General Information
Under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSA Act), Pub. L. No. 116-260 (December 27, 2020), Congress first authorized the Emergency Assistance to Non-Public Schools (EANS) program as part of the Governor’s Emergency Education Relief (GEER II) Fund to provide emergency services or assistance to non-public schools in the wake of the Coronavirus Disease 2019 (COVID-19). The American Rescue Plan Act of 2021 (ARP Act), Pub. L. No. 117-2 (March 11, 2021), authorized a second round of funding (ARP EANS) to provide services or assistance to non-public schools. With two exceptions, the requirements of ARP EANS are the same as those in section 312(d) of the CRRSA Act. The two exceptions are: (1) a State educational agency (SEA) may only provide services or assistance under ARP EANS to non-public schools that enroll a significant percentage of students from low-income families and are most impacted by the novel Coronavirus Disease 2019 (COVID-19) emergency and (2) an SEA may not use ARP EANS funds to provide reimbursements to any non-public school for costs the school incurred to address the impact of COVID-19 emergency.
The Connecticut State Department of Education (CSDE) may provide services or assistance to non-public schools under the EANS program directly or through a contract with an individual, association, agency, or organization. To better facilitate this program under the deadlines, CSDE has contracted with the State Education Resource Center (SERC) to disseminate and collect applications and to provide the services and assistance under the EANS program. To receive services or assistance under the EANS program, an eligible non-public school must submit an application to SERC.
Important Updated Information
Given that the eligibility threshold of 40% of students from low-income families was restrictive and prevented many non-public schools from participating in the program, the State is offering a second opportunity to apply for assistance. All requirements will remain the same except that there will not be a low-income threshold that schools must meet. However, while there is no low-income threshold, CSDE still must prioritize services or assistance to non-public schools that enroll low-income students and are most impacted by COVID-19; therefore, schools will be required to provide the necessary low-income information for reporting purposes and to prorate funding should the total amount of assistance requested be greater than the total amount of funding available.
A non-public school may apply to receive a variety of services or assistance from SERC to address educational disruptions resulting from COVID-19. Schools will not be reimbursed for supplies or assistance they have previously purchased. Services and assistance include, for example, supplies to sanitize, disinfect, and clean school facilities; personal protective equipment (PPE); training and professional development for staff on sanitation, PPE, and minimizing the spread of COVID-19; temporary physical barriers to facilitate social distancing; and educational technology to assist students and teachers with remote or hybrid learning.
All services or assistance provided with GEER ARP EANS funds must be secular, neutral, and non-ideological.
Program Authority
Section 2002 of the American Rescue Plan Act of 2021 (ARP Act), Public Law 117-2 (enacted on March 11, 2021).
Applicable Regulations
- The Education Department General Administrative Regulations in 34 CFR parts 76, 77, 81, 82, 84, 86, 97, 98, and 99.
- The Office of Management and Budget Guidelines to Agencies on Government wide Debarment and Suspension (Nonprocurement) in 2 CFR part 180, as adopted and amended as regulations of the Department in 2 CFR part 3485.
- The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR part 200, as adopted and amended as regulations of the Department in 2 CFR part 3474.
Eligible Non-Public Schools
For purposes of the ARP EANS program, an eligible nonpublic school is an elementary or secondary school that:
- is non-profit (Note: A for-profit non-public school is not eligible to receive equitable services for its students and teachers under the EANS program. Section 315(6) of the CRRSA Act defines a “non-public school” as a non-public elementary or secondary school. Section 315(8) of the CARES Act incorporates the definitions in ESEA section 8101 for any terms not defined in the CARES Act. ESEA section 8101(19) and (45) defines “elementary school” and “secondary school,” respectively, and specifies that they must be non-profit.);
- is accredited, licensed, or otherwise operates in accordance with State law;
- was in existence prior to March 13, 2020, the date the President declared the national emergency due to COVID-19; and
- although there is no low-income eligibility requirement, schools will need to provide such data. The following sources of data may be used, but all data needs to match the income guidelines that are used for Free and Reduced Lunch Eligibility, which is 185% of the 2020 Federal poverty level (2019-2020 Free and Reduced Price Lunch Income Eligibility (https://www.govinfo.gov/content/pkg/FR-2019-03-20/pdf/2019-05183.pdf):
- Data on student eligibility for Free and Reduced Price Lunch under the Richard B. Russell National School Lunch Act,
- Data from the E-rate program administered by the Federal Communications Commission, or
- Data from a different source, such as scholarship or financial assistance data; and
- Has been most impacted by the COVID-19 emergency. The state will utilize the public data available on the number of COVID-19 related infections per capita and deaths per capita in the community served by the non-public school to determine most impacted.
Public Control of Funds
Control of funds for the services or assistance provided to a non-public school and title to materials, equipment, and property purchased with GEER ARP EANS funds must be in a public agency and a public agency must administer such funds, services, assistance, materials, equipment, and property, i.e., all equipment and supplies will be the property of the State Department of Education. CSDE is contracting with SERC to provide services or assistance to non-public schools under the GEER ARP EANS program.
The CSDE will take title to and own all materials and equipment, which will need to be returned to the State at the end of the performance period (September 30, 2024) unless they can continue to be used for the purposes of the EANS or another federal education program, such as the ESEA or the Individuals with Disabilities Education Act (IDEA). In that case, the SEA must retain title to, and maintain administrative control over, the equipment and supplies or transfer title and control to another public agency such as an LEA providing equitable services under another federal education program.
Submission Requirements
Completed applications should be submitted by Wednesday, March 8, 2023. Decisions will be communicated by Thursday, April 6, 2023.
For questions regarding the EANS application process please contact:
Leah Grenier
Connecticut State Department of Education
Bureau of Fiscal Services
450 Columbus Boulevard
Hartford, CT 06103
Leah.Grenier@ct.gov
For questions on allowable services or assistance, please see the Frequently Asked Questions posted online at https://oese.ed.gov/files/2021/09/Final-EANS-FAQ-Update-9.17.21.pdf
If additional information is needed on allowable services or assistance, please email:
eans@ctserc.org