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Accounting for AB 86 Funding – IPI and ELO Grants

This guidance was sent via email on April 15, 2021 to the SACS Forum, ESSCO, and COFS email distribution lists regarding accounting for the Assembly Bill (AB) 86 funding – In-Person Instruction (IPI) and Expanded Learning Opportunities (ELO) Grants.

To assist local educational agencies (LEAs) with reopening schools in the 2020–21 school year and to implement a learning recovery program, the state legislature approved Assembly Bill (AB) 86 (Chapter 10, Statutes of 2021) that provides funding to support these activities – In-Person Instruction Grant and Expanded Learning Opportunities Grant.

Following is guidance to assist LEAs with accounting for these grants.

In-Person Instruction (IPI) Grant

The California Department of Education (CDE) has established Resource 7422, In-Person Instruction (IPI) Grant, effective 2020–21, to allow LEAs to account for IPI grant revenues and expenditures. Resource 7422 is subject to unearned revenue. LEAs will not recognize revenue until all eligibility requirements are met, which is when LEAs offer in-person instruction pursuant to Education Code (EC) Section 43521(c)(3) by May 15, 2021.

Note that IPI grant revenue is affected by the number of days the LEA delays offering in-person instruction, pursuant to EC Section 43521(c)(2)(B)(i). Revenue recognized should reflect these adjustments, if applicable. No revenue should be recognized by LEAs that do not plan to offer in-person instruction by May 15, 2021. Any funding that must be returned to CDE should be recorded to Object 9590, Due to Grantor Governments.

Expanded Learning Opportunities (ELO) Grant

The CDE has established Resource 7425, Expanded Learning Opportunities (ELO) Grant, to allow LEAs to account for ELO grant revenues and expenditures. In addition, EC Section 43522(c) requires that at least ten percent of the funds appropriated under EC Section 43521(b)(3) (part of the ELO grant) must be used to hire paraprofessional staff to provide supplemental instruction and support throughout the learning recovery program as defined in EC Section 43522(a). Therefore, CDE has also established Resource 7426, Expanded Learning Opportunities (ELO) Grant: Paraprofessional Staff, to assist LEAs in complying with this requirement.

Both Resource 7425 and 7426 are effective 2020–21. Carryover of unexpended balances in Resource 7425 is reported as restricted ending balance (Object 9740).

Expenditures reported using Resource 7426 should be limited to paraprofessional staff salary and benefits, e.g., Object 2100, Classified Instructional Salaries, and corresponding benefit objects 3XX2, using the appropriate goal and/or functions. In order to reduce the potential reporting burden on LEAs should paraprofessional expenditures exceed the minimum ten percent required, e.g., having to split one staff’s salary and benefit expenditure entries between Resource 7425 and Resource 7426, all ELO paraprofessional staff expenditures should be reported using Resource 7426.

Revenue reported in Resource 7426 using Object 8590, All Other State Revenue, should equal ten percent of the funds appropriated under EC 43521(b)(3), as provided in column D.2 of the schedule of estimated allocations for the IPI and ELO grants, available on the CDE IPI and ELO Grants Funding Results web page. Since Resource 7426 is used to record total ELO paraprofessional salary and benefit expenditures, LEAs should record a contribution from Resource 7425 to Resource 7426 using Object 8990, Contributions from Restricted Revenues, for the excess of expenditures over the minimum required ten percent, i.e., amount reported in Object 8590. Please note that the contribution should be limited to the actual expenditures incurred. In addition, restricted contributions can only be made to Resource 7426 from Resource 7425.

Contributions to ELO and IPI Grants

Please note that CDE will not open Resource 7422, 7425, and 7426 in combination with Object 8980, Contributions from Unrestricted Revenues. Because ELO and IPI grant awards are intended to provide emergency relief to LEAs to address the impact that COVID-19 has had on education, and not a “program,” in the sense that it is not “a group of related activities that operate together to accomplish specific purposes or objectives,” it would be counterintuitive to the reason for contributions to allow them for these funding sources. The customary reason for recording unrestricted contributions to a program is to keep program expenditures together, which does not apply in this context. Furthermore, because LEAs have a statutory requirement to report the receipt and use of ELO and IPI grant, contributions to resources 7422, 7425, and 7426 would distort ELO and IPI expenditures and not result in the intended reporting transparency.

For these same reasons, Object 8990, Contributions from Restricted Revenues, will not be opened for Resource 7422. Note that restricted contributions are allowed from Resource 7425 to Resource 7426, as discussed previously under the ELO grant accounting guidance. Appropriate documentation should be maintained to demonstrate that the contribution is made from Resource 7425 to Resource 7426.

Questions regarding this accounting guidance may be emailed to the Financial Accountability and Information Services office at sacsinfo@cde.ca.gov.

Questions regarding the IPI and ELO grants may be emailed to InPersonGrants@cde.ca.gov and ELOGrants@cde.ca.gov respectively.

Further information regarding ELO and IPI funding can be found on the CDE COVID-19 Relief and School Reopening Grant web page.

Questions:   Financial Accountability & Information Services | sacsinfo@cde.ca.gov
Last Reviewed: Monday, April 19, 2021