Michigan Ed Department: Don’t look to us for CARES Act spending guidance

School district superintendents in the state have been told not to seek state approvals for uses of federal coronavirus relief funds, but rather to follow U.S. Department of the Treasury criteria.
By: | December 14, 2020
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The Michigan Department of Education said it will not be approving districts’ use of Coronavirus Relief Funds provided by the CARES Act. Letter to Local and Intermediate Sch. Dist. Superintendents, 120 LRP 36690 (SEA MI 11/20/20).

“MDE is not issuing formal approvals or denials for specific uses of these funds,” wrote Kyle L. Guerrant, deputy superintendent. “Districts are encouraged to apply the [U.S. Department of the Treasury] criteria and guidance to determine independently the allowability of charging CRF for past or proposed expenditures.”

Unlike ESSER or GEER funds, the CARES Act requires CRF funds to be used only for costs that:

  • Are necessary expenditures incurred due to the response to COVID-19;
  • Were not accounted for in the budget most recently approved as of March 27, 2020, for the state or government; and
  • Were incurred between March 1, 2020, and Dec. 30, 2020.

Coronavirus Relief Fund Guidance for State, Territorial, Local, and Tribal Governments, 120 LRP 36688 (USDT 09/02/20).

The U.S. Department of the Treasury says it interprets the term “necessary expenditures” to mean that “the expenditure is reasonably necessary for its intended use in the reasonable judgment of the government officials responsible” for spending CRF monies.

The guidance also notes that funds cannot be used for revenue replacement or to backfill funding shortfalls.

According to Coronavirus Relief Fund Frequently Asked Questions, 120 LRP 36685 (USDT 10/19/20), CRF funds may be used to assist schools through:

  • Expanding broadband capacity.
  • Hiring new teachers.
  • Developing an online curriculum.
  • Acquiring computers and similar digital devices.
  • Acquiring and installing additional ventilation or other air filtering equipment.
  • Incurring additional transportation costs.
  • Incurring additional costs of providing meals.

The FAQ notes the CRF may also be used to cover distance learning costs, such as laptops for students, and in-person learning costs, such as personal protective equipment for students.

Treasury Department officials said grantees do not have to report how CRF funds are used so long as the amount spent is no more than $500 per student.

“MDE interprets this guidance to indicate that districts are not required to maintain documentation related to their use of CRF up to $500 per pupil, although doing so is encouraged as a best practice and part of sound internal control,” Guerrant wrote.

However, he added, grantees in the state must still meet the “state-level requirement to account for expenditures of these restricted funds using the appropriate grant codes.”

Charles Hendrix covers education funding and other Title I issues for TitleIAdmin, a DA sister publication. Documents mentioned above are accessible to subscribers.