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ARP EANS & GEER II

2022 Emergency Assistance for Students and Teachers in Non-Public Schools

The Nebraska Department of Education will provide three COVID-19 emergency assistance programs for Nebraska non-public schools through the Governor’s COVID-19 emergency award of funds.

An eligible non-public school is anticipated to quality for services and assistance under one of the three relief aid programs unless a school collectively received a loan(s) guaranteed by the Payment Protection Program (PPP) on or after December 27, 2020, that was larger than the amounts calculated under CRRSA EANS (EANS I), and ARP EANS (EANS II) combined.

ARP EANS Key Takeaways

The U.S. Department of Education launched the Emergency Assistance for Non-Public Schools (EANS) initiative through the American Rescue Plan (ARP) Act in March 2021. Under the ARP EANS program, the Governor secured through an approved application and for the Nebraska Department of Education to administrate $17,054,414 in school aid to provide services or assistance to eligible non-public schools to address the impact that the Coronavirus Disease 2019 (COVID-19) emergency has had, and continues to have, on non-public school student and teacher in the State.

    • Reserved from the American Rescue Plan (ARP) Act specifically for non-public schools
    • Additional emphasis on serving eligible nonpublic schools that enroll a significant percentage of low-income students and are most impacted by the qualifying emergency
    • Reimbursement is not an allowable activity
    • Service and assistance period ends September 30, 2024

GEER II Key Takeaways

The U.S. Department of Education launched the Governor’s Emergency Education Relief (GEER II) Fund through the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA) on December 27, 2020.  Under the GEER II Fund, the Governor secured $7,161,168 in funds intended to help mitigate the impact of COVID-19 for all students and families, including those who choose non-public schools.

The Nebraska Department of Education will provide two (2) emergency assistance programs specifically for Nebraska non-public schools from the Nebraska GEER II award of funds:

  • Geer II Supplemental Assistance, $2,250,000 school aid
    • Priority #1
      • For schools not served under ARP EANS
      • Emphasis on serving students from families of low-income and most impacted factors consistent with ARP EANS index for distribution
      • Provides for direct assistance and services consistent with ARP EANS allowable activities whereas indirect reimbursement activities are not allowable
      • Service and assistance period ends September 30, 2023
    • Priority #2
  • GEER II Gap Assistance, $900,000 school aid
    • For schools that received funds under the Paycheck Protection Program (PPP) on or after December 27, 2020
    • Whereas the school received fewer funds than what would have been provided to the school under the CRRSA EANS and ARP EANS programs, resulting in a funding gap
    • Provides for direct assistance/services and indirect reimbursement (including pre-award costs dating back to March 13, 2020) consistent with CRRSA EANS allowable activities
    • Service and assistance period ends September 30, 2023

Overview

Rescue Plan Emergency Assistance to Non-Public Schools (ARP EANS)

The American Rescue Plan Act of 2021 (ARP Act), Pub. Law 117-2 (March 11, 2021) provides awards to Governors under the American Rescue Plan Emergency Assistance to Non-Public Schools (ARP EANS) program to provide services or assistance for eligible non-public elementary and secondary schools to address the impact that COVID-19 has had, and continues to have, on non-public school students and teachers in the State. This is the second round of relief assistance and services for Nebraska non-public schools. Nebraska’s approved ARP EANS award will potentially result in over 84% of low-income students enrolled in non-public schools being served through services and assistance to non-public schools with targeted higher levels of assistance to those schools that enroll a greater share of students from low-income backgrounds.

After several meetings and conversations with the United Stated Department of Education, Nebraska’s application was approved on February 23, 2022. The U.S. Department of Education required a Significant Poverty Percentage threshold of 22% to gain approval for the application. This then means that any school with a Significant Poverty Percentage of 22% or higher would meet this eligibility aspect of the program. Significant Poverty Percentage is calculated by the higher of a non-public school’s low-income data or proportionality of the public school district’s poverty percentage in which a nonpublic school resides and serves the same community.  Lower than 22% becomes ineligible for the ARP EANS program.

  • Sources of Low-Income Data allowable provided the poverty threshold is consistent across all data sources and does not exceed 185 percent of the 2020 federal poverty level:
    • Data on student eligibility for free or reduced-price lunch; Income Guidelines for 19-20 School Nutrition Program
    • Data from the E-Rate program administered by the Federal Communication Commission
    • Data from a different source, such as scholarship or financial assistance data
  • Under the Federal Final Requirements, an eligible non-public school must also be most-impacted by the COVID-19 emergency by at least one most-impacted factors.  The State was approved to utilize the following Most-Impacted Factors:
    • University of Nebraska Medical Center’s Social Vulnerability Index (Above 50th Percentile)
    • The number of COVID-19 infections per capita in the county served by the non-public school with above State average cases
    • The number of COVID-19 deaths per capita in the county served by the non-public school with above State average cases
    • Data on student eligibility for free or reduced-price lunch counts by grade span and greater than or equal to the averaging method (lesser or average or median) by grade span
    • Data on economic impact of the COVID-19 emergency and mitigation costs/strategies per the Center for Disease Control and Prevention (CDC) and the Nebraska cost per student ($436) with total school costs greater than or equal to the averaging method (lessor of average or median) by grade span
  • The Department will allocate services or assistance to an Eligible Non-Public School which meet the following criteria through the period of September 30, 2024:
    • Is non-profit,
    • Serving K-12 students,
    • Is accredited or approved to operate in accordance with Nebraska Administrative Rule 10 or 14, respectively,
    • Accredited or approved to operate prior to March 13, 2020; the date a national emergency was declared,
    • Students from Low Income Families 2019-2020 Data from a low-income source that does not exceed 185 percent of the 2020 Federal poverty level and generates a Significant Poverty Percentage of 22% or higher. A non-public school’s poverty percentage also incorporates proportionate poverty data (22% growth limitation) from the public school district in which the non-public school resides and serves the same community.
    • Most-impacted by the COVID-19 emergency and meeting one of the most-impacted factors, and
    • Did not, and will not, apply for and receive a loan under the Small Business Administration’s Paycheck Protection Program (PPP) (15 U.S.C. 636(a)(37)) that is made on or after December 27, 2020. Schools will be considered ineligible if they accepted PPP on or after December 27, 2020.

Governor’s Emergency Education Relief Supplemental Assistance (GEER II Supplemental Assistance)

The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSA), Pub. L. No. 116-260 (December 27, 2020) provides awards to Governors under the Governor’s Emergency Education Relief (GEER II) Fund, whereas the Governor has determined that it would serve the aims of the CRRSA to use $2,250,000 of the GEER II funds to provide assistance and services to eligible non-public schools that have incurred or will incur expenses to address educational disruptions related to COVID-19 but which are not covered by ARP EANS either because (1) no funds have been allocated to the non-public school under the ARP EANS program; or (2) the expenses were incurred prior to the availability of funds in Nebraska under the ARP EANS and funds remain available.

  • Priority #1 – Schools Not Served Under ARP EANS
    • An Eligible School is a Nebraska non-public school that did not receive any loan under the Small Business Administration’s Paycheck Protection Program (PPP) (15 U.S.C. 636(a)(37)) that was made on or after December 27, 2020, and did not receive an allocation of funds under ARP EANS.
    • The Minimum Per Pupil ARP EANS Award is the lowest per-pupil amount of any award allocated to a Nebraska non-public school under the ARP EANS program.
    • Eligible Service or Assistance is any service or assistance to address educational disruptions resulting from COVID-19 at an Eligible School if such service or assistance is of a category that would have been an allowable service under ARP EANS through the period of September 30, 2023.
    • Consistent with ARP EANS, reimbursement is not an allowable activity.
    • Geer II funds will be allocated to Eligible Schools that received no allocation from the ARP EANS program, provided that no distribution under this provision should exceed the Minimum Per Pupil ARP EANS Award. Schools allocated funds under Priority 1 may receive Eligible Services and Assistance for the 2021-2022 and/or 2022-2023 school year.
  • Priority #2 – Reimbursement
    • An Eligible School is a Nebraska non-public school that did not receive any loan under the Small Business Administration’s Paycheck Protection Program (PPP) (15 U.S.C. 636(a)(37)) that was made on or after December 27, 2020, and incurred expenses during the 2021-2022 school year for services or assistance to address educational disruptions resulting from COVID-19 prior to the date ARP EANS and GEER II: Supplemental Priority #1 services were mad available for use by Nebraska non-public schools.
    • Eligible Reimbursement is any reimbursement for actual, reasonable, and necessary expenses incurred by an Eligible School for a service or assistance to address educational disruptions resulting from COVID-19 if (a) such service or assistance is of a category that would have been an allowable service or expense under CRRSA EANS as specified in Section 312(d)(4)(A)-(L) of the CRRSA; (b) such service or assistance is not of a category for which reimbursement was prohibited under CRRSA EANS as specified in Section 312(d)(4)(M) of the CRRSA; and (c) such expense was not paid using any other source of federal funds.
    • Remaining GEER II Funds available under this reservation, if any, will be allocated to Eligible Schools for Eligible Reimbursements for services or assistance that (1) are of a category that would have been allowable under CRRSA EANS and not prohibited; (2) were incurred during or for the 2021-2022 school year, and (3) before ARP EANS funds were available for use by Nebraska schools.
    • Funds not able to be budgeted for reimbursements prior to August 1, 2021 may be used for services moving forward into the 2022-2023 school year.

Governor’s Emergency Education Relief Gap Assistance (GEER II Gap Assistance)

The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSA), Pub. L. No. 116-260 (December 27, 2020) provides awards to Governors under the Governor’s Emergency Education Relief (GEER II) Fund, whereas the Governor has determined that it would serve the aims of the CRRSA to use $900,000 of the GEER II funds to provide assistance and services to non-public schools that received a loan under the Small Business Administration’s Paycheck Protection Program (PPP) (15 U.S.C. 636(a)(37) that was made on or after December 27, 2020 and experienced a funding gap due to ineligibility for assistance and services under the CRRSA EANS and ARP EANS programs.

  •  A PPP Gap School is a non-public school that (a) received funds through PPP on or after December 27, 2020; (b) was denied funds that otherwise would have been available to the school under CRRSA EANS and ARP EANS because of funds the school received through PPP; and (c) would have received more from combined allocations under CRRSA EANS and ARP EANS than the amount the school received from the PPP on or after December 27, 2020.
  • Amount of the PPP Gap is the difference between (a) the combined allocation that a PPP Gap School would have received from CRRSA EANS and ARP EANS if the school had not received PPP funds; and (b) the amount of funds the school received under the PPP program on or after December 27, 2020.
  • Eligible Service or Assistance is any service or assistance to address educational disruptions resulting from COVID-19 at PPP Gap Schools if such service or assistance is of a category that would have been an allowable service or expense under CRRSA EANS as specified in Section 312(d)(4)(A)-(L) of CRRSA.
  • Eligible Reimbursement is any reimbursement for actual, reasonable, and necessary expenses incurred by a PPP Gap School, at any time between March 13, 2020 and September 20, 2023, for a service or assistance to address educational disruptions resulting from COVID-19 if (a) such service or assistance is of a category that would have been an allowable service or expense under CRRSA EANS as specified in Section 312(d)(4)(A)-(L) of the CRRSA; (b) such service or assistance is not of a category for which reimbursement was prohibited under CRRSA EANS as specified in Section 312(d)(4)(M) of the CRRSA; and (c) such expense was not paid using any other source of federal funds.

 Updated – Program Timeline (April 27, 2022)

 

Date Year Activity
March 22 2022 Program Webinar: 2022 Emergency Assistance to Nonpublic Schools, Part 1

Application Published
March 22 – April 12 2022 Application Deadline
April 20 – May 3 2022 Applications Approved
May 4 2022 Final Services and Assistance Published

Program Webinar: 2022 Emergency Assistance to Non-public Schools, Part 2

Schools Begin Budgeting Distributions

Approved Budgets – Schools Begin Requesting/Obligating Services or Assistance
June 3 2022 Initial Budget Workbook Submission Deadline (to receive summer services)
August 15 – September 30 2022 Workbook Submission Deadline

Due Date for Obligation of Service/Assistance
September 20 2023 GEER II Supplemental/Gap Services and Assistance Period Ends
September 30 2024 ARP EANS Services and Assistance Period Ends

 

Final Allocations and Distribution of Services and Assistance

The 2022 Emergency Relief to Non-Public Schools Allocations provides reference to the level of services and assistance for each school.

In partnership with FACTS Education Solutions, a third-party vendor, will provide fiscal agent services and spenddown reports; technology and training to facilitate budgeting and requesting services; and provide/contract for the distribution of services and assistance. FACTS Education Solutions will directly contact non-public schools, starting with the application process.

NDE Guidance and FAQ

The following guidance is also available:

Commissioner’s Message: 2022 Emergency Assistance to Non-Public Schools (03/17/2022)

2022 Emergency Assistance for Non-Public Schools Application – unique link provided to each school administrator (03/22/2022)

Refer to the ARP EANS Program Overview for answers to common questions (3/18/2022)

The Facts Sheet provides a side-by-side comparison of the ARP EANS and GEER II assistance programs (03/22/2022)

The Allowable Activities Guidance highlights allowable and reimbursable activities by program and category (5/4/2022)

Determining Low Income Student Counts (04/06/2022)

Statewide training: ARP EANS Program Overview Webinar Recording (PDF) (03/22/2022)

ARP EANS/GEER Presentation

ARP EANS/GEER Next Steps

 

ARP EANS Federal Guidance

The United States Department of Education published an FAQ on the EANS grant programs, which is linked to the Office of Elementary and Secondary Education’s main EANS webpage. The FAQ addresses issues related to eligibility (Section C) and allowable services and assistance (Section D).

Further ARP EANS questions? Contact us at:

For program, eligibility, application, allowable services, and student data questions, please contact the Nebraska Department of Education:

Jim Kent
Nebraska Non-public School Ombudsman
Jim.Kent@nebraska.gov

For budget workbook, requesting services and assistance, or spenddown report questions, please contact FACTS Education Solutions:

Elizabeth Shelton & Sarah Noble
EANSfunds@factsmgt.com

Updated September 13, 2022 3:35pm