Emergency Assistance For Non-Public Schools (EANS) Roundtable

Due to the evolving nature of EANS funding, School Choice Wisconsin Action (SCWA) hosted a roundtable discussion on May 12, 2021 for school staff members to ask questions and share information. Our panel included Lori Saqer of Messmer High School, Brian Frank of St Augustine Preparatory Academy, and Donna Bembenek of Catholic Memorial High School. The FAQ from that roundtable is below. 

* SCWA Disclaimer: While seeking to be a helpful resource to schools, SCWA has pulled together answers from CESA6 and DPI for the following questions submitted to the May 12th SCWA roundtable on EANS. This tool in no way supersedes DPI/CESA guidance. Schools are encouraged to email [email protected] for additional clarification.

1. Why the change early on from DPI handling EANS administration through WiseGrants to CESA6?

SCWA note: Federal law dictated that the EANS administration run through the state agency, which is DPI. SCWA and other advocates were concerned that DPI might not be as efficient as the CESAs and perhaps limit private school access to their own vendors. Getting the CESAs involved was a way to mitigate that concern and handle EANS efficiently.

Through EANS, the federal law requires a public agency to be the one offering these direct services, so a private school can’t have the individual contract with the vendor. Funneling administration through CESA6 allows you the opportunity to get your vendors involved.

2. Why is processing EANS funds so different than Title IIA reimbursements?

SCWA note: The EANS program is a limited-time grant for pandemic relief; it is completely separate from and unrelated to the Title IIA program. The rules for processing EANS funds are dictated by the federal laws for EANS.

3. Do requests have to be sent through CESA6? Or would we send requests through the CESA whose boundaries we are located?

All direct service request will come to CESA6 at some point since CESA6 will approve and process the PO for the respective CESA. The school should work on scoping the service or material with their CESA. If they do ultimately come to program administration, CESA6 will help them navigate their requests.

[SCWA note: Usually, you start with your local CESA catalog for any direct service, except for window installation or building contractors, contact CESA10.]

4. Any news on individual Chromebooks/tablets?

The purchase of any type of laptop for students or staff involved in remote or hybrid learning is an allowable expense.

5. Can we continue to buy COVID related items, ie. Chromebooks, Tv’s, etc. through our own vendors or do we have to order through CESA 6?

The school is welcome to purchase education technology from a vendor of choice. The purchase prices will need to be reasonable. [SCWA note: Effective June 2, 2021 “future” reimbursements require prior approval from CESA6; for tech purchases, review CESA2 catalog for pricing deals or use your own vendor, then request approval from CESA6.]

If the item is only direct serviceable it needs to be acquired through a CESA. [SCWA note: a local CESA, not necessarily CESA6; CESA2 handles purchasing.]

6. We are considering ordering some new Chromebooks in the next week or two. My understanding is that the reimbursable expense period goes through June 1. Can these be ordered, but paid for when received, even if past June 1, and still submitted for reimbursement? Or does the invoice need to be paid by June 1 to be included in reimbursable past expenses? Are we required to submit the Chromebook order for approval through CESA’s direct service portal now?

If schools make an order prior to June 1st, it will be reimbursable. They will need to submit their reimbursement request prior to September 30, 2021.

[SCWA note: If in doubt, reach out to [email protected] to provide peace of mind.]

7. When you mentioned about $5,000 for supplies and talked about Chromebooks, I was needing 45 iPads and would target these funds as we are adding 45 children to our enrollment next year. This cost will be more than $5,000. How will this be dealt with?

SCWA note: DPI has explained the $5,000 threshold for supplies refers to the cost of each individual item (e.g. cost of one Chromebook). As long as the item is used within the grant period, DPI seeks to handle them as supplies, meaning the title won’t need to be transferred to a public agency at the end of the grant period. DPI hopes to get guidance out on this soon, perhaps next Friday.

8. If they are considered a supply, is the hope that they won’t need to be transferred to Title management after 2023?

SCWA note: Yes, however, if the item was unused during the grant period (i.e. was purchased but wasn’t necessary), the title will need to be transferred.

9. Would interactive whiteboards be covered?

Yes, smartboards and their installation are covered.

10. If EANS Funds can be used to pay for software such as PowerSchool, Schoology and TurnItIn, how will the licensing work? Will it be controlled by CESA 6 or the school?

CESA6 will not be licensing it, the school would. At the conclusion of the program the LEA may request it to be licensed differently. Schoology and TurnItIn would likely be allowable but PowerSchool will be questionable since Student Information Systems are not allowable. (SCWA note: Is there a particular feature to your SIS that needed to be added because of remote learning?)

11. What about materials?

All purchasing of materials will be processed through CESA2.

12. New textbooks or supplies to support learning loss?

Yes, physical textbooks would be allowable if a demonstrated case is made for their acquisition in alignment with category #12, Initiating and maintaining education and support services or assistance for remote or hybrid learning or to address learning loss.

13. Can EANS funds be used for multi-year subscriptions? Like a three-year subscription for cost savings or is it a year at a time?

Yes. After the time limit is up on the program, the school would resume responsibility of the remaining balance of the time left on the subscription. So, after 9/30/2023.

14. Can we include costs like the new wiring we had to run in the building to accommodate the increased internet speed because of all the devices we now have to have in order to have a 1:1 student to device ratio?

No. Cabling would be considered a capital expense which is not allowable per USED guidance. Service to install cabling will be allowed under the category of educational technology to improve connectivity.

15. Guidance mentions transportation but does not give specifics. Can we be reimbursed for our inter-campus shuttle?

SCWA note:  In this example, the school is not offering a new service, but the school typically charges families for this service.  Since the pandemic, the school has suspended those extra charges to help families cope with the financial strain.

CESA6 answer: The intercampus shuttle as presented would be an allowable reimbursement.

16. Would Transportation for athletics which was specifically required due to the pandemic be included? We had to use twice the number of busses to transport students under and according to CDC guidance. Two busses instead of one to get to and from events because of limits of capacity.

Yes, this is a reasonable transportation cost.

17. Outdoor Classrooms. MPS will be using ESSER funds for outdoor classrooms. What will this look like? Do seating need to be moveable?

SCWA note: The use of outdoor classrooms must be pandemic related, and appropriate to current CDC guidance. A safe way to ensure this is to find the items that you’re looking at and run it by CESA6 to make sure you have prior approval.

Large permanent structures would not be allowable, but things required to accommodate social distancing and current CDC guidelines that are moveable, temporary, and reasonable would likely be allowable. [e.g. tents, folding chairs, etc.]

18. Would bikes count if the goal is to take PE classes outdoors?

This will need further review to determine allowability. Later next week we should have an answer.

19. Window installation is covered under clean air solutions as direct service but there are no capital improvements allowed. Where is the line between improvements for ventilation and capital improvements? We have a lot of windows that we would like to install.

Services related to improvements to or installation of ventilation systems are allowable [as a “Direct Service”]. These have to be directly provided via the CESA Catalog. Contact Paul Wurtz at CESA10 for window installation/repair, or to request a preferred contractor be added to their list.

*Reimbursements (past or future) are allowable only for portable air purification systems.

[SCWA note: window repair or installation that has already occurred is not eligible.] Improvements to ventilation systems (including windows), except portable air purification systems, are not reimbursable. Additionally, this would be a capital improvement, which is not allowed. However, service to install new windows (that are purchased with private funds by the school) or to repair existing windows may be eligible.

20. HVAC systems. I understand that installation and service are covered through Direct service. What about the units themselves? We have 4 rooftop units that need to be replaced.

While the law allows services or assistance to improve ventilation systems, capital improvements are not allowable. As such, an allowable expense in this area would be limited to services to fix and/or improve ventilation systems, but not to purchase a new system. Therefore,

EANS funds may be used to repair existing air conditioners or install new units, but not purchase the air conditioners.

21. Will EANS funds pay for the installation of touchless toilets and urinals as well?

YES. The installation of touchless flush mechanisms is allowed. This service will need to be provided via direct service.

If a school is interested in this, they should reach out to:

• • Paul Wurtz
  • CESA 10
  • Facilities Management Advisor
  • [email protected]
  • (715) 720-2165

22. Is there a specific component of law that makes the contracted cleaning services not allowable? That has been an allowable use of ESSER Funds. I want to be able to understand the distinction.

Yes, see the FAQ from the US Department of Education, D-3: “Are services for sanitizing, disinfecting, and cleaning school facilities an allowable use of EANS funds?”

“(NEW March 19, 2021) No. Section 312(d)(4)(A) specifically authorizes a non-public school to request “supplies to sanitize, disinfect, and clean school facilities.” This authority does not extend to contracting with a vendor to perform the cleaning.

If a non-public school has contracted for cleaning and seeks reimbursement, an SEA may reimburse it for the cost of supplies but not for the full cleaning contract.”

23. Can we still work with our consultants that we’ve worked closely with for years?

Perhaps. The best thing to do would be to contact your local CESA and make sure your consultants and vendors are on the list for direct services.

24. How would schools be able to use outside consultants to help give professional development related to academic learning loss, implementing technology/hybrid learning, or other pandemic-related topics?

SCWA note: Review the CESA catalog first, then contact your local CESA.

25. Are contracted CESA employees still expected to follow Diocesan guidelines, rules, and expectations?

Each CESA may approach this differently. CESA 6 would require that employees hired through CESA 6 follow those guidelines, rules, and expectations. For instance, the employee handbook from CESA 6 directs third-party staffing arrangements and itinerant staff need to follow the guidelines, rules, and expectations of their placement.

26. Who assumes the liability if a contracted employee violates Diocesan policies?

As an employee of a CESA they would be covered under the CESA’s liability policy.

27. Who cover workman’s comp?

The employer, so the CESA.

[SCWA note: DPI has said CESA6 is in the process of creating an MOU (Memo of Understanding) to help give schools a voice and provide clarity in staffing arrangements.]

28. Can EANS funds be used to pay for contracting teachers currently employed by a school to perform curriculum work during the summer (which is outside their contracted hours), if they were to be contracted by one of the CESAs or another third party?

Yes, but the allowableness of the curriculum development would have to be approved.

29. The Choice Program does not require teachers to be licensed. Teachers must only demonstrate that they have a bachelor’s degree from an accredited university. If a private school is approved to use EANS funds for a “direct service” teaching position (interventionist, summer school, etc.), would a CESA require the employee to be licensed or would a bachelor’s degree be sufficient?

Each CESA will potentially handle this differently.

For instance, CESA 6 will work with the school and honor their requests around licensure, compensation, and assignment. CESA 6 will not require a teacher to be licensed.

Please continue to reach out with questions and if you need assistance with staffing CESA6 can help schools navigate that process.

30. If a summer school class for academic purposes is funded or supported using stimulus funds, can that academic summer school class be included as a Choice or SNSP summer school class that is part of a summer program for which the school receives state aid?

Yes, stimulus funds, including ESSER and EANS, may be used to support Choice or SNSP summer school courses that are offered for academic purposes as part of the Choice or SNSP summer school program. (See pg 4 of DPI’s Summer School Bulletin, April 2021.)

31. Do you see any advantage to making purchases prior to June 1, 2021? Do you anticipate the future reimbursement process being more difficult or limited?

If purchases are made prior to June 1, 2021 it will qualify for a past reimbursement. Schools have until September 30, 2021 to claim prior reimbursements (purchases between March 13, 2020 – June 1, 2021).

The potential risk a school has is that something they buy is not reimbursable. If they wait until May 25, 2021 when the future reimbursement process will open up, they will be provided a prior approval so they can make the purchase with confidence it will be reimbursed.

32. Will direct reimbursement funds be applicable in determining single audit requirements?

Per DPI: No. Under the EANS program, private schools are not receiving federal awards through a subgrant or directly, so EANS reimbursements should not be considered when determining if an entity is required to have a single audit. Reference: U.S. Department of Education FAQ, question D-12

33. Is it correct that reimbursements for allowable reimbursable costs can be sought through September 30, 2023? Or is there an earlier deadline for that?

Prior reimbursements run from March 13, 2020 – June 1, 2021. They will need to be submitted by September 30, 2021.

Future reimbursements run from June 2, 2021 – September 30, 2023. Future reimbursements will require prior approval and the actual reimbursement will need to be submitted by October 31, 2023.

SCWA note: Other misc. questions

• UV lights – yes, for consumables (replacement bulbs); no for UV filtration systems.
• HEPA filters – yes, for consumables; no for HVAC equipment
• Staffing: Contact local CESA (e.g. nurse, after school tutors, reading interventionist, administrative staff for supervision or support of remote learning, etc.)
• Fans – yes
• Plexiglass barriers – only reimbursable if purchased prior to March 19, 2021
• Furniture – yes, if to facilitate social distancing (e.g. desks to replace tables)
• Lunch program disposable trays, etc – Yes
• One-time set up for technology – Yes
• Ongoing support for remote learning – Yes, as a direct service through CESA
• Mental health supports – Yes as a direct service through CESA

You can watch the entire roundtable here: https://youtu.be/wRA_tKwSFGQ.