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Funding & How to Effectively Provide Services to Students Experiencing Homelessness

Wichita, Kansas

July 26, 2023

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Session Outline

Setting the Stage: Definition of Homelessness & Removing barriers and providing services to MV students
Section 1: Funding sources and their purposes
Section 2: Effective and allowable use of grant funds
Section 3: Establishing a workable plan for a sustainable future

Annual Liaison Training| 2

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McKinney-Vento Definition of Homelessness

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Who is Considered Homeless?

McKinney-Vento (MV) Definition

- Children or youth who lack a fixed, regular, and adequate nighttime residence

Fixed – stationary, permanent, not subject to change
Regular – used on a predictable, routine, or consistent basis (e.g., nightly)
Adequate – lawfully and reasonably sufficient to meet physical and psychological needs typically met in a home environment

42 U.S.C. § 11434a(2)

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Examples of Living Situations

The definition continues with examples of circumstances considered to be homeless:

Sharing the housing of other persons due to the loss of housing, economic hardship, or a similar reason
Living in motels, hotels, trailer parks, or campgrounds due to the lack of alternative adequate accommodations

42 U.S.C. § 11434a(2)

The definition continues with examples of circumstances considered to be homeless: (focus on the highlighted wording)

- Sharing the housing of other persons due to the loss of housing, economic hardship, or a similar reason;

- Living in motels, hotels, trailer parks, or campgrounds due to the lack of alternative adequate accommodations;

- Living in emergency or transitional shelters;

- Abandoned in hospitals;

- Living in a public or private space not designed for or ordinarily used as a regular sleeping accommodation for human beings;

- Living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings;

- Children of migratory agricultural workers (including migratory dairy workers or fishers) – living in qualifying circumstances; and

- Unaccompanied youth - living in qualifying circumstances.

NOTE: It’s important to remember that not all people sharing housing or living in motels, hotels, trailer parks, or campgrounds are considered homeless. Only those living in the conditions specified in the definition are considered homeless.

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Examples of Living Situations – Cont.

Living in emergency or transitional shelters
Abandoned in hospitals
Living in a public or private space not designed for or ordinarily used as a regular sleeping accommodation for human beings
Living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings

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42 U.S.C. § 11434a(2)

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Examples of Living Situations – Cont.

Children of migratory agricultural workers (including migratory dairy workers or fishers) – living in qualifying circumstances
Unaccompanied youth - living in qualifying circumstances

42 U.S.C. § 11434a(2)

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Unaccompanied Homeless Youth (UHY) Definition

Student’s living arrangement must meet the definition of homeless, AND
Student must be considered unaccompanied, defined as “not in the physical custody of a parent or guardian”

Homeless

Not in Physical Custody

UHY

See NCHE’s Unaccompanied Youth Eligibility Flowchart �https://nche.ed.gov/wp-content/uploads/2018/10/app-9a.doc

(42 U.S.C. § 11434a(6))

We always get questions about unaccompanied homeless youth here at NCHE, so let’s go a little bit deeper into some of them called out in the law.

It’s important to note that:

Not all unaccompanied youth are homeless; to be considered an UHY, the youth must be living in an eligible living situation (remember, fixed, regular and adequate) and also is NOT in the physical custody of a parent or guardian. NCHE has a flowchart on our website to help schools determine if a student is an UHY.
There are no age limits in the McKinney-Vento Act (UHY will “age out” with state law, attendance, age provisions, or IDEA) (Individuals with Disabilities Education Act) rules.
Eligibility is based on the student’s housing (a student could be considered an UHY even if the parents say they are willing to provide students with a home).

UHY have some unique needs and may require additional support from liaisons. When a student is an UHY, we have an obligation to help with enrollment and school selection.

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Removing Barriers & Providing Services to Students

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Goal of Education of Homeless Children and Youth (EHCY) Program = Stability & Access

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“Full Participation in Education”

Comparable Services �(available to ALL students)

Removing Barriers�(available to SOME students)

Example: Transportation back to School of Origin

Example: Transportation to “Fully Participate”

Allowing for full participation by a student is a key component of the MV/EHCY program. We often think of the picture on the left when we think of equity, but what if we stretched this further, broke down the fence, and invited all students to “play the game”? To do this for our students experiencing homelessness, I think two terms are important to think about.

1 - “Comparable Services” – those things that are available to all students, and

2 - What can we do to “Remove Barriers” for some students with specific needs?

When we think about comparable services – this would include:

Immediate enrollment
Transportation to the school of origin
Child Nutrition programs – breakfast/lunch
Any other program for which a student qualifies

Title IA interventions
Special Education
English Language Acquisition
Migrant
Gifted/Talented
Others

When I think about “Removing Barriers,” I think about ways we can help students participate in

Extra-curricular/Afterschool activities, including paying for fees or additional transportation that may be needed
Course fees – such as band instrument rentals or materials needed for College Technical Education/CTE courses
Wrap-around Services – students may need additional

Nutrition support
Clothing
Hygiene/Laundry products or services
Mental, medical, and dental health referrals
Navigation to other social service providers

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McKinney-Vento (MV) Requirements for All LEAs

Local Liaison
Identification
Enrollment & Records
School Stability
Resolve Disputes
Privacy
Comparable Services
Remove Barriers to Full-Participation
Coordination of Services

NCHE Local Liaison Toolkit – Chapter 2

These are the “gotta do’s” related to the MV Act.

Every LEA (regardless of if they receive federal program funding, i.e., Title I-A, etc.) must have someone named as a local liaison. This person must have the time and training to fulfill the ten specific responsibilities listed in the law and meet the reporting requirements.

Section 2.1.1 of the McKinney-Vento Act provides several LEA requirements for serving homeless children and youths [42 U.S.C. § 11432(g)(3)].

The tasks outlined in the law are summarized below.

In general, LEAs must:

continue a homeless child’s or youth’s education in the school of origin for the duration of homelessness and for the remainder of the academic year if the child or youth becomes permanently housed during an academic year; or
enroll the homeless child or youth in any public school where non-homeless students who live in the attendance area in which the child or youth is actually living are eligible to attend [42 U.S.C. § 11432(g)(3)(A)].

School stability provisions require LEAs to:

presume that keeping the child or youth in the school of origin is in the child’s or youth’s best interest, except when doing so is contrary to the request of the child’s or youth’s parent or guardian or (in the case of an unaccompanied homeless youth) the youth;
consider student-centered factors related to the child’s or youth’s best interest, including factors related to the impact of mobility on achievement, education, health, and safety of homeless children and youths, giving priority to the request of the child’s or youth’s parent or guardian or (in the case of an unaccompanied homeless youth) the youth;
provide a written explanation of the reasons for the LEA’s decision, including information regarding the right to appeal, to the parent or guardian of a homeless student or to an unaccompanied homeless youth if the LEA determines it is not in the best interest of the child to attend the school requested; and
ensure, in the case of an unaccompanied homeless youth, that the local liaison assists in placement or enrollment decisions, gives priority to the views of the youth, and provides notice of the right to appeal an LEA’s best interest determination that is contrary to the youth’s request [42 U.S.C. § 11432(g)(3)(B)].

Regarding enrollment and records, the enrolling school must

immediately enroll the child or youth, even without records that are normally required for enrollment or if the child or youth has missed application or enrollment deadlines during any period of homelessness;
contact the school last attended for relevant records;
assist with obtaining immunizations or other required health records; and
make any records ordinarily kept by the school available in a timely fashion when the child or youth enrolls in a new school or LEA [42 U.S.C. § 11432(g)(3)(C)-(D)].

If a dispute arises over eligibility, school selection, or enrollment in a school:

the child or youth must be immediately enrolled in the school in which enrollment is sought, pending final resolution of the dispute, including all available appeals;
the parent or guardian of the child or youth or (in the case of an unaccompanied youth) the youth must be provided with a written explanation of any decisions related to eligibility, school selection, or enrollment made by the school, LEA, or State educational agency (SEA), including the rights to appeal the decision;
the parent, guardian, or unaccompanied youth must be referred to the local liaison to carry out the dispute resolution process; and
in the case of an unaccompanied youth, the local liaison must ensure that the youth is immediately enrolled in the school in which the youth seeks enrollment pending resolution of the dispute [42 U.S.C. § 11432(g)(3)(E)].

Privacy provisions require LEAs to:

treat information about a homeless child’s or youth’s living situation as a student education record and not deem it to be directory information [42 U.S.C. § 11432(g)(3)(G)].

Comparable services provisions require LEAs to:

provide services comparable to those offered to other students in the school [42 U.S.C. § 11432(g)(4)].

Coordination provisions require LEAs to:

coordinate with local social services agencies and other agencies or entities providing services to homeless children and youths and their families, including services and programs funded under the Runaway and Homeless Youth Act [42 U.S.C. § 11432(g)(5)(A)(i)].

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Funding Sources and Their Purposes

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How Federal Grant Funding Works

Determine Needs

Create Plan

Develop

Budget

Provide Services

Seek Reimbursement

Report

Here’s a flowchart of how federal grant funding works.

1^st – You need to determine your need:

Develop project purposes/goals/success criteria

Consider all funding sources

2^nd – Here’s where you create your plan and develop a budget:

Determine essential elements, timeline, and budget for “The Plan.”

Consider personnel, partners, and capacity

Read the” Award Notification” letter carefully to understand the assurances and timelines

Establish grant account/budget

Establish processes for accessing/using funds

Establish the process of reimbursement from the State Dept of Ed.

Establish a process for record-keeping and data collection.

Next – The is where you “work you plan” and provide services & then seek reimbursement for costs associated with that:

Execute “The Plan”

Finally – There is always some reporting requirement:

Compile and analyze data

Complete reports and evaluations in a timely manner

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Federal Funding Sources for Homeless Education Programs

Title IA Homeless Set-Aside	ECHY/Homeless Subgrant	American Rescue Plan –Homeless Children & Youth (ARP-HCY) I & II Subgrants
2022-23 All LEAs receiving Title IA $ Multiple ways of determining the homeless set-aside.	2021-2024 3-year cycle 11 to 12 grants ($208,537 state administrative set-aside)	ARP-HCY I – $1,020,145 12 LEAs ($340,049 state set-aside) ��ARP-HCY II – $4,083,208�286 LEAs (no state set-aside)
$556,583	$625,611	$5,103,353

This chart shows the amount that is available to LEAs to support students experiencing homeless by grant type.

This year LEAs collectively set aside $556,583 from Title I-A funds to help support MV programming in their districts/charter schools. Every LEA in the state that receives a Title I-A allocation must set aside an amount to help meet the needs of MV students. Only a few LEAs set aside more than the “minimum” amount.

In addition to these funds set-aside, 12 LEAs split $625,611 of Homeless Education subgrant funds. This is the last year of this grant cycle and any LEA who is interested in receiving additional funds may apply for this 3-year competitive grant.

The ARP-HCY funds totaled a little over $5.4 million going to LEAs between the ARP-HCY I competitive and ARP-HCY II formula grants. Kansas sent all its ARP-HCY II funds out to LEAs and covered statewide activities with a 25% state administrative set aside from the ARP-HCY I funds. These funds were used to hire an additional staff member for the MV program team.

This meant that LEAs across the state had an additional $5.1 million to use to enhance their EHCY programs, to increase identification, and to support students experiencing homelessness. This is 5 times the amount that is normally allocated to support HCY. This is a good time to look for ways to consider sustainability in the systems/programming created using ARP-HCY funds. How will you be able to continue the quality of services to students when these funds are no longer available? You may need to increase the Title I-A homeless set-asides.

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Other Funding Sources

“Angel” Funds

Foundations, Donations, Community-Based Organizations, Etc.

Runaway Homeless Youth Programs

Bloom House Youth Services, Inc. (Emporia)

Basic Center Program

Wichita Children’s Home (Wichita)

Maternity Group Home Program
Transitional Living Program
Street Outreach Program

Angel Funds are a way for LEAs to leverage the generosity of their communities. Sometimes these are done through an education foundation. These funds can be utilized in ways that the other grant funding sources may NOT cover or be allowable. The district or charter can determine its own criteria for using these. It’s a good idea to figure out a process to accept and track both monetary and other types of donations. This can be an important part of determining your needs related to your Title I-A homeless set aside.

Other funds or services may be available through partners receiving Runaway Homeless Youth grants. Sometimes they are able to help cover transportation costs – if it is written in their grants. Here are the grantees in Kansas who received funding and may make great partners with the schools in supporting students experiencing homelessness.

It is so important to know and understand your local resources as you strive to meet the needs of students and remove barriers for them to fully-participate in school.

Basic Center Program

Grant Period 2021 — 2024

Bloom House Youth Services, Inc (New RHY awardee)�Emporia, KS�Phone: (918) 457-9286�www.bloomhouseks.org/

Maternity Group Home Program

Grant Period 2021 — 2024

Wichita Children's Home�Wichita, KS�Phone: (316) 684-6581�www.wch.org

Transitional Living Program

Grant Period 2022 — 2025

Wichita Children's Home�Wichita, KS�Phone: (316) 684-6581�www.wch.org

Street Outreach Program

Grant Period 2022 — 2025

Wichita Children's Home�Wichita, KS�Phone: (316) 684-6581�www.wch.org

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Purpose of Title I-A

Purpose: The purpose of Title I-A is to provide all children with a significant opportunity to receive a fair, equitable, and high-quality education and to close educational achievement gaps. Title I-A provides supplemental funding to help low-income children served to meet the challenging State academic standards.

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Purpose of EHCY/Homeless Subgrant

Purpose: This grant provides funds to districts/charters to be used to establish educational programs and/or services that meet the purpose of the McKinney-Vento (MV) Act to promote the enrollment, attendance, and success of homeless children and youth in school and preschool.

Services provided with McKinney-Vento Act funds may not replace the regular academic program. They must be designed to expand upon or improve services provided as part of the school’s regular academic program.

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Purpose of ARP-HCY I and II

New American Rescue Plan funding to support students experiencing homelessness has tremendous potential to expand the systems in your State to identify and support the needs of homeless children and youth.

The purposes of the ARP-HCY Fund are to help States and local educational agencies (LEAs) identify homeless children and youth, provide wraparound services that address the multiple effects of the COVID-19 pandemic on homeless children and youth, and ensure that homeless children and youth are able to attend school and participate fully in school activities.
As a result of the COVID-19 pandemic, students experiencing homelessness are increasingly under-identified, as learning outside of school building settings likely impeded the critical role of educators and staff in schools and LEAs to identify students properly, and these students have remained underserved by schools, LEAs, and States.

There are two major themes in the purposes of ARP-HCY I and II funding.

The first is expanding systems and improving identification, especially in the area of advancing racial equity and support for underserved communities. Specifically, we should consider Black, Latino, Indigenous and Native American persons, Asian Americans and Pacific Islanders and other persons of color; members of religious minorities; persons identifying as LBGTQI+; persons with disabilities; persons who live in rural areas; and persons otherwise adversely affected by persistent poverty or inequality.

The second is meeting the needs of the “whole” child through wraparound services. This emphasis has helped schools connect to community-based organizations to create partnerships and expand the support provided to HCY so they can fully participate in their schooling – not only if it is held in a traditional sense but also if it is in a virtual setting.

.

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Important Dates – ARP-HCY I and II

Last day to Obligate – Sept. 30, 2024
Last day to Draw Down – Dec. 29, 2024

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Effective & �Allowable Use of Funds

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Allowable Uses for Title I-A Homeless Set-Aside

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.

• 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 or local education foundation) used to provide similar services for economically disadvantaged students.

(ESEA section 1113(c)(3)(C)(ii)) �EHCY Non-Regulatory Guidance, pg. 38-39

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Title I-A Homeless Set-Aside – Cont’d

Examples of Allowable Expenditures*

Clothing/shoes necessary for participation in classes
Student fees necessary to participate in general education program
Personal school supplies
Acquisition of birth certificates
Immunizations
Food
Medical & dental services
Eyeglasses & hearing aids

*BUT not limited to these

Counseling services
Extended learning time
Extra-curricular activity fees
Tutoring services
Parental involvement activities
Fund all of part of the homeless liaison’s salary
Excess cost of transporting students to and from their school of origin

(ESEA section 1113(c)(3)(C)(ii)) �EHCY Non-Regulatory Guidance, pg. 38-39

To help homeless students effectively take advantage of educational opportunities, an LEA may use Title I, Part A funds to provide, where appropriate, items or services including, but not limited to, the examples listed here.

Title I, Part A funds may be used to provide services to homeless children and youths, including those in Title I schools that may not ordinarily be provided to other Title I students. (ESEA section 1113(c)(3)(C)(ii)). For example, to help homeless students effectively take advantage of educational opportunities, an LEA may use Title I, Part A funds to provide, where appropriate, items or services including, but not limited to—

Please note that Title IA funds may not, however, be used to pay for transportation expenses that are reimbursed by State funds.

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Authorized Uses for McKinney-Vento Subgrant Funds

Provide tutoring, supplemental instruction, and enriched educational services
Expedite evaluations of the strengths and needs of HCY, including for eligibility for special programs and services (IDEA, Gifted & Talented, EL, etc.
Provide professional development to heighten the understanding and sensitivity to the needs of HCY
Provide referral services of HCY for medical, dental, mental, and other health services
Defray to excess cost of transportation for students
Provide early childhood education program, not otherwise provided through other funding
Provide services and assistance to attract, engage, and retain HCY, particularly youth who are not in school
Provide HCY before- and after-school, mentoring, summer programs, tutoring, homework assistance and supervision of educational activities by qualified individuals

Payment of fees and other costs associated with tracking, obtaining, and transferring records necessary to enroll HCY in school (birth certificates, immunization, health records, academic records, guardianship records, and evaluations for special programs or services)
Provide training to parents/guardians of HCY about the rights of, and the resources available to HCY and other activities designed to increase meaningful involvement
Development of coordination between school and agencies providing services to HCY
Provide specialized instructional support service (including violence prevention counseling) and referral for services
Activities to address the needs of HCY due to domestic violence and parental mental health of substance abuse
Adaptation of space and purchase of supplies for non-school facilities to provide services to HCY
Provide school supplies
Provide other extraordinary or emergency assistance needed to enable HCY to attend school and �participate fully in school activities

42 U.S.C. 11433, SEC. 723(d)(1-16)

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ARP-HCY I and ARP-HCY II Authorized Activities

In addition to the 16 McKinney-Vento authorized activities, LEAS can use ARP-HCY funds to

provide wraparound services (which could be provided in collaboration with and/or through contracts with CBOs, and could include academic supports, trauma-informed care, social-emotional support, and mental health services);
provide needed supplies (e.g., eyeglasses, school supplies, personal care items);
provide transportation to enable children and youth to attend classes and participate fully in school activities;
purchase cell phones or other technological devices for unaccompanied youth to enable the youth to attend and fully participate in school activities;
provide access to reliable, high-speed internet for students through the purchase of internet-connected devices/equipment, mobile hotspots, wireless service plans, or installation of Community Wi-Fi Hotspots (e.g., at homeless shelters), especially in underserved communities;
Pay for short-term, temporary housing (e.g., a few (3) days in a motel) when such emergency housing is the only reasonable option for COVID-safe temporary housing and when necessary to enable the homeless child or youth to attend school and participate fully in school activities (including summer school); and,
provide store cards/prepaid debit cards to purchase materials necessary for students to participate in �school activities.

Letter to Chief State School Officers, 4.23.21

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NCHE Allowable Funds Tip Sheet

https://nche.ed.gov/wp-content/uploads/2022/10/use-of-funds-tip-sheet.pdf

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Is the expenditure allowable?

Decision Point 1:

Other LEA or community resources are not available to meet the need

YES

Decision Point 2:

Expenditure aligns with the purposes of the statute

YES

Decision Point 3:

Expenditure aligns with the statutorily allowed use of funds

Decision Point 4:

Expenditure aligns with statute’s comparability requirement

YES

Decision Point 5:

Expenditure aligns with the allocability requirement in federal regulations

YES

Decision Point 6:

Expenditure aligns with necessary & reasonable requirements in federal regulations

YES

Allowable Expenditure

This graphic appears in NCHE’s just released or forthcoming ARP-HCY Use of Funds Tip Sheet. We’ll go over the steps in each of the next slides. We’re going over this with you to align our thinking, help you be clear about what’s not allowable or preferable and understand when or why ED may allow something that an SEA or LEA chooses not to in order to mitigate the risk of fraud, waste and abuse. There is a lot of discretion and “it depends” in thinking through any allowable use of funds question. That’s why there isn’t an extensive list of always allowable activities or purchases with EHCY and ARP-HCY funds.

Decision Point 1: Other LEA or community resources are not available to meet the need the proposed expenditure addresses.

Tips:

Become familiar with all LEA programs that could assist HCY. ARP nor EHCY subgrants should be used when activities or services can be provided through other LEA programs or funding.

Ask:

What existing SEA and LEA services and programs are available to meet the needs?
Are community resources available and better able to meet the targeted needs or achieve the desired outcomes?

First, you must exhaust all LEA and community resources before spending federal funds – and that includes ARP funding. You’ll need to become familiar with state and local programs that are serving HCY so you’ll know what services and programs they provide.

In addition, schools and LEAs should make referrals to service agencies and community partners who are providing services beyond the scope or capacity of schools and LEAs.

Decision Point 2: Proposed expenditure aligns with the purposes of the authorizing statute(s).

Tip:

Familiarize yourself with the purposes of the statute(s).

Ask 1: Is the proposed use of funds aligned with the purposes of the McKinney-Vento Act? Does it

ensure HCY have equal access to the same free, appropriate public education as other students;
remove barriers to the identification of, or the enrollment, attendance, or success in school of HCY;
ensure HCY are not separated from the mainstream school environment; and
enable them to have access to the education and other services that they need to meet the same challenging state standards to which all students are held (42 U.S.C. § 11431).

#2 is whether the expenditure aligns with the purposes of the laws.

First, you’ll need to look at the purposes of MV:

ensure HCY have equal access to the same free, appropriate public education as other students;
remove barriers to the identification, enrollment, attendance, and success in school;
ensure HCY are not separated from the mainstream school environment (remember that stigmatization is specifically prohibited in the MVA; and
ensure HCY have access to the education and other services they need to meet the same standards for all students.

Ask 2: Is the proposed use of funds aligned with the purposes of the American Rescue Plan Act?

Does it support HCY through

identification;

school engagement; and/or

provision of wrap-around services?

LEAs can support these students in school and in partnership with CBOs that are well-positioned to identify and connect students to educationally related supports and wraparound services

ED encourages an intentional focus on historically underserved student populations

2b is determining whether the proposed expenditure aligns with the purposes of ARP, which include identification, school engagement, and wraparound services.

LEAs can partner with community-based orgs (CBOs) to connect students to supports and wraparound services.

Remember that ED encourages a focus on historically underserved student populations:

Rural

Tribal

Students of color

English Learners

Students with disabilities

LGBTQ+

Pregnant, parenting, and/or caregiving students

Decision Point 3: Proposed expenditure aligns with the statutorily allowed use of funds.

Tip:

Familiarize yourself with the McKinney-Vento allowed use of funds

Ask: Is the proposed use of funds aligned with one of the 16 authorized activities in the McKinney-Vento Act (42 U.S.C. § 11433(d)(1-16))? �https://nche.ed.gov/mv-auth-activities/

For #3, does the expense not only align with the purposes of the laws, but does it align with the allowed use of funds stated in the laws?

Know those 16 authorized activities in the MVA. There’s a link to them on our website.

Familiarize yourself with the ARP allowed use of funds

Ask: Is the proposed use of funds

one of the McKinney-Vento 16 authorized activities

Wraparound services (academic, trauma-informed, social-emotional, mental health)

Needed supplies (PPE, eyeglasses, school supplies, personal care items)

Transportation to support school engagement

Communication devices and technology needed for school engagement

Short-term housing as a last resort when needed for school engagement (a few days in a motel)

Prepaid store or debit cards are needed to purchase materials for school engagement

Awarding contracts to CBOs

In addition to those MV 16 authorized activities, ARP expanded the way we can spend funds. Here’s a list:

Wraparound services including academic, trauma-informed, social-emotional, and mental health services

Supplies such as PPE, eyeglasses, school supplies, and personal care items

Transportation to support school engagement

Communication devices and technology for school engagement

Short-term housing as a last resort when needed for school engagement (a few days in a motel) – not more than 2-3 nights

Prepaid store or debit cards needed to buy materials for school engagement, and

Awarding contracts to CBOs

Decision Point 4: The proposed expenditure aligns with the statute’s comparability requirement

Tip:

Consider the comparability requirements in the McKinney-Vento Act. Under the comparability provision, if a service or resource is provided for all students, the cost of providing that service or resource to students experiencing homelessness cannot be paid with subgrant funds.

Ask: Does the school, LEA, or SEA already provide the proposed service or resource to other eligible students?

Decision point 4 is around whether the expenditure aligns with the statute’s comparability requirement. In MV, if an LEA provides a service or resource for all students, they can’t single out homeless students and say instead of providing that service with the same funds, MV funds must be used. The same concept applies with ARP funds. If a district is serving all students, that must include providing MV students with the same services from the same funding.

Decision Point 5:

The proposed expenditure aligns with the allocability requirement in federal regulations.

Tip:

Ensure the cost of the proposed activity is allocable to the program

A cost is allocable if the goods or services are relative to the benefits received. If HCY are participating in a program that already serves other students, subgrant funds should only pay for the fees of the HCY. However, if the program is for at-risk students and HCY are included, subgrant funds cannot be used to pay for their tuition only (2 C.F.R. § 200.405).

McKinney-Vento funds must focus on students who meet the McKinney-Vento definition of homeless and do not include services that benefit only parents or other household members. Parents and other family members may incidentally benefit from an LEA providing funded services for eligible students, such as internet services, bedding, equipment, or food provided to the student.

For #5, you’re looking at whether the expense is allocable based on federal regulations. For example, it’s allocable if it’s relative to the benefits received. If you want to add HCY to a program that already serves other students, subgrant funds can only cover fees of homeless students. But, if the program is set up for a broader category of at-risk students including HCY, subgrant funds can’t be used they’re already being covered as all other students.

McKinney-Vento funds must focus on students who meet the McKinney-Vento definition of homeless. The funds must be focused primarily on the student and cannot benefit only parents or other household members. Parents and other family members can benefit from an LEA providing services to the student. For example, things like internet services, bedding, equipment, or food provided to the student might also benefit other family members. So, the focus is on the student but there may be spillover benefits to the family.

Decision Point 6:

The proposed expenditure aligns with necessary and reasonable requirements in federal regulations.

Tip:

Determine if all costs are necessary and reasonable (Uniform Guidance, 2 C.F.R. § 200.403-404)

Necessary: essential to enable a student or group of students who are experiencing homelessness to attend school and participate fully in school activities

Reasonable: nature and amount does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost

Finally, look at the impact, considering the amount of the expenditure and number of students who would benefit. IOW, look at the cost/benefit ratio of supporting one student to attend an out-of-state debate competition vs. supporting a group of students in a shelter with a supplemental reading program.

Tips for this are based on whether it’s necessary and reasonable. Let’s look at those terms. 1. To be necessary, the expense is essential to enable students to attend school and participate fully in school activities. 2. It’s reasonable if the “nature and amount does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost”. I like to say: does it make good sense? After gathering all the relevant information, is what you want to spend the funds on and the amount you plan to spend the best decision you can make based on the information you have at the time?

This will always be context specific. Some expenditures are reasonable a month before graduation but not at the beginning of the school year. Think about a parenting senior who needs childcare the last few weeks before graduation vs paying for childcare from the start of the school year.

Ultimately, you’ll need to document student needs overall and consider the effectiveness of activities and expenses on all students served by the program. We highly recommend doing a needs assessment and we have both SEA and LEA needs assessments on our website.

Ask: Is the proposed use of funds:

necessary to achieve the goals of the EHCY program,

necessary to enable HCY to attend school and participate fully in school activities, and/or

reasonable, considering the expected impact and the cost in relation to what is spent on other students and activities?

Questions to ask include:

Is it necessary to achieve the goals of the EHCY program?

Is it necessary to enable HCY to attend school and participate fully in school activities?

Is it reasonable, considering the expected impact and the cost relative to what’s spent on other students and activities?

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Activity: Can We Pay For ____?

Is it necessary and reasonable?
Are there other resources (partners or donations) available to cover the expense?
Does the expense align with the purposes of the law?
Does the expense align with the law’s allowed use of funds?
Are other students already provided comparable services?
Is the cost relative to the benefits received?

Is it Allowable?

Which funding source would you use?

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Scenario #1

Keshawn, an UHY, moved in with another family in a neighboring district. After determining it was in his best interest to stay at his school of origin so that he could graduate with his peers. The transportation director from the district where he is now residing says they are not responsible for covering the transportation costs because he is not one of their students.

Is it necessary and reasonable?
Are there other resources (partners or donations) available to cover the expense?
Does the expense align with the purposes of the law?
Does the expense align with the law’s allowed use of funds?
Are other students already provided comparable services?
Is the cost relative to the benefits received?

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Scenario #2

An LEA is looking at renovating space in an old school for a McKinney-Vento/Counseling Center. They want to make it a "homey" place for their students and families by painting walls and ceilings, installing new laminate floor to replace old, smelly carpet, and adding a shower in the bathroom. How would you decide whether to allow this expense?

Is it necessary and reasonable?
Are there other resources (partners or donations) available to cover the expense?
Does the expense align with the purposes of the law?
Does the expense align with the law’s allowed use of funds?
Are other students already provided comparable services?
Is the cost relative to the benefits received?

EHCY/Homeless Subgrant focused scenario -

How would you decide whether to allow this expense?

Grantees and subgrantees are prohibited from using grant funds to purchase real property or to construct new property, unless these activities are “specifically permitted by the authorizing statute or implementing regulations for the program” (see 34 CFR § 76.533). As neither the EHCY nor the ARP-HCY statutes expressly permit the use of program funds for construction, activities would only be allowable to the extent they could be considered minor remodeling rather than construction. Per 34 CFR § 77.1(c):

Minor remodeling means minor alterations in a previously completed building. The term also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building. The term does not include building construction, structural alterations to buildings, building maintenance, or repairs.

Accordingly, to the extent that the project requires any structural alteration, building maintenance, or repairs (as these terms are commonly defined), the LEA may not use EHCY or ARP-HCY funds for these portions of the expenses.

If the activities meet the definition of minor remodeling, the costs would be allowable provided (1) that they meet the purposes of the EHCY or ARP-HCY program and (2) that the costs are reasonable and necessary under the Uniform Guidance (see 2 CFR § 200.404). Factors to consider might include the necessity of the activities (i.e., whether the space would be usable without the changes), the number of students experiencing homelessness that would use the counseling center, the number of years the LEA expects to serve students experiencing homelessness at this counseling center, and the cost required to complete the changes to the counseling center.

Section J of the EHCY Non-regulatory Guidance discusses circumstances in which an LEA must provide transportation to students experiencing homelessness. McKinney-Vento and ARP-HCY funds may potentially be used to cover the cost of this transportation, including the excess cost of school of origin transportation. As with all cost determinations, however, for a purchase to be allowable it must be reasonable and necessary and allocable to the Federal award.

In order to show that this use of funds is reasonable and necessary, at a minimum, the LEA should be able to demonstrate that the purchase of the vehicle or vehicles would be more efficient and cost less overall than other means of transportation available. For example, if the LEA already has a vehicle that it could use to transport students to their school of origin or a less expensive means to transport the students (e.g., leasing a vehicle or using a private vehicle and reimbursing for the cost of transportation), it would not be reasonable and necessary to use ARP-HCY funds to purchase a vehicle or vehicles. If, however, the LEA determines that the cost of a particular vehicle, including related expenses such as fuel and insurance, is less than the cost of alternative means of transportation, the purchase may be considered reasonable and necessary given the circumstances. As noted above, this determination is fact-specific and thus this kind of purchase would need to be considered on a case-by-case basis.

Furthermore, the cost must also be allocable to the Federal program. Accordingly, a vehicle purchased with ARP-HCY funds could only be used to serve students eligible for ARP-HCY services.

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Scenario #3

An LEA wants to purchase a vehicle that would be dedicated to transporting students experiencing homelessness and hire a retired teacher to drive kids to/from school because transportation on school buses is so difficult to arrange.

Is it necessary and reasonable?
Are there other resources (partners or donations) available to cover the expense?
Does the expense align with the purposes of the law?
Does the expense align with the law’s allowed use of funds?
Are other students already provided comparable services?
Is the cost relative to the benefits received?

ARP-HCY focused scenario –

How would you decide?

Section J of the EHCY Non-regulatory Guidance discusses circumstances in which an LEA must provide transportation to students experiencing homelessness. McKinney-Vento and ARP-HCY funds may potentially be used to cover the cost of this transportation, including the excess cost of school of origin transportation. As with all cost determinations, however, for a purchase to be allowable it must be reasonable and necessary and allocable to the Federal award.

In order to show that this use of funds is reasonable and necessary, at a minimum, the LEA should be able to demonstrate that the purchase of the vehicle or vehicles would be more efficient and cost less overall than other means of transportation available. For example, if the LEA already has a vehicle that it could use to transport students to their school of origin or a less expensive means to transport the students (e.g., leasing a vehicle or using a private vehicle and reimbursing for the cost of transportation), it would not be reasonable and necessary to use ARP-HCY funds to purchase a vehicle or vehicles. If, however, the LEA determines that the cost of a particular vehicle, including related expenses such as fuel and insurance, is less than the cost of alternative means of transportation, the purchase may be considered reasonable and necessary given the circumstances. As noted above, this determination is fact-specific and thus this kind of purchase would need to be considered on a case-by-case basis.

Furthermore, the cost must also be allocable to the Federal program. Accordingly, a vehicle purchased with ARP-HCY funds could only be used to serve students eligible for ARP-HCY services.

Grantees and subgrantees are prohibited from using grant funds to purchase real property or to construct new property, unless these activities are “specifically permitted by the authorizing statute or implementing regulations for the program” (see 34 CFR § 76.533). As neither the EHCY nor the ARP-HCY statutes expressly permit the use of program funds for construction, activities would only be allowable to the extent they could be considered minor remodeling rather than construction. Per 34 CFR § 77.1(c):

Minor remodeling means minor alterations in a previously completed building. The term also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously completed building. The term does not include building construction, structural alterations to buildings, building maintenance, or repairs.

Accordingly, to the extent that the project requires any structural alteration, building maintenance, or repairs (as these terms are commonly defined), the LEA may not use EHCY or ARP-HCY funds for these portions of the expenses.

If the activities meet the definition of minor remodeling, the costs would be allowable provided (1) that they meet the purposes of the EHCY or ARP-HCY program and (2) that the costs are reasonable and necessary under the Uniform Guidance (see 2 CFR § 200.404). Factors to consider might include the necessity of the activities (i.e., whether the space would be usable without the changes), the number of students experiencing homelessness that would use the counseling center, the number of years the LEA expects to serve students experiencing homelessness at this counseling center, and the cost required to complete the changes to the counseling center.

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Scenario #4

How would you evaluate whether to spend funds on housing assistance for a family or UHY?

Is it necessary and reasonable?
Are there other resources (partners or donations) available to cover the expense?
Does the expense align with the purposes of the law?
Does the expense align with the law’s allowed use of funds?
Are other students already provided comparable services?
Is the cost relative to the benefits received?

Other or Angel Fund related scenario –

When ARP-HCY funds expire, angel funds could possibly be a way for LEAs to cover these costs.

Currently, the Dear Colleague Letter language (p 4) says ARP funds can be used to pay for “short-term, temporary housing (e.g., a few days in a motel) when such emergency housing is the only reasonable option for COVID-safe temporary housing and when necessary to enable the homeless child or youth to attend school and participate fully in school activities (including summer school)”

Are there other resources like community housing assistance, including emergency rental assistance. Is the cost relative to expense?

If an LEA opts to use ARP-HCY funds to pay for short-term temporary housing, they should establish clear parameters to ensure the use of funds aligns with the guidelines in the Dear Colleague Letter.

I’d also consider whether 1. how to handle the situation when the time is up, so does a few days in a motel position a family to move into a more permanent arrangement? And 2. how to handle any damage fees incurred by the family.

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Questions

Questions?

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Establishing a Workable Plan for a Sustainable Future

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Achieving Sustainability

The ability to maintain or support a program continually over time.

Environment “Culture"

Processes

People & Partners

“Sustainability Plan” worksheet

Sustainability: The ability to maintain or support a process continuously over time.

Its intent is the proper alignment of people, processes, and the environment to achieve success. Leadership is imperative to make sustainability work.

The graphic shows why all three components need to be in place. When leaders only focus only on any one areas, People & Partners, Processes, or the Environment/Culture, little, if any, progress is achieved. However, when these elements are aligned with one another, progress begins to drive the success towards effectively creating a program that not only identifies students and removes barriers to accessing education for students experiencing homelessness but also helps set up students for academic success and a more hopeful future.

Use the “Sustainability Plan” handout as a note-taker to capture your ideas.

Complete the “funding sources” as best as you can. You may need to go back and complete this later.

Ask yourself what do you need to do in each of these three areas. Complete the “Current Practice” and “Desired Outcomes” sections as you plan for next year.

- Are the “right” people in the positions? Do they understand their job? Do they feel supported? Do they have the training and other resources they need to accomplish the tasks required of them? Have relationships with partners in the community been established to meet the needs of the whole child and to provide needed referrals for medical, dental, mental health, housing, nutritional support, etc. to UHY or MV families?

- Are processes or protocols in place to effectively identify and support students? Are the relationships built and communication lines open to be able to arrange for transportation, interventions, or provide referrals of outside agencies, etc.?

- Is there an environment or culture that understands the signs of homelessness, �

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Checking for Understanding

Definition of Homelessness
Remove barriers and providing services to MV students
Funding sources and their purposes
Effective and allowable use of grant funds
Establishing a workable plan for a sustainable future