What is the American Recovery Plan Act (ARPA)?
This is a recovery plan signed into law on March 11, 2021, by President Joe Biden. The plan includes $1.9 trillion in funding designed to go toward:
- Vaccination efforts
- COVID-19 testing
- State and local governments
- Stimulus checks
- Unemployment assistance extension
- Rental assistance
- Small business recovery
How much ARPA funding is dedicated to education?
In this plan, there are three main allocation for K12 education:
- $122 billion is allocated to the Elementary and Secondary School Emergency Relief Fund (ESSER), the third and largest allocation of ESSER funds
- $2.6 billion additional for IDEA, Part B
- Another round of $2.75 billion toward Emergency Assistance for Nonpublic Schools (EANS)
All told, from March 2020 through ARPA, this amounts to an unprecedented sum of over $6 billion of funding for nonpublic schools.
What are the details surrounding the second round of EANS funding (EANS II)?
The same framework applies as EANS I, with a couple of noteworthy exceptions:
- It is explicitly noted that this funding is “to provide services or assistance to nonpublic schools that enroll a significant percentage of low-income students and are most impacted by the qualifying emergency.”
- Funds are not to be used to provide reimbursements to any nonpublic school.
Which schools are eligible?
Private schools are eligible under the following guidelines:
- Not for profit
- Accredited, licensed, or otherwise in accordance with state law
- Was in existence prior to March 13, 2020
- Did not, and will not, apply for and receive a Payroll Protection Program (PPP) loan on or after December 27, 2020 (the second round of PPP funding)
- Faith-based schools are eligible
What’s involved in the ARP EANS application process?
We are waiting to see whether the U.S. Department of Education (DoED) will simply release to states this second round of EANS funding or whether it will require Governors to apply again. Once states receive ARP EANS / EANS II, they are likely to make a second application available to schools, though it is conceivable that some states may just double the EANS allocation of every school that was awarded CRRSA EANS / EANS I. Just as with CRRSA EANS / EANS I, applications for individual schools will need to be submitted either by the schools themselves or by organizations with governing authority over a group of schools (e.g., an Archdiocese) on behalf of all member schools.
Applications must be made available to private schools as soon as possible, but no later than 30 days after the state receives the funds.
When will the second round of EANS funds be available?
A date has not yet been determined. We’re awaiting information from the DoED.
Will the Tydings Amendment allow schools to extend the eligibility to spend the second round of EANS funding until September 30, 2024?
States will have to apply or request the Tydings Amendment extension; in most cases, approval is granted.
Will schools have had to apply for EANS I in order to apply for EANS II?
This may vary state to state.
It is expected that DoED will provide further clarity and guidance in the coming days and weeks.
Does receiving PPP I and/or PPP II funds make my school ineligible for funding?
Receiving Paycheck Protection Program (PPP) funds prior to December 27, 2020 does not make your school ineligible—you’re still eligible if you accepted the first round of PPP.
If you accepted a PPP loan after December 27, 2020, you are not eligible for the first round of EANS funding, and it’s assumed that your school would not be eligible for the second round of EANS funding either. We are currently waiting on DoED guidance regarding this matter.
Is there any risk of this funding being walked back like ESSER I funds were?
As of now, there does not seem to be a real risk of that. This money is being kept at the state level and is earmarked for nonpublic schools, so it’s clear how these funds will be allocated.