In the October 19, 2020 FAQs outlining the allowable expenses for CRF, the U.S. Department of Treasury states in FAQ #53
(PDF) “as an administrative convenience, Treasury will presume that expenses of up to $500 per elementary and secondary school student are eligible expenditures, such that schools do not need to document the specific use of funds up to that amount.”
It is important to note that this guidance only relates to CRF (not ESSER, GEER, or GF). CDE recommends that the $500 per student allowability should be based on 2020–21 enrollment as reported and certified in the California Longitudinal Pupil Achievement Data System as of October 2020.
For LEAs that received $500 per student or less in CRF:
You may use this option but must ensure that funds are still spent in the required timeframe of March 1, 2020 – May 31, 2021.
For the CRF reporting in the CDE Stimulus Funding Reporting Portal, when reporting in the exact dollars section, an LEA that meets this threshold would enter expenditures and/or obligations in the “Facilitating Distance Learning” category and list what funds have been obligated or expended.
For the percentages section, LEAs should calculate the expenditures by percentage and enter them into the proper category to meet the state required LLMF reporting.
LEAs are not required to adjust their reported expenditures if they have already reported the entirety of their CRF in the CDE Stimulus Funding Reporting Portal. If they have not expended or obligated all of their funds yet, they may choose to leave their previous reporting as is or move the previous expenditures into the “Facilitating Distance Learning” category.
For LEAs that received more than $500 per student in CRF:
Treasury also specifies that schools may for certain expenditures exceed the $500 per student. These expenses are limited to specified expenses discussed below and require additional documentation and detailed reporting. As such, the reporting approach falls into two categories based on the amount per student.
Consistent with U.S. Treasury guidance, an LEA that received more than $500 CRF per student may use the administrative convenience of up to $500/per student presumption AND may use any amount above $500 per student for the following limited expenses for the purpose of addressing COVID-19:
- 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; or
- Incurring additional costs of providing meals.
In other words, if taking advantage of the flexibility, the LEA must use the CRF in excess of the $500/per student threshold only on the seven activities outlined above. These funds must also be spent in the required timeframe of March 1, 2020 – May 31, 2021.
NOTE: The CDE recommends LEAs be cautious in using this allowability. This allowability will not absolve LEAs of the need to maintain documentation for all funds used above the $500 per student allowability. For funds above $500 per student, LEAs will be required to maintain documentation to substantiate:
- The information reported to CDE on expenditure of CRF in each category.
- That the LEA used CRF only during the period of availability.
- The LEA used its CRF in accordance with state requirements as outlined in SB 98 (Committee on Budget and Fiscal Review, Chapter 24, Statutes of 2020) LLMF.
- Any funds received above $500 per student are used in accordance with federal requirements.
If an LEA decides to still use this option, when reporting in the exact dollars section, an LEA would enter the eligible expenditure (up to $500 per student) in the “Facilitating Distance Learning” category and list what funds have been obligated or expended. For any funds beyond that, they must be listed in the appropriate category to which they correspond (Note: some of these excess funds may still be listed in the “Facilitating Distance Learning Category”).
For the percentages section, LEAs should calculate the expenditures by percentage and enter them into the proper category to meet the state required LLMF reporting.
