Transportation for homeless students during school closures and beyond

Understanding district obligations for transporting students who are homeless during distance learning and the transition back to school
By: | April 29, 2020
Photo credit – Zhenyakot

Transportation can be a major barrier to the education of children and youths experiencing homelessness, even as state and local educational agencies move toward distance learning in efforts to mitigate the novel coronavirus pandemic.

Local homeless education liaisons still have the responsibility to ensure transportation services are provided where and when such services remove barriers for homeless students.

Homeless education experts noted during a SchoolHouse Connection presentation on COVID-19 response efforts that unanticipated school closures may pose as barriers to students’ full participation in school activities, and therefore, require continued or additional supports for transportation.

The McKinney-Vento Homeless Assistance Act, as amended by the Every Student Succeeds Act, Pub. L. No. 114-95, states that transportation services must be provided for children and youths experiencing homelessness, including to and from their school of origin, until the end of the school year (Section 722(g)(1)(J)(iii)(I)).

Section 722(g)(4) of McKinney-Vento further states that an LEA must provide services to each homeless child and youth that are comparable to services offered to other students in the LEA such as transportation. The services may also include educational programs for which a homeless student meets the eligibility criteria, including programs for children with disabilities, English learners, career and technical education, gifted and talented students, before- and afterschool, preschoolers and school nutrition.

Transportation for school participation

Emergency assistance. Subgrant funds under McKinney-Vento may be used for extraordinary or emergency assistance needed to enable homeless children and youths to attend school and participate fully in school activities (Section 723(d)(16), such as transportation to a Summer Food Service Program or Seamless Summer Option food distribution site during COVID-19 school closures.

Enrollment and extracurricular activities. McKinney-Vento requires that SEAs and LEAs maintain policies to remove barriers to the identification, enrollment, and retention of homeless children and youths (Section 721(2), Section 722(g)(1)(I), and Section 722(g)(4)(A)). As a student is considered enrolled if the student attends classes and participates fully in school activities (Section 725(1)), which may include extracurricular activities, and to the extent that lack of transportation is a barrier to such activities, an LEA would be required to provide a student with transportation to or from extracurricular activities, e.g. a child care center that facilitates online learning (Section 722(g)(1)(F)(iii)). Education for Homeless Children and Youths Program Non-Regulatory Guidance, J-11.

Child care. Providing transportation to childcare may be an allowable use of McKinney-Vento subgrant funds, if transportation to childcare is necessary to enable a student to participate in school activities, according to SchoolHouse Connection. During COVID-19 school closures, a child’s participation in childcare may be necessary to permit a student to participate fully in school activities, be that meals, virtual classes, or other activities.

McKinney-Vento subgrant funds may be used to defray the excess cost of transportation not otherwise provided through federal, state, or local funds, to enable students to remain in their schools of origin (Section 723(d)(5)). Education for Homeless Children and Youths Program Non-Regulatory Guidance, H-1, J-7, and M-5. LEAs may also use Title I, Part A funds reserved to defray excess costs of transporting homeless students to and from their school of origin. Excess cost is the difference between what an LEA normally spends to transport a student to school and the cost of transporting a homeless student to school. Section 1113(c)(3)(C)(ii)(II) of ESSA; Education for Homeless Children and Youths Program Non-Regulatory Guidance, J-8.

In an interdistrict situation, if both LEAs are unable to agree on a method for sharing the cost and responsibility for providing transportation, the LEAs must share the responsibility and costs equally. Education for Homeless Children and Youths Program Non-Regulatory Guidance, J-9.

Johnny Jackson covers homeless and at-risk students and other Title I issues for ESEA Now, a DA sister publication. Documents mentioned above are available to ESEA Now subscribers.