• Distributing information about EANS promptly to nonpublic schools
  • Creating an application
  • Establishing poverty criteria from generally available sources of poverty data
  • Establishing the information a nonpublic school must provide to enable the SEA to prioritize schools most impacted by COVID 19
  • Ensuring nonpublic schools provide enrollment of students from low-income families and a description of the emergency services requested from the SEA
  • Making an application easily available to nonpublic schools as soon as possible but no later than 30 days after receipt of EANS funds
  • Approving/denying each application promptly but no later than 30 days after receipt
  • Determining what services or assistance the SEA will provide directly through LEAs, other public entities, or contractors
  • Ensuring control of funds and title to materials, equipment, and property are in a public agency
  • Ensuring all services or assistance provided is limited to secular, neutral, and nonideological purposes
  • Obligating all funds in an expedited and timely manner and not later than 6 months after receiving the funds

What does it mean that funds must be “obligated within 6 months?”

EANS I requires that funds be obligated within 6 months and spent no later than September 30, 2022, with an additional year available if requested by the state (meaning funds can be spent until September 30, 2023). EANS II also requires that funds be obligated within 6 months; they must be spent no later than September 30, 2023, with an additional year available if requested by the state (allowing spending until September 30, 2024).

Obligation of the funds occurs in different ways. If the state or other government entity is providing services (such as direct services to students or professional development to teachers), the funds are obligated when the service is performed. If the state or government entity is entering into a written agreement for services to be delivered at a future date, the obligation occurs when the agreement is made. Many states are entering into written agreements with a third-party entity to administer the program—thereby obligating the funds—and this third party then contracts with service providers to deliver the services.

What happens if the funds are not obligated within 6 months?

If the EANS I or II funds are not obligated within the required 6-month time period, these funds move to the GEER program. The Governor is encouraged (but not required) to use the former EANS funds that are moved to the GEER program for their original purposes.