Have you and your fellow building administrators been involved in developing your district's spending plans for federal ARP/ESSER III dollars? Every district in the state that received money in the third round of federal stimulus funding (which includes every traditional public school district in the state) is required to develop a spending plan for those dollars. And the federal guidance on those plans clearly spells out that, in developing their plans, districts "must engage in meaningful consultation with stakeholders including students; families; school and district administrators (including special education administrators); and teachers, principals, school leaders, other educators, school staff, and their unions."
There is an unprecedented amount of federal money flowing into Michigan's schools at the moment. Three different rounds of federal stimulus funding mean many districts are seeing major funding increases (you can click here to find district-by-district breakdowns of all three rounds of ESSER funding). Moreover, while these federal funds come with a few strings attached, districts largely have wide discretion in how they allocate them.
If you haven't been involved in these conversations in your district, it is not too late, but you don't want to wait to engage. While districts have years yet to spend their federal allocations (see the infographic below), many are already planning how they are going to spend these dollars.
To assist Principals in engaging in these conversations, we've broken down the spending rules and allowable uses below. To help you think through what this might look like in your district, we've also provided you with some links to national resources about how other districts are using these funds. Additionally, MASSP will be surveying members about how their districts are using these funds and we will be sharing this information with members to provide additional local context.
Finally, for those districts with smaller Title I eligible populations and which are slated to receive equalization funds, we've provided a quick status update on those funds based on what information we have available as of now.
Rules and Allowable Uses
The rules are slightly different for each round of ESSER funding, but the biggest chunk of dollars (ESSER III) also came with the most flexibility in how it can be spent. Since that is the largest pot of money still unspent in most districts, those are the rules we are going to review here. And if your central office needs you to cite a reference, the U.S. Department of Education Fact Sheet: American Rescue Plan Act of 2021 Elementary and Secondary School Emergency Relief Fund (ARP ESSER) will back you up on all the information we are sharing here.
Of the total amount of ESSER III dollars allocated to each district, the district must reserve at least 20 percent of funds to "address learning loss through the implementation of evidence-based interventions and ensure that those interventions respond to students’ social, emotional, and academic needs and address the disproportionate impact of COVID-19 on underrepresented student subgroups" In this case, subgroups means each major racial and ethnic group, children from low-income families, children with disabilities, English learners, gender, migrant students, students experiencing homelessness, and children and youth in foster care.
The remaining funds may be used for a wide range of activities to address needs arising from the coronavirus pandemic, including any activity authorized by the ESEA, the Individuals with Disabilities Education Act (IDEA), Adult Education and Family Literacy Act (AEFLA), or Carl D. Perkins Career and Technical Education Act of 2006 (Perkins CTE). Specifically, ARP ESSER funds may be used to develop strategies and implement public health protocols including, to the greatest extent practicable, policies in line with guidance from the Centers for Disease Control and Prevention (CDC) on reopening and operating schools to effectively maintain the health and safety of students, educators, and other staff, as well as:
- coordinating preparedness and response efforts with State, local, Tribal, and territorial public health
- departments to prevent, prepare for, and respond to COVID-19;
- training and professional development on sanitizing and minimizing the spread of infectious diseases;
- purchasing supplies to sanitize and clean the LEA’s facilities;
- repairing and improving school facilities to reduce risk of virus transmission and exposure to
- environmental health hazards;
- improving indoor air quality;
- addressing the needs of children from low-income families, children with disabilities, English learners,
- racial and ethnic minorities, students experiencing homelessness, and foster care youth;
- developing and implementing procedures and systems to improve the preparedness and response
- efforts of LEAs;
- planning for or implementing activities during long-term closures, including providing meals to eligible
- students and providing technology for online learning;
- purchasing educational technology (including hardware, software, connectivity, assistive technology,
- and adaptive equipment) for students that aids in regular and substantive educational interaction
- between students and their classroom instructors, including students from low-income families and
- children with disabilities;
- providing mental health services and supports, including through the implementation of evidence based full-service community schools and the hiring of counselors;
- planning and implementing activities related to summer learning and supplemental after-school
- addressing learning loss; and
- other activities that are necessary to maintain operation of and continuity of and services, including
- continuing to employ existing or hiring new LEA and school staff
If this seems like a pretty all-inclusive list, that's because it is. There are certainly limits, but this is one of those rare and wonderful circumstances where schools are largely being allowed to spend their money in the ways they think best.
Now that you have an understanding of the rules governing these dollars, what might this look like in your district? As we outlined earlier, it is still early in the process, but we've found a couple of resources outlining are or could be spending these dollars.
- First look at ESSER priorities: Districts are placing their bets on what they know
- Making the most of ESSER funds
Finally, as we mentioned earlier, MASSP will be sending a survey to members about how their districts are using these funds and we will be sharing this information with members to provide additional local context, so watch your email.
The most recent School Aid budget included a per-pupil equalization payment for districts that receive less than $1,093 per pupil through ESSER III. The payments are enough to bring every district in the state up to at least $1,093 per pupil in one-time pandemic-response money. The source of these funds is the 10% of discretionary ESSER III funding that Michigan received. Despite being discretionary, the state still needs approval from the US Department of Education (USED) to spend the money on an equalization payment.
Most recently, Michigan has received notice from USED that, “The legislation’s per pupil allocation eligibility threshold does not appear to take into account the ‘disproportionate impact’ of the pandemic on underserved populations as required by section 2001(f) of the ARP Act.” In other words, USED is indicating that the equalization payment may not be legal under federal law.
This is not a final determination. No final decision has been made. MDE and members of the Whitmer administration have met with USED to plead the case for Michigan’s use of these funds, and the decision is now in their hands. Still, districts that would be impacted by this line item should contact their members of Congress to encourage the White House and USED to grant Michigan permission to use ARPA funds for this per-pupil equalization.
Finally, MASSP members should note that state revenues are coming in higher than anticipated. That is, they are many millions higher than the May consensus revenue estimates said they would be and those estimates were already pretty high. So if USED rules against Michigan, there should be sufficient state funding to keep this section whole. However, as this is not a guarantee and the Legislature would have to act for this to happen, approval from USED is still the better outcome.