continued oversight. Essentially, this provides a summary of the attestations that are included on the attestations tab, which we will address in more detail later in the presentation. Next slide, please. The grantee request overview tab is the first tab in the template that does require grantee information, and we do recommend that you begin on this tab. As the information entered on this tab, we will inform and prefill various cells on the remaining tabs. And while much of this is basic information about the grant, there are also a few items that may need some additional explanation. Uh, we've asked for the a LN to be included. This is the assistance listing number, which was formally referred to as the CFDA. If you're submitting for the state's EAMS grant, you'll input 84.425. Speaker 4 00:24:24 And if you're submitting a request for the state's AR SER grant, you should insert 84.425 U and these notes are included in the template for you. Please do ensure that you check the PR award number and the award amount for accuracy. And now moving to the dates, there are a couple of data points to enter here. Uh, one is the date of submission and the date of data finalization. So the date of submission, uh, should obviously indicate when you're submitting the request to the department's office of state and grantee relations. Uh, and the date of data finalization indicates the date by which the data is accurate or representative of the information that's included within the request, particularly as it relates to the obligation and liquidation data. So, for example, if the grantees required its sub-recipients or LEAs to provide obligation data to them by September 20th, 2024, the grantee would just insert that date and that date would then apply to the dates indicated on the grantee and sub-recipient information tabs that we'll review in a couple of minutes. Speaker 4 00:25:34 There are several fields which will either be populated by data in the request or have been pre-populated within the re populated within the template, the amount of the grantee request and the amount of the sub-recipient request both will populate from the totals that are calculated on those specific tabs. And then the total of the extension request is just the summed total of the grantee request in the sub-recipient request listed above the statutory obligation and liquidation dates have also been included for you. And then the next dates to indicate are the grantee requested extension date and the sub-grantee requested extension date. Neither of these dates can exceed March 28th, 2026, as that indicates the full 18 month extension past the period of obligation. These dates can be the same if the grantee selects to have the same date for both grantees and sub-grantees. But the grantee can also, for administrative purposes, indicate an earlier extension date for sub-grantees. Speaker 4 00:26:34 Then for the grantee that decisions at the discretion of the grantee and can be adjusted for the timeframe that would be appropriate to meet the state's specific administrative needs. The sub-recipients or LEAs should be aware that this option available to grantees and is well within their oversight responsibilities to determine those separate dates. And certainly those dates should be clearly communicated to sub-recipients. If approval of the liquidation extension request is received, the state director and the state authorizing official should also match the information that's listed in G six for that associated grant award. And if that information needs to be updated for some reason, please reach out to your program officer and, uh, they will assist you with that. Next slide please. Speaker 4 00:27:23 The second tab that requires information to be completed prior to submission is the grantee attestation tab. All of the information at the top should be populated from the information that you enter on the grantee request overview tab, including the date of submission. As long as that information has been entered, the attestation does need to be signed by an authorizing official. This page can either be printed for a wet signature and then scanned as a PDF along with the Excel request template or an official digital signature can be included on this tab. Attest stations for the grantees that are included on this tab include the assertion that all information and data is complete and accurate and that the activities and services represented within the request have been properly obligated for allowable expenses under the R Act. Additionally, there's an assertion that the certifications and assurances remain in effect for the duration of the grant, including the extended liquidation period, both for grantees and subrecipients. Speaker 4 00:28:26 The assertion that the grantee will continue to fulfill oversight and monitoring responsibilities throughout the liquidation period, an assertion that data verification of obligation and liquidation information may be required throughout the liquidation period. The assertion also that the appropriate supporting documentation for the request is available with either the grantee or the sub-recipient, and it is incumbent upon the grantee to ensure that that sufficient documentation, uh, to support the liquidation extensions of the subrecipients that are included in the request is available at either of those levels, and that that documentation supports both the timeliness and the allowability of the expense documentation. Uh, like this might include copies of contracts, uh, service agreements or purchase orders. Um, as a reminder, it is not necessary to submit this information to the department along with the request, but the grantee and its sub-recipient should be aware that that information, uh, should be made available in the event of a monitoring or auditing activity. Speaker 4 00:29:36 Additionally, there is an assertion that the grantee has conducted its own review of sub-recipient data that's included in the request. And as we've noted previously by inclusion within the liquidation request, it will be understood that the grantee is able to support for recommendation all of the sub-recipients that are included, and grantees, again, may utilize any data at their disposal for that consideration or what data they prefer to use in order to make that recommendation. They could include the sub-recipient, prior performance or various risk, uh, risk factors or risk designations. Grantees should thus, again, use both discretion and oversight when including a sub-recipient or an LEA within the request. Grantees are attesting that the sub-recipients that are included within the request have been assessed for risk and are ensuring the sub recipient's capacity for liquidating those funds within that extended period. Next slide please. Speaker 4 00:30:37 The third tab requiring information to be completed prior to the submission is the grantee information tab. In the event that the grantee is applying for an extension solely on behalf of its subrecipients and does not need an extension of state level funds, this tab should be left blank. So information should only be included on this tab for the grantees that also need an extension of their state level funding. And so examples of that funding that might need to be extended could include ESSER or E ns administrative costs, uh, separate or supplemental state setaside funds, uh, E Ns, SEA services to non-public schools or EAMS reverted funds that were expended at the state level. Speaker 4 00:31:22 Information for columns A and B should be populated from the information that's entered on the grantee request overview tab, including the grantee name and the UEI, uh, columns. C, d and E will need to be completed by the grantee. That's the state set aside a reserve total, the, uh, amount that has been obligated by September 30th, 2024, and the amount that has been liquidated by the grantee by, uh, the end of September of 2024. Columns f and g should calculate automatically, uh, those indicate the percent of the state reserve that's been liquidated as well as the balance remaining column H should be completed by the grantee, and that indicates the amount that's been obligated, but still needs to be liquidated. And so essentially this is the amount of funding that requires the liquidation extension. It may or may not equal the balance remaining depending on the amount that's been obligated or depending on when the grantee submits their request. Speaker 4 00:32:23 Uh, but once again, we do want to remind grantees that the extension applies to the liquidation of funds that have been properly obligated by the end of September of 2024 column. I also needs to be completed by the grantee and should detail the use of funds that necessitates the liquidation extension request. Uh, examples might include contracts or delayed receipt of various materials or supplies. Uh, and this information should be specific to the funds that will be liquidated during the extended period and should provide enough detail to indicate what efforts are being supported through that funding. Uh, later in the presentation, we'll look at an example of both an SR request and an Ian's request. Uh, so you can see some examples of what we're referring to. Column J should further elaborate the justification for the non-liquid funds that are indicated in column I, and it does provide some space for some additional detail. This is also a place where the grantee can indicate any measures they've taken to ensure that the funds will be liquidated in a timely manner. Column K indicates the supporting documentation that's available to document and justify the allowability and timely obligation. So for example, in the event of service contracts continuance due to delays or change orders, the purchase order or the contract agreement would be sufficient. And again, as a reminder, it is not necessary to submit that information to the department, but should be available in the event of monitoring or auditing purposes. Speaker 4 00:33:59 Column L is available for other grantee or fund specific notes. Uh, the use of this column is not required, but it would be particularly helpful when multiple types of funds are referenced, or particularly if an ARP ees request is including both costs related to services and assistance for non-public schools, as well as reverted funds costs, clarity and specificity within your request will reduce the likelihood that our program office has to reach back out to the state to provide additional information or clarifications. Next slide please. The final tab that requires input for submission is the subrecipient information tab. The information included within this tab should represent all of the subrecipients or LEAs for which a liquidation extension is needed, but only the subrecipients are LEAs that need that extension. Uh, additionally for an RPS request, there should be no non-public schools included on this tab, unless in the rare occasion that they have met the appropriate requirements to be a sub-recipient and were awarded funds through the reverted s programs. Speaker 4 00:35:14 Cost related to services or resistance for non-public schools should be included on the grantee tab as non-Public schools are generally not recipients of federal funds. The information to be provided includes the sub-recipient or LEA name, the UEI, the allocation total for the sub-recipient, the amount obligated and the amount liquidated by, uh, September 30th, 2024 or whatever date the grantee has selected. Uh, the use of funds that necessitate the request, the justification column to further elaborate the needs that are en listed in the use of funds, as well as the column to insert additional information about the SUBRECIPIENT data or other relevant notes once data's been entered for the amount of obligations and liquidations, uh, the next three columns, column F, G, and H should calculate automatically for you. Those represent the percentage of the allocation that's been liquidated, the balance of the allocation and the amount of obligated funds that needs an extension, which is based on the previous information. Speaker 4 00:36:20 And while column H, that amount of obligated funds that needs an, uh, an extension will calculate automatically. It can also be edited as needed. Uh, totals will be calculated for each of these at the bottom of the spreadsheet, and those totals will then feed the information on the grantee request overview tab. There are several examples included here to illustrate the types of fund uses that might necessitate an extension. And these are included in the notes section for column I. Uh, these examples include instruction construction contracts, HVAC contracts, uh, contracts for continuing instructional services, delayed materials and supplies. And it's important to note that this list is not exhaustive of the uses of funds that might necessitate a subrecipients need for liquidation extension, but these are some common requests that we do see come in on our other requests. Speaker 4 00:37:17 Column J should document the LEA specific justifications that are currently available. States should provide the initial data about this, such as subrecipient specific justifications that are available to them, and the approval of the state's request is not dependent upon the addition of notes for every subrecipient or LEA during the request and approval process, but there should be enough detail for us similarly as the grantee tab to understand what those uses of funds are for and why they were delayed in the liquidation column. K is also available for any notes that a grantee or sub-recipient might wish to include regarding any data outliers or other associated or applicable information. Uh, again, the approval of the state's request isn't dependent upon the addition of notes for every sub-recipient or LEA, um, and the justification to substantiate an independent request will be reviewed consistent with the state and federal oversight practices. Speaker 4 00:38:17 However, as we noted on the grantee tab, the use of this column will be particularly helpful when multiple types of funds are referenced, particularly on an ARP ES request that includes reverted funds. And again, clarity and specificity within the request will reduce the likelihood that the program office needs to reach back out to the state for additional information. Grantees are reminded that they are attesting to the availability of the information at the state or the sub-recipient level, and while the documentation is not required to be submitted to the department as part of the request, we do again remind grantees and sub-recipients, but that supporting documentation should indicate the timeliness and the allowability of those costs as and, uh, should be made available as requested during monitoring or auditing activities. Next slide, please. Speaker 4 00:39:13 The final tab of the request template is provided for definitions and additional resources. And again, this is informational only. Uh, you'll note that this tab includes those definitions that we've referenced for liquidating and obligating funds, and it also includes the associated reference hyperlinks and FAQs and certifications and agreements for both the ARP SER and a e programs. Next slide, please. Right now we're going to take a look at some sample requests, uh, that, uh, include both arp, ER and ARP ES grantee and sub-recipient levels of funds. So the first one we'll take a look at is the grantee, uh, request overview tab for the ARP SER template. This state, uh, has filled in their information and we can see from this tab that there are amounts of funds at both the grantee level and the sub-recipient level. So we would expect to see information on both tabs for each of those levels. Next slide, please. Speaker 4 00:40:23 The attestation tab is, uh, again, should be filled out at the top for you since all of that information was completed on the grantee overview tab. And then the only part that needs to be completed would be the name of the authorizing official and their title. And then if a signature is applied digitally, that would be here. Otherwise, this page can be printed, uh, for a wet signature to be scanned to the department. Next slide, please. On the grantee information tab, uh, we can see that there are some costs that have been included. There's only one line of information included here, which is typically what we do see when, uh, grantees submit requests for grantee level funds. They have completed the, uh, their state setaside funds as well as the amount that has been obligated and liquidated, and they're requesting one and a half million dollars. They have explained in the uses of funds category or in that column that there are two contracts that are continuing, one for mental health services, which was amended in July of 2024. They've noted on a tutoring contract for state setaside funds outlined in the state plan that has been amended, uh, in August of 2024. Speaker 4 00:41:45 The justification, uh, that has been included explains a little bit more about why those services were delayed and who will be the recipient of those services. So it notes the mental health services is going to support 38 LEAs, uh, that were delayed in services mainly due to labor shortages. And the tutoring contract supports 16 LEAs that had additional funding that was remaining and requested some additional funding through the 24 25 school year. And so their, uh, documentation that they have noted that's on file includes a reference to the contracts, uh, and the Amen, the Associated Amendments, and then they've put in the other grantee funds specific notes column that, again, those service contracts, how many LEAs they'll support. And they've also noted that it specifically will help them combat their chronic absenteeism that they've noted in the state and that the tutoring contract is going to support 16 high need LEAs, uh, and approximately 12,000 students will receive services. And so again, while that column isn't required, uh, it is helpful to help, uh, fill in some context for the state's request. And, uh, also this is information that certainly could be lifted from the Excel template and included within the, uh, cover letter that is required. Next slide, please. Speaker 4 00:43:16 The next slide is, or the next tab is the subrecipient, uh, information tab. Uh, this particular request includes a handful of, uh, LEAs that have been included, and you can see that there are a variety of costs that have been included. Uh, one LEA only needs an extension for HVAC contracts that they've explained have been delayed due to late delivery of materials. Another grantee needs tutoring contracts as well as an HVAC project that were delayed. And then they've explained a little bit of why those delays are there, and the other uses of funds included here. Uh, the third LEA that's included has referenced that they have a licensing contract that, uh, addresses math and literacy skills. They've got a professional learning services contract and then instructional supplies and intervention toolkits. And their, uh, justification column explains why each of those are delayed. Uh, other costs that are included include mental health services, contracts, uh, professional learning, um, some construction contracts, a technology infrastructure project. Speaker 4 00:44:27 And so this is certainly not exhaustive of all of the types of funds that could be requested. Uh, but again, this is pretty illustrative of the requests that we have received thus far under cares and csa. And you can see, as we noted, there are some notes that have been included in the notes column, that column all the way to the right. Uh, however, not every LEA has included notes, and that's perfectly fine. Uh, the notes that have been included either extend a bit more into the, uh, the services that will be provided through the extension or explain that, uh, one LEA in particular had a low amount that they're requesting compared to the remaining balance, and they just noted that they plan on liquidating during the regular liquidation period. Speaker 4 00:45:16 Uh, next slide please. Now we'll take a look at an ARP ES request. Uh, the ARP ES request, uh, as you can see from the grantee overview tab, also is addressing or requesting grantee funds as well as sub-recipient funds. And so we should expect to see information on both of those tabs. Uh, next slide, please. Uh, the grantee attestation, same as before. All of that information will feed in automatically to the top, and then it just needs to be printed or a digital signature inserted. Next slide, please. The grantee level funds that are listed here, you can see this has two lines of text for the state level funding, and we're actually going to cut over to the notes column. Uh, this grantee has been very specific that that top line of funds is addressing ES services to non-public schools. And then the second line of funds is specific to their reverted funds. Speaker 4 00:46:26 And so their uses of funds for that top line, uh, is including contracted services to provide tutoring to non-public school students and support services staffing contract for non-public schools. And they've listed that it's, uh, specific to counselors and school social workers, and then they've explained why those contracts were delayed for them. It was, uh, due to weather related delays as well as labor shortages that kind of delayed that onset of services. And then they've noted that the SEA documentation on file includes those contracts that were signed and amended with the reverted funds. They've listed that there is a statewide Math and Literacy Academy trainings. Uh, their justification includes that, uh, eight of the 10 cohorts were able to be completed, but several remaining cohorts will be completed in December of 2024, but the liquidation isn't expected until February. And so they need the extension for that. And they've referenced that the contract is also available for SEA documentation on file. Uh, next slide please. Speaker 4 00:47:36 And for the ARP ES request, again, just a reminder that we should not see any non-public schools on this tab unless they happen to be a recipient of the reverted funds under the ES program. Uh, this particular request includes sub-recipients that were the state University State Community College, and then they have a handful of LEAs that are included. And similarly as the subrecipients under the ARP eser, they've detailed the use of funds, uh, including the state university has the completion of a final phase of their educator pipeline program. Uh, the community college has, uh, some training contracts specific to early childhood development, and then the LEAs were all recipients of the s e's innovation grants. And so one has a CTE expansion, another has, uh, the regional Community Access Center being developed, and then a series of summer steam camps. And similarly as the arp er, uh, subrecipients on this tab. Also, we have some justifications listed that indicate why the funds were not able to be liquidated, and some of those reasons include that the projects were delayed due to procurement, uh, various schedules that were conflicting, and so projects were delayed, labor shortages, et cetera. And again, notes required in this column or notes are not required in this column. However, especially for the AIMS program, if you have included a number of different types of funds, it will be helpful just to indicate that these were sub-recipients of reverted funds. Next slide, please. Speaker 1 00:49:23 So Jenny, we had a couple of questions that that came into the chat box, um, and we encourage folks to go ahead and, and place any remaining questions there. Um, the first question that we have is, um, a question related to, um, the obligation, um, for personal services and if we had any suggestions because in this particular states instance, they have a non-permanent employee, um, that they would like to retain, but their state procurement, uh, rules prevent them from, uh, switching the way in which that that person is employed. Unfortunately, the obligation requirement here is very clear and we can't speculate on how a state may use other funds, um, to support, you know, contracting, for example, with that individual. So unfortunately, we do not have any suggestions in response to that question. The next question that we have, Jenny, is if a sub-recipient has multiple sub-grants, do all of all of the subgrants need to be included in a single row? And if so, do you include in the amounts and data for the subgrants for which no extension is requested? Oh, Jenny, you're on mute. Speaker 4 00:50:48 Thank you so much. Sorry about that. Uh, that's a great question. Uh, if the a sub-recipient has multiple sub-grants, um, I would suggest that you do whatever makes sense for your particular circumstance. So, uh, if it's, if it is easier for you as the grantee to list a sub-recipient with very specific, uh, uh, sub-grants, you could list those separately and just maybe include in the notes program or in the notes column that, uh, it's a sub-recipient with multiple grants. If it's easier for you to consolidate all of that together, that would be appropriate as well. Um, but if you do decide to consolidate it, you really only need to include the amounts, um, that would need to be included within that extension. Speaker 1 00:51:42 And I see one other question. Can an SEA submit multiple extension requests or does an SEA have to submit one for everyone? Speaker 4 00:51:54 It is recommended that you submit one, uh, comprehensive request that includes all of the LEAs and subrecipients that would be needed for your particular program. So separate requests if you're overseeing both the ARP SER and ARP EAMS programs. But each of those requests should be comprehensive of all of the extensions that are needed within that one request document. Speaker 1 00:52:21 And we'll give everyone, um, another minute to, to pose any questions. I do want to highlight I placed in the chat box for folks the hyperlink to the SDRs deadlines and announcement webpage where all of our extension request, uh, materials for CARES ACTA Act and our act are posted. And the slides from today's presentation, uh, will be posted soon as well as a recording of today's webinar. We have another question that came in, uh, just now. Can you please outline the process for drawing down claiming liquid late liquidation funds? Um, Speaker 4 00:53:21 Sure. And I see there's, uh, there's a little bit, um, Speaker 1 00:53:24 Of an explanation. Yeah, Speaker 4 00:53:25 Have an explanation for that question, but that's also a great question. Uh, and, uh, please understand that the information that we're sharing here will also be communicated individually to any, uh, grantee that has a li an approved liquidation extension. But, um, once you have an approved liquidation extension, if it is prior to the end of the regulatory liquidation period, so prior to for the art programs, uh, January of 2025, uh, you will continue to liquidate those funds as normal. Once you hit the end of January, at the end of that liquidation period, your grant with an approved extension will be placed on what is considered route pay. And so what will happen is you'll submit your drawdowns as normal, but you'll receive, or whomever on your team, uh, does those drawdowns will receive an automatic email that says that your uh, request has been routed for approval. Speaker 4 00:54:25 Uh, that means that if, uh, we would request that you reach out to your SGR liaison or your SGR program officer and let them know that a request is pending. Uh, and you will need to, uh, include in that email or in that request, which sub-recipients are included in that, in that figure. And that can be done through email. We have some grantees that include an Excel document along with it, but usually it's just in the body of an email. The program officer will review that according to your approved liquidation extension request. Uh, and then they will submit it for approval. And then once it's approved, you'll receive the funds in your account within 24 to 48 hours. And again, we'll, we'll, uh, communicate all of that information with anyone who has an approved grant, um, extension. Speaker 1 00:55:18 And Jenny, we had another question that came in. Um, if the district signs an amended contract today under the assumption that it will be granted late liquidation, can the services continue during the liquidation period as the SEA waits to hear from Ed as to whether the state is approved for late liquidation? And I think, um, the important thing to note here is that we are working with each, um, state to get to an approval process. So, um, for those contracts that are amended prior to the end of the obligation period, certainly those services can, could continue. There may be, as Jenny mentioned during, um, her portion of the presentation, some follow up questions that we might have with regard to, um, specific items in the states given requests as it pertains to sub recipient information. But again, we are working with all states to ensure that their requests are timely approved and that they're able to move forward with that extension. Um, and we've been able to do that usually within 30 days. Speaker 4 00:56:27 And I would also add to, uh, just to follow up with what Christopher was just saying, is that if you are preparing your request and uh, you have some questions, please reach out to your program officer through the state mailbox, uh, if needed, we can jump on a call with you to talk through any questions that you might have or respond to you in email, um, prior to your submission, if that would be helpful to you. Speaker 1 00:56:53 And we had, um, another question related to, um, contracts for services and contracting with an individual employee at a state education agency who might also then, um, be working as a state employee, um, on non SSR programmatic work. And we're going to have to take that question back to our attorneys. Um, and Matt, if you will provide that question through your state's mailbox, um, we will route that to our policy group, um, so that we can make sure that we're responding appropriately to that question and offering, um, guidance that's hopefully going to help you be able to reach your goal there with regard to retaining that person for closing out the grant. Jenny, I see another question. For just the SEA Reserve Learning Loss funds, we have multiple projects. Did I hear that we need to ask for an extension on each project or just one overall request for all of those projects? Speaker 4 00:58:03 For the grantee level funds? It, again, it really depends on what's going to be easiest for you at the grantee level. Typically what we will see at the state level for those funds is that there's just a single line of information and all of it is consolidated into one line. Uh, although we have seen a couple of requests that have come through specific to the different projects that have been funded out of the state set asides. So for example, under our esser, uh, let's say it's easier for you because they're split in your fiscal system according to emergency needs set aside and your other major setaside categories, if you wanted to uh, list those separately, that's perfectly fine, but it isn't required that you list them separately. It would just be if it's more, uh, if it's more beneficial for you or easier for you. And again, if, if you do decide to list them separately, it would be helpful in the notes column to utilize that section just to help us understand what those, what those funds are used for. Speaker 1 00:59:04 We had another question come in, um, related to reporting. Will late liquidation result in additional years of reporting? And the answer is yes, consistent with our reporting practices, states will continue to report through the end of the fiscal year that the last amount of their a, uh, funds are expended. So in this instance, reporting would continue into 2026 as a result of expenditures, for example, that are finalized in 2025. And we have one other question, Jenny. Have there been any situations or examples of projects that were not able to be approved for some reason? Speaker 4 00:59:51 That's another great question. Um, at this time there have not been any requests overall that have been denied. Uh, what typically happens, and as Christopher referenced earlier, uh, the office of state and grantee relations will work with you on your request to ensure that, uh, what is being requested is, uh, allowable. Um, there have been some instances where we've needed to reach out for some additional information, uh, but the state in those cases has been able to, uh, respond with the appropriate information that gives us the, uh, assurance that it is able to be moved forward for approval. Speaker 1 01:00:36 Alright, so we are over time, um, I'm not seeing any other questions. I would like to just remind folks to please feel comfortable reaching out to your program officer at your state mailbox. Um, we will work very quickly to get, um, a response as it pertains to liquidation extensions, um, and aim to be as supportive as possible as we move through the approval process, um, throughout the remainder of the RPE and RPS funds. Thank you. Speaker 4 01:01:04 Thank you everyone. Speaker 0 01:01:07 Thank you everyone for attending. You may now disconnect.
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