FY 2020–21 ESSA CSI LEA Subgrant CloseoutInformation regarding the Every Student Succeeds Act (ESSA) Comprehensive Support and Improvement (CSI) Local Educational Agency (LEA) Subgrant Closeout Timeline, Instructions, and Resources for Fiscal Year (FY) 2020–21.
The FY 2020–21 CSI LEA Federal Subgrant Closeout web page includes information about the timeline to close out the FY 2020–21 ESSA CSI LEA subgrant; information pertaining to the retention and access to records requirements; use, management, and disposition of equipment and supplies purchased with federal funds, inventory and resources. These topics are supported by citations contained within the Code of Federal Regulations (CFR). (The Uniform Grant Guidance [UGG] is contained in 2 CFR Part 200 . For more information about the UGG, see the federal guidance and other resources .)
The General Education Provisions Act Section 421(b)(1) and the Elementary and Secondary Education Act as reauthorized by the ESSA Section 1127(a), state that any Title I funds received, which are not obligated and expended by the LEA within the current FY, shall remain available for obligation and expenditure for one additional FY. All remaining funds not expended or obligated by September 30 of the succeeding FY shall be returned to the California Department of Education (CDE).
The federal requirements found in the Office of Management and Budget guidance cited at Title 2, CFR, Part 200.344, Closeout is the process by which the CDE determines that all applicable administrative actions and all required work of the federal award have been completed for the allocation year.
For guidance from the California School Accounting Manual for accounting and financial reporting by LEAs and for helpful information on “Distinguishing Between Supplies and Equipment,” see Procedure 770 at Definitions, Instructions, & Procedures.
- Subgrant funds must be expended by September 30, 2022, and the LEA must liquidate its funds within 90 days of reporting final expenditures. If the LEA closes out its subgrant on a date prior to September 30, 2022, the LEA should liquidate its expenditures within 90 days of reporting final expenditures. All expenditures must be liquidated within 90 days from September 30, 2022.
- Final expenditures must be reported in the Grant Management and Reporting Tool (GMART) on or before October 31, 2022.
- The School Improvement and Support Office will review for approval, final expenditure reports on or before November 30, 2022.
- Even after an LEA has closed out its subgrant, LEAs are responsible for reporting the required Federal Reporting data based on the Federal Reporting Timeline.
- Unused ESSA CSI 1003(a) will revert Title I, subpart 2 of part A per ESSA CSI 1003 (a)(g)(1).
Retention and Access to Records Requirements
Financial records, supporting documents, statistical records, and all other records pertinent to the federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the federal awarding agency or pass-through entity in the case of a subrecipient (2 CFR § 200.334).
There is one exception for the length of time that a nonfederal entity must retain records relating to equipment. Records for real property or equipment acquired with Federal funds must be retained for 3 years after final disposition (2 CFR § 200.334[c]). Thus, the grantee must keep managing property and maintaining records related to such management of the property for at least 3 years after it finally disposes of the property.
The Secretary and the Comptroller General of the United States, or any of their duly authorized representatives, shall have access, for the purpose of audit examination, to any records maintained by a recipient that may be related, or pertinent to, grants, subgrants, cooperative agreements, loans, or other arrangements or which may relate to the compliance of the recipient with any requirement of an applicable program. All records must be maintained in a way that provides timely and reasonable access in order to make audits, examinations, excerpts, and transcripts, including timely and reasonable access to personnel for the purpose of interview and discussion related to such documents (2 CFR § 200.337).
Use, Management, and Disposition of Equipment and Supplies Purchased with Federal Funds
The use, management, and disposition of equipment and supplies purchased with federal funds is governed by federal regulations, particularly the Property Standards found at 2 CFR § 200.310 – 200.316.
Re: “Equipment,” as defined: “Equipment” is defined as tangible personal property having a useful life of more than one year and a per-unit acquisition cost that equals or exceeds the lesser of $5,000 or the capitalization level established by the grantee for accounting/financial statement purposes (2 CFR § 200.1).
Title to and use of Equipment
Generally, a grantee acquiring Equipment under the federal grant takes a “conditional title” to the Equipment – it owns and may continue to use the property subject to certain conditions (2 CFR § 200.313[a]). Those conditions include that the grantee must: (1) use the Equipment for the authorized purposes of the project during the period of performance, or until the property is no longer needed for the purposes of the project; and (2) not encumber the property without state or federal approval. (Id.)
In addition, even after the grant ends, use and disposition conditions and requirements apply with respect to the Equipment. For example, the grantee must continue to use the Equipment in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the Federal award (2 CFR § 200.313[c]).
When no longer needed for the original program or project, the Equipment may be used in other federally-supported activities, in the following order of priority: first, activities under another federal award from the U.S. Department of Education; and then second, activities under federal awards from other federal agencies. (Id.)
Management of Equipment until Disposition
Until disposition, grantees must continue to follow proper management procedures with respect to Equipment (2 CFR § 200.313[d]). Such procedures will, at a minimum, include: (1) maintaining property records that include the information specified in (2 CFR § 200.313[d]); (2) a physical inventory and reconciliation with the written records at least once every two years; (3) a control system to ensure adequate safeguards against loss, damage or theft; and (4) adequate maintenance procedures. (Id.)
Ultimate Disposition of Equipment
Generally, when Equipment is no longer needed for the original project or program, or put to use in other currently or previously federally-supported activities, the following disposition rules apply: (1) items of Equipment with a then-current per unit fair market value of $5,000 or less may be retained, sold, or otherwise disposed of with no further responsibility to the U.S. Department of Education; (2) items of Equipment with a then-current per unit fair market value in excess of $5,000 may be retained or sold, but the U.S. Department of Education must be compensated for its share of the cost of the original purchase (i.e., the product of multiplying the current market value [or proceeds from the sale] by the federal agency’s percentage of participation in the cost of the original purchase). If the equipment is sold, then the grantee may deduct from the federal agency’s share the lesser of $500 or ten percent of the proceeds for its selling and handling expenses (2 CFR § 200.313[e]).
Re: “Inventory,” as defined: “Inventory” is an itemized list for tracking and controlling property.
The governing board of each school district, shall establish and maintain a historical inventory, or an audit trace inventory system, or any other inventory system authorized by the State Board of Education, which shall contain the description, name, identification numbers, and original cost of all items of equipment acquired by it whose current market value exceeds five hundred dollars ($500) per item, the date of acquisition, the location of use, and the time and mode of disposal. A reasonable estimate of the original cost may be used if the actual original cost is unknown (California Education Code Section 35168).
Materials and Supplies Costs Including Costs of Computing Devices
Re: “Supplies,” as defined: “Supplies” is defined as all tangible personal property that does not qualify as “Equipment” (because it does not have a useful life of more than one year, or a sufficiently high per-unit acquisition price) (2 CFR § 200.1).
Title, Use, and Disposition of Supplies
Title to “Supplies” acquired under the grant vests in the grantee (2 CFR § 200.314). The grantee must use the Supplies for the project or program for which they were acquired.
Upon termination or completion of such project or program, the grantee may use any residual Supplies in support of any other federal award. (Id.)
If there is a residual inventory of unused Supplies upon termination or completion of the project or program, and the Supplies are not needed for any other federal award, then the grantee must compensate the U.S. Department of Education if the total aggregate value of such unused Supplies at that time is greater than $5,000. If the total aggregate value is less than $5,000, then there is no compensation requirement. The amount of compensation is computed in the same manner as with respect to Equipment, discussed above. (Id.)
For additional information related to CSI, please visit the CDE CSI web page.