Tales from the Field: Allowable Use of Funding for the Summer

In this scenario, we will learn about the kind of funding that can be used for summer programming for MV Eligible students.

The Tale:

A district liaison has called the NYS TEACHS helpline. This is their first school year in the role as a McKinney Vento liaison. Being that they have not experienced the end of the school year as a liaison they are wondering if they can use funds to support McKinney Vento students now and over the summer. The DL called regarding a family that has been in a shelter since November after losing their home due to economic hardship. The school that the student attends is an elementary school within the district. Mom has shared that she received a letter from the teacher regarding the end-of-year picnic, that letter also states that students are to provide $10 each to cover the cost of the picnic by the stated deadline. Mom also shared that there was a list of suggested items to bring to the picnic such as a bathing suit for water play and a towel. Mom has shared that she is currently not able to provide those materials and the required fee for the end-of-year picnic. Additionally, the mom has shared that she is planning on picking up more shifts at work and is wondering if there are any summer programs available for her child. The district liaison has called the helpline inquiring about Title I funds and other funds that could be used in this scenario. Is this situation an allowable expense? Are summer programs also an allowable expense?

Resources:

• Allowable and Strategic Uses of American Rescue Plan- Homeless Children and Youth (ARP-HCY) Funds 

• Allowable Uses of ARP-HCY Funds - Two Page Reference

• TITLE I, Part A: Homeless Set-aside Guidance on Allowable and Unallowable Expenditures

• Consolidated Appropriations Act, 2014 and Expansion of Allowable Use of Title I Part A and Set-aside Funds for Students in Temporary Housing (Homeless)

• Local Homeless Education Liaisons: Understanding Their Role

• McKinney-Vento Summer School Information

Questions to consider:

1. Can the district liaison provide the mom with funds to purchase a bathing suit and towel for the child to participate in the end-of-year picnic?

2. The liaison is not familiar with ARP-HCY Funds but has some knowledge of Title I funds, can Title I funds be used in this scenario?

3. The parent in the scenario above shared that there is a fee for the end-of-year picnic, how can the district liaison assist that family if they are not able to pay that fee?

4. How can the liaison assist the parent regarding summer programs? What is the guidance on summer school?

Question 1: Can the district liaison provide the mom with funds to purchase a bathing suit and towel for the child to participate in the end-of-year picnic?

It is important to ensure that McKinney Vento students are able to participate in all activities. As the school year comes to an end, many schools/classrooms plan for their end-of-year celebrations. Ensuring participation allows for students to continue to feel welcomed and seen. Additionally, it allows for the development of social skills, increases confidence, and overall social-emotional development.

The district liaison can work with the parent to purchase a bathing suit and other items the child may need. Additionally, they can also Provide store cards/prepaid debit cards to purchase materials necessary for students to participate fully in school activities (Allowable Uses of ARP-HCY Funds - Two Page Reference).

American Rescue Plan - Homeless Children and Youth Funds (ARP-HCY) funds are uniquely flexible funds dedicated to supporting the identification, enrollment, and school participation of children and youth experiencing homelessness, including through wrap-around services. Eligible uses of funds include “any expenses necessary to facilitate the identification, enrollment, retention, or educational success of homeless children and youth to enable homeless children and youth to attend school and participate fully in school activities.

Please see the language below on Prepaid Debit and Store Cards using ARP-HCY Funds-

Can ARP-HCY funds be used to purchase prepaid debit and store cards?

Yes. ED’s Dear Colleague Letter specifically names as allowable “store cards and prepaid debit cards to purchase materials necessary for students to participate fully in school activities.” Debit and store cards are a streamlined way to provide clothing, school supplies, hygiene items, and other needs to children and youth. These cards eliminate the need for liaisons to shop for specific sizes and needs or find a place to store supplies. Liaisons should check with their State Coordinator and LEA business office regarding the purchase of prepaid cards and any necessary tracking to mitigate waste and abuse. For example, some LEAs purchase cards that cannot be used for alcohol and tobacco, and require parents or youth to sign for cards when received.

As with all ARP-HCY funds, it is recommended that the LEA first use community resources to meet these needs, if such resources are reasonably available. (Allowable and Strategic Uses of American Rescue Plan- Homeless Children and Youth (ARP-HCY) Funds)

Question 2: The liaison is not familiar with ARP-HCY Funds but has some knowledge of Title I funds, can Title I funds be used in this scenario?

Title I funds may be used in this scenario to support the student and aid their participation in school activities to continue to enhance and nurture their social-emotional development. Though Title I funds may be used, it is also strongly encouraged to work with the school PTA and other local sources to see if any funds are available for this specific event. School PTAs are a great start, there may be additional funds to support students who may not be able to have access to materials needed to participate in these end-of-year activities.

Please see below on Title I Funds -

When considering using Title I funds there are two guiding principles:

●      Are the services reasonable and necessary? 

●      Are there other fund sources available?

Two principles govern the use of Title I, Part A funds to provide services to homeless students. First, the services must be reasonable and necessary to assist homeless students in taking advantage of educational opportunities. Educational opportunities are activities that can support both the academic and social-emotional development of the student.

Second, Title I, Part A funds must be used only as a last resort when funds or services are not available from other public or private sources, such as public health clinics, or local discretionary funds (sometimes provided by the PTA) used to provide similar services for economically disadvantaged students. These services may not ordinarily be provided to other Title I students but may be provided to help homeless students effectively take advantage of educational opportunities.

NYSED has provided a guidance document on allowable expenditures using Title I funds.

Question 3: The parent in the scenario above shared that there is a fee for the end-of-year picnic, how can the district liaison assist that family if they are not able to pay that fee?

The district liaison can connect with additional school support staff if they are not an in-school support such as a counselor, social worker, school psychologist, etc. The housing status of McKinney Vento families is confidential and should be shared on a need-to-know basis. Connecting with the right support staff is beneficial to ensure that students can participate in all school activities. The liaison may be able to connect with the teacher if appropriate to waive the fee. Additionally, as previously stated there may be additional funds through the school PTA that could cover the fee. Overall, the student should not be excluded from the end-of-year picnic due to lack of payment or monetary contribution.

Question 4: How can the liaison assist the parent regarding summer programs? What is the guidance on summer school?

The liaison can assist the parent by connecting them with any summer programs in the community. There may be community-based organizations or local organizations such as the YMCA that offer summer programs at a free or reduced cost. Additionally, many programs offer financial assistance for families. The local liaison must have the ability to develop and maintain collaborative relationships with community agencies to ensure that McKinney-Vento students are linked to services that are beyond what the school or district provides (Local Homeless Education Liaisons: Understanding Their Role).

Please see below on the guidance on summer school -

Students in temporary housing have important rights related to summer school. The federal law makes clear that LEAs “must ensure that homeless children and youths who meet the relevant eligibility criteria do not face barriers to accessing academic and extracurricular activities, including… summer school.”[2] If your LEA does not offer a summer school program, but resident students can attend summer school offered by a neighboring LEA for a fee, students in temporary housing must be afforded this same opportunity, and they must not be charged the fee. Instead, your LEA will be asked to cover the summer school fee for such students. Title I, Part A set-aside, Elementary and Secondary School Emergency Relief (ESSER), Governor’s Emergency Education Relief (GEER) funds, and American Rescue Plan Homeless Children and Youth (ARP-HCY) Part I and Part II funds may be used to pay for any fee associated with summer school.

To the extent that an LEA has a summer school policy that limits participation based on a student’s attendance during the regular school year, the LEA must revise such policy to make an exception for students experiencing homelessness. The McKinney-Vento Act requires that LEAs “develop, review and revise, policies to remove…barriers to enrollment and retention due to outstanding fees or fines, or absences.”[3]

If an LEA recommends that a student who is homeless participate in summer school and/or LEA-sponsored summer programming and the student can’t participate without transportation, the district where the student is enrolled is responsible for arranging transportation.[4]

McKinney-Vento Summer School Information