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COVID-19 Grants Q & A
COVID-19 Flexibilities for Grants Management - FAQs
Effective March 19th to June 16th, 2020
These FAQs will apply to both state and federal grants, unless otherwise noted.
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Will CDE's COVID-19 grant guidelines be applicable to both Federal and active State Grants?
Yes, both Federal and State awards should be managed with the same regulations and rules in mind. This ensures that allowability of costs and consistent procedures are followed. The guidelines will be utilized for both state and federal grants, unless noted. As always, if you are unsure, please reach out to your Program Manager or Grants Fiscal Analyst.
How long will the flexibility described in these guidelines be in place?
The Office of Management and Budget (OMB) will be reviewing guidance for federal grants every 90 days beginning March 19th . As stated above, state grant guidance will follow the same timelines for review. Updates to this guidance will be posted to this website and will be communicated to districts on CDE's website and the Finance listserv.
OMB Guidance: March 19, 2020 M-20-17 MEMORANDUM TO THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES (PDF)
My grant expires 6/30/2020. May we obtain a 12 month no-cost-extension? Does this also apply if we have unobligated funds (carryover)?
If my award will receive a 12 month no cost extension, how will I be notified?
Grant Award Letter amendments, indicating the No Cost Extension to the performance period, will be sent to grant program managers and fiscal contacts within the next week or two.
Are there restrictions on which grants allow carryover?
State:
Carryover and No Cost Extensions will be applicable to all competitive state grants currently awarded with FY2019-20 funds and within the period of performance, which will extend the period of performance an additional 12 months.
Additionally, Executive Order D 2020 007 suspends the statutory restriction limiting carryover of READ per pupil intervention funds to 15%. Therefore, districts can carry over unspent funds from the FY 2019-20 to FY 2020-21 without penalty.
Federal:
Depending on the funding source, carryover will vary. For example, LEAs that receive Title I funds were not able to carry over more than 15% of their Title I funds from year to year. CDE applied for and received authority to waive the Title I 15% carryover limitation in ESEA Section 1127 for FY 2019 and received preliminary approval from the US Department of Education. This authority will give all Colorado districts the ability to carry over excess Title I funds due to the Coronavirus pandemic. We will be providing additional information on the implementation of this waiver.
Will continuation funding move forward for those state grants that have one or two years left of the grant?
Due to COVID-19, the Colorado State Legislature temporarily adjourned the FY2020 session. They plan to reconvene to complete the FY20-21 state budget in May 2020. CDE will not have funding information for CDE state grants until the Legislature has approved the Long Bill, and it is signed by the Governor. Until the Long Bill is signed, future appropriations for all CDE funding sources are unknown. As more information becomes available, we will provide updated information.
With the evolving needs due to COVID-19, can we adjust the way grant funds are spent?
All carryover is required to follow the approved application. However, several state and federal grants may be able to help with technology, food or other expenses related to COVID-19 response efforts. The potential flexibility for individual grant programs for CoVID-related items can be found at: Grant Programs and COVID-related expenses - March 2020
Please contact the applicable Program Manager to update your budget with these considerations.
What is the status of FY 2020-21 State Grant competitions?
The Joint Budget Committee (JBC) will be meeting at the beginning of May to discuss the state revenue forecast and options for meeting state funding obligations for the current fiscal year as well as for fiscal year 2020-21. State agencies may be asked to revert 2019-20 unspent funding to assist with the financial situation in addition to budget reductions for the 2020-21 budget year.
Due to these circumstances, CDE will continue pausing current application processes for 2019-20 grant programs that have not yet been awarded or distributed. Once the JBC has concluded its work and the state budget has been passed by the Colorado General Assembly, the department will know whether it can distribute funds not yet awarded and distributed for the 2019-20 school year. At that time, the department will also know which new or currently funded grant programs will have funding for the 2020-21 school year to assist districts in making budget decisions. The continued pause in application processes does not apply to state grants already awarded and funded for the 2019-20 school year, federal grants, or categorical* grant funds.
*Categorical programs include: English Language Proficiency Act Program Funds, Gifted and Talented Education State Funding, Special Education State Funding, Transportation, Vocational Education State Funding, Small Attendance Centers, Expelled and At-Risk Student Services, and Comprehensive Health
The Competitive Grants and Awards Office will notify grantees if and when these applications will move forward.
My Non-Profit/Community Based Organization received funding from the Paycheck Protection Program (PPP). How to I manage those funds in relation to federal funding I received?
If a subrecipient receives a federally-guaranteed loan under the PPP to cover staff costs instead of its own funding, and later seeks reimbursement for those same costs from the SEA under their 21st Century Community Learning Centers (21st CCLC) competitive grant program or Adult Education and Family Literacy Act (AEFLA) award (for example), here are the following considerations on whether this would be a duplication or supplanting issue.
Duplication occurs when the subrecipient uses AEFLA or 21st CCLC funds to pay for specific costs already covered by other sources.
For example, if the subrecipient pays a staff position from the PPP loan then draws down AEFLA or 21st CCLC funds to cover the same staff position, but never pays the loan back because it was forgiven, the subrecipient may have duplicated costs (or otherwise made an improper payment), (see 2 C.F.R. 200.53), unless the forgiven loan funds are allocated to a different cost item.
For example:
- The PPP loan paid salary for employee 1, but then reallocated to pay salary for employee 2, and then used the AEFLA or 21st CCLC funds funds to pay for employee 1.
- If the subrecipient pays back the loan, it would not be duplication.
Supplanting occurs when a subrecipient intentionally replaces its nonfederal funding sources with AEFLA or 21st CCLC funding.
For example:
- If a subrecipient uses AEFLA or 21st CCLC funds to replace a PPP loan, then repays that loan instead of keeping the loan funds under the forgiveness provisions, it would not be supplanting.
- If a subrecipient uses AEFLA or 21st CCLC funds to replace a PPP loan, then uses those loan funds for another expense (whether the loan is forgiven or not), it typically would not be supplanting because PPP funding is not specifically designated for those particular service program purposes.
If a subgrantee wanted to use the PPP pay for personnel and then shift AEFLA or 21st CCLC funds in their grant off of personnel into other budget lines to help during the COVID-19 crisis, would that be allowable?
In general, as permitted by their state administering agency, a subrecipient may use PPP loan funds instead of AEFLA or 21st CCLC funding for specific cost items (e.g., using PPP instead of AEFLA or 21st CCLC funds for personnel, and using AEFLA or 21st CCLC funds for other allowable costs) to best use available victim service funding under the circumstances. Subrecipients should follow the budget modification requirements of their respective AEFLA or 21st CCLC Assistance state administering agency.
Is the PPP considered match?
Regarding match, a subrecipient using funds from a private loan (whether forgiven later or not) is essentially a subrecipient’s commitment of its own funds. Although the PPP loan is a federally guaranteed loan, this is not considered a loan (even if forgiven) to be funds “paid by the Federal Government under another Federal award” for purposes of match (see 2 C.F.R. § 200.306) – thus, such funds would be a permissible source of match for AEFLA or 21st CCLC funds projects. (The subrecipient could not use AEFLA or 21st CCLC funds to replace those loan funds and still count the loan funds as match).
May a grantee continue to pay the compensation of an employee paid with grant funds from the Colorado Department of Education during the period the employee is unable to work because his or her organization is closed due to novel Coronavirus Disease 2019 (COVID-19)?
Yes. Generally, a grantee may continue to charge the compensation (including but not necessarily limited to salaries, wages, and fringe benefits) of its employees who are paid by a currently active grant funded by the Department to that grant, consistent with the grantee's policies and procedures for paying compensation from all funding sources, federal and non-federal, under unexpected or extraordinary circumstances, such as a public health emergency like COVID-19. Thus, if the grantee pays, consistent with its policies and procedures, similarly situated employees whose compensation is paid with non-federal funds during an extended closure, those paid with grant funds from the Department may also continue to be paid. However, an employee who is being paid with Department grant funds while the program grant activities are closed in whole or in part due to the COVID-19 pandemic may not also be paid for the time during which the program is closed by the grantee or another organization for working on other activities that are not closed down. If a grantee does not currently have in place a policy that addresses extraordinary circumstances such as those caused by COVID-19, the grantee may amend or create a policy in order to put emergency contingencies in place for federal and non-federal similarly situated employees. If the conditions exist for charges to be made to the federal grant, charges may also be made to any non-federal sources that are used by a grantee or sub-grantee in order to meet a matching requirement.
A grantee must maintain appropriate records and cost documentation as required by 2 CFR §200.302(financial management), 2 CFR § 200.430(i) (standards for documenting personnel expenses), and 2 CFR §200.333(retention requirements for records) to substantiate the charging of any compensation costs related to interruption of operations or services. At the same time, recipients should consider ways that employees paid with grant funds can support continuing activities, including distance learning opportunities for students served by the grant.
Select Questions Related to Use of US Department of Education Grant Funds (PDF)
Additional considerations from CDE: If an employee is teleworking – ensure the treatment of those labor costs align with the grantee's policy and are consistently applied to federal and non-federal employees, ensuring all the same considerations as employees continuing to work onsite.
Consider if adjustment to work schedules or total hours is necessary, and also consider the repurposing of grant staff from one activity to another in alignment with the approved grant application, ensuring the purpose and beneficiary always remain the same and the job description is aligned.
If a conference, training, or other activity related to a grant from the Colorado Department of Education is cancelled due to COVID-19, may grant funds be used to reimburse nonrefundable travel (e.g., conveyance or lodging) or registration costs that were properly chargeable to the grant at the time of booking?
Yes, provided that a grantee first seeks to recover nonrefundable costs (e.g., travel, registration fees) associated with a grant from the Department from the relevant entity that charged the fee (e.g., airline, hotel, conference organizer). Some businesses are offering flexibility with regard to refunds, credits, and other remedies for losses due to the COVID-19 outbreak. Moreover, many agreements or contracts for conferences, training, or other activities related to a grant contain an emergency or “act of God” provision, and the grantee must seek to exercise those clauses to the extent possible in light of the COVID-19 outbreak. If a grantee is unable to recover the costs, the grantee may charge the appropriate grant for the cancellation costs, provided the costs were reasonable and incurred in order to carry out an allowable activity under the grant, consistent with the Federal cost principles described in 2 CFR Part 200 Subpart E of the Uniform Administrative Requirements, Cost Principles, And Audit Requirements For Federal Awards(Uniform Guidance).
Grantees should not assume additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel. Grantees must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 (financial management) and 2 CFR §200.333 (retention requirements for records) to substantiate the charging of any cancellation or other fees related to the interruption of operations or services.
Select Questions Related to Use of US Department of Education Grant Funds (PDF)
Additional considerations from CDE: Entities can charge the cancelled travel costs (travel costs banked, airline tickets, conference fee) to the federal award in its entirety at time of cancellation (obligation date). Every effort (and internal control) should be made to utilize that banked airline credit. For example, using that credit for another trip for the same federal award. Best practice would be to have the employee sign an agreement stating they will use those credits for work purposes.
Always document the cancellation costs to the grant with support. Documentation to be maintained with fiscal grant files should include dates cancelled, agenda or trip detail, internal travel cancellation policy due to pandemic, signed employee agreement regarding usage of the credit for the same future or other federal conference, as well as receipts for the original costs should.
If a grantee is planning future travel under a grant from the Colorado Department of Education, may it purchase travel insurance with grant funds?
Due to health concerns related to COVID-19, grant-supported travel generally should not be occurring. However, if travel is permitted by federal, state, and local directives and is the only means to carry out an essential grant function that must be undertaken on a time-sensitive basis during the COVID-19 pandemic, consistent with the grantee's travel policy, travel insurance is allowable provided the cost is reasonable and allocable to the grant consistent with the federal cost principles described in 2 CFR Part 200 Subpart E of the Uniform Guidance.
Select Questions Related to Use of US Department of Education Grant Funds (PDF)
My district/school is delivering meals to our students. Can those transportation costs be claimed against my Nutrition Grant/Assistance?
There is no additional reimbursement for home delivery or mobile meals delivery, but related expenses, such as postage or delivery service fees, would be considered an allowable cost under the summer Food School Program (SFSP) or Seamless Summer Option (SSO). Delivery costs could also be paid with non-program funds such as state or local funds, or private donations. View more details on transportation costs here.
What if I can't get my nutrition reimbursement claim in before the 60 day cut off?
Claims for reimbursement are required no later than 60 days following the last day of the full month covered by the claim, unless otherwise authorized by CDE. CDE expects that districts will continue to make timely claims submissions to the greatest extent practicable. However, CDE and the USDA recognize current challenges may delay the submission and/or adjustment of claims for reasons falling beyond the local agency's control. Contact CDE for any exceptions.
Please note that the meals served during Emergency Feeding are coming from the Summer Food Service Program (SFSP) grant. All other meals served by districts in March before school closures for COVID-19 will be claimed under the National School Lunch Program (NLSP) and School Breakfast Program (SBP) and coded accordingly.
More details are available at: CDE School Nutrition Waivers
Will FY1920 budget revision and FY20-21 continuation budget due date be extended?
For any budget revisions allowed and submitted, please ensure that the beneficiary and intended purpose remains the same. While changes in budget to allow distance learning or other COVID19 related changes may be allowed, the purpose and beneficiary (students or staff) remains the same. A change in scope and budget to allow technology purchases (for distance learning, to meet IEP goals and virtual instruction and services) or costs to delay an activity are types of allowable budget changes.
Budget revisions to accommodate these COVID19 related changes will be accepted at any time. Please work with your Program Manager and Grants Fiscal Analyst.
For continuation grants/budgets, please visit the BUDGET AND APPLICATION Section of these FAQs.
Have there been any changes to the OMB Procurement guidance?
Awarding agencies may waive the procurement requirements contained in 2 CFR§ 200.319(b) regarding geographical preferences and 2 CFR§ 200.321 regarding contracting small and minority businesses, women's business enterprises, and labor surplus area firms.
March 19, 2020 M-20-17 MEMORANDUM TO THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES
Additional considerations from CDE: OMB did not grant any major procurement revisions, with the exception of sole sourcing due to extreme circumstances (timeliness) and geographic locations, and the provision to purchase from minority and women owned businesses.
Be careful with sole sourcing, do not abuse the flexibility.
Grantees should get documented quotes and ensure to document the decision if you utilize these flexibilities.
Grantees should review the contracts in place with service providers for grants. Determine if the organization is paying for services the service provider cannot provide due to the suspension of in person instruction. Revisit if the contract should be canceled or suspended.
Contracts will not define how to pay (or not) for work not received/completed/provided. Grantees should look at the scope and pay structure and amend the scope and deliverables going forward. Grantees should determine if the contract should be terminated or amended. Paying contractors from grants without documentation that they delivered what was reasonable, allowable, allocable and contracted for, may result in audit findings.
LEAs should use caution continuing to pay contractors with grant funds for services without documentation that it is allowable and allocable that are not being delivered due to suspension of in person instruction. Unless the contract says there is a condition for this situation showing how it is allowable and allocable, most likely you will be required to amend the statement of work and pay structure. There is no flexibility if this is not outlined in the contract.
My districts' Indirect Cost Rate (ICR) will expire soon. Do we have any leeway on timing?
CDE has already calculated ICR for 2021 applications, so no flexibility is required.
What sort of documentation should I retain for labor costs, purchases, etc. to support these flexible guidelines?
Any extraordinary circumstance or operation and expense outside normal fiscal and federal regulation should be documented carefully. For all purchases, best practice would be to document the WHY and WHO the purchase will serve and the specific cost objective or deliverable in the grant that the purchase will support. This applies to labor costs as well. For example, a memo attached to the purchasing support would include the item, the approvals the deliverable copied from the grant budget and how this purchase will support would help assuage questions during an audit.
Remember, if people are working remotely, then digital signatures and email approval should be included. If approving by email (purchases or time and effort,) you will need to be specific in the email as to what the approval is for, document the reason for the approval (what it is, etc.) within the body of the email.
We are going to purchase some technology for distance learning, what should we consider?
Track the location and assignment of all technology hardware. Inventory as you would equipment purchase under 2CFR 200.313(b)(4) and include an agreement with the student/family indicating the cost of the item and the repercussions should that item not be returned or damaged. Remember, the grant funds must remain whole and any equipment lost, stolen or damaged must be reported to your Grants Fiscal Analyst for further instructions for repayment to the grant fund, document insurance claim, etc.
In addition, ensure that your entity has an internal policy for checking out equipment so the whereabouts can be tracked.
For additional information regarding caps on ESEA technology, visit (ESEA FAQ).
Has the 15% technology threshold been waived by the US Dept of Education for our Title IV-A funds?
On April 6, 2020, CDE applied for and received authority to waive section section 4109(b) of Title IV, Part A of the ESEA with respect to the spending limitation for technology infrastructure for FY 2018 and FY 2019.
In addition, CDE also received authority to waive 4106(d) of Title IV, Part A of the ESEA related to local educational agency (LEA) needs assessments for the 2019-2020 school year and section 4106(e)(2)(C), (D), and (E) of Title IV, Part A of the ESEA with respect to content-area spending requirements for FYs 2018 and 2019 Title IV, Part A funds.
CDE is awaiting formal approval of these waivers. Additional information on the implementation of this waiver is forthcoming.
Has the 15% carryover limitation for Title I Part A FY 2019 funds been relaxed?
CDE applied for and received authority to waive the Title I 15% carryover limitation in ESEA Section 1127 for FY 2019 on April 6, 2020. This authority will give all Colorado districts the ability to carry over excess Title I funds due to the Coronavirus pandemic. CDE is awaiting formal approval of these waivers. We will be providing additional information on the implementation of this waiver as soon as it becomes available.
We have rented a classroom, building or other space to utilize for our adult education or after school programs. Now that they are closed to in person learning, we are still liable for the lease. What should we do?
If the LEA is paying a lease for a classroom, for example, that is now closed, use the Idle Capacity reg 2 CFR 200.446 to continue to pay the lease.
What about other, additional unplanned costs such as increased janitorial/maintenance labor costs and supplies or new/different transportation costs related to delivering services and supports?
These sorts of costs can be added to the grant budget if allowable and does NOT supplant General Fund costs. If they are specific costs for specific grant programs, justification and supporting documentation are key. Remember, the beneficiary and intent of the grant must remain if you plan to expense these costs. These types of costs may be very difficult to link to program objectives so caution should be utilized.
Has the Colorado Department of Education received Assessment Waivers?
CDE applied for and received approval to waive the assessment and accountability requirements under The Every Student Succeeds Act (ESSA).
See information for additional waivers received under the Fiscal - Allowable Costs - OMB Guidance Section of these FAQs.
CDE invites all interested parties to submit any comments related to the waiver by April 24, 2020 to ESSAquestions@cde.state.co.us or mail to:
Colorado Department of Education
Federal Programs Unit
1560 Broadway, Suite 1100
Denver, CO 80202-5149
Colorado's ESEA Assessment and Accountability Waiver
Meal Service Options During COVID-19 Questions and Answers (PDF)
How can I ensure I get my grant reimbursement payments?
Grants Fiscal has put into place an electronic review process with our Accounting department, to ensure that these requests for reimbursements are processed on the same schedule as usual, so all reimbursements should happen in the same manner as pre-CoVID-19.
Will there be any guidance or option to delay the single audit submissions for FY2020?
Extension of single audit submission (2 CFR 200.512): Recipients who have not yet filed their single audits with the Federal Audit Clearinghouse and have a fiscal year-end through June 30, 2020, should receive a six (6) month extension beyond the normal due date. Recipients do not have to seek approval from agencies for this extension. This delay will still qualify the recipient as ‘low-risk auditee' under the criteria of 2 CFR 200.520 (a).
CDE can provide an extension for receipt of these audits for 6 additional months beyond normal due date. However, the requirements to submit audited financial statements pursuant to the Local Government Audit Law (C.R.S. 29-1-606) remains in place.
We will have close out reports due soon, will there be any delay or allowance of time?
Extension of closeout (2 CFR 200.343): Awarding agencies may allow the grantee to delay submission of any pending financial, performance and other reports required by the terms of the award for the closeout of expired projects, provided that proper notice about the reporting delay is given by the grantee to the agency. This delay in submitting closeout reports may not exceed one year after the award expires.
Check with your Grant Fiscal Analyst or Program Manager for details, as your grant may have received an automatic 12 month no-cost-extension.
Will AFR due date be extended? What will the new deadlines be for EOY reporting and interim financial reports?
If your grant was allowed a 12 month no cost extension, the schedule for those interim and annual financial reports will remain the same. What would have been an annual financial report due at the close of a grant ending 6/30/2020 with the report due to Grants Fiscal Management in September 2020, would now include those expenditures through 6/30/2021 and be due in September 2021. Interim financial reports should continue as scheduled.
What sort of documentation should I retain for purchases, labor costs, contracts, etc., during this extraordinary time?
More is better! Ensure that you include approvals, quote comparisons, written justifications for specific purchase/activity and how it supports the intent of the award AND the original beneficiary of the award. Include your internal policy flexibility documented why the flexibility occurs (site closure, distance learning, labor cost continuation, etc.
For more information on finance related topics, districts may contact the following:
Jennifer Austin - Director, Grants Fiscal Management
303-866-6689
austin_j@cde.state.co.us
Financial information on schools and districts throughout Colorado. Learn more about financial transparency.
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UPDATED
May 28, 2020
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