Apr. 14th, 2020

Highlights of U.S.D.E and MDE Updates in Response to COVID-19

Charging employee salaries to federal programs

U.S. Department of Education issued a fact sheet responding to FAQs related to the use of grant funds during COVID-19. These FAQs address compensation, travel, and conference costs that are otherwise allowable costs under applicable program statutes and regulations.

  • Generally, a grantee or subgrantee may continue to charge the compensation of its employees who are paid by a currently active grant to that grant. However, an employee who is being paid with grant funds while the program grant activities are closed due to the COVID-19 pandemic may not also be paid for the time during which the program is closed by the organization or another organization for working on other activities that are not closed down.
  • A grantee and subgrantee must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 (financial management), 2 CFR § 200.430(i) (standards for documenting personnel expenses), and 2 CFR § 200.333 (retention requirements for records) to substantiate the charging of any compensation costs related to interruption of operations or services.

For more information, refer to Coronavirus fact sheet fiscal questions.

Also, it is allowable to continue to charge salaries and benefits for special education staff teleworking and staff not working using IDEA Part B funds following the district’s policy of paying salaries from all funding sources, federal and non-federal. Staff would be paid from the same funding sources similarly as before the COVID-19 crisis and supported by time and effort documentation.

For more information and a Q&A, refer to the MDE’s memo 012, Use of Federal Title Funds During Mandated COVID-19 Closure

Federal Funding for Technology

MDE issued a waiver for all schools for Title funding that allows schools flexibility in Title spending for students and teachers for technology purchases. Specifically, the waiver allows schools flexibility for:

Title I Funds:

  • To purchase Hot Spots and other internet access tools for students
  • To purchase devices for teacher use to support student learning
  • To purchase student devices (computers, iPads, etc.)

Title IIA Funds:

  • To support training for educators to help them learn how to deliver instruction and connect with students virtually
  • To support professional development opportunities delivered virtually to support goals identified in district improvement plans
  • To purchase devices needed to support the teacher trainings

Title IV Funds:

  • To support technology (devices, access, etc.)
  • To purchase more than the 15% limit normally applied for technology

Reporting

  • Districts will not need to receive prior approval for the purchase of technology supports during this period of emergency. Districts should e-mail their regional consultant to inform him/her of the changes.
  • Additional budget amendments will be allowed for an extended period.

For more information, refer to MDE’s memo 021, Flexibility in Title Funds for Technology

Nutrition Programs

  • MDE has requested a waiver for all Michigan school districts for statutory and regulatory requirements of the Child Nutrition Program. This includes a waiver for the Emergency Food Assistance Programs and the Commodity Supplemental Food Program.
  • MDE has opened advance payments for school nutrition programs and is focused on providing meals during this time of crisis to all students in need.
  • MDE received waiver from USDA to serve non-congregate meals under the Unanticipated School Closure provision of the Summer Food Service Program (SFSP). The waiver allows schools to serve meals without having to keep children together and on-site.
  • Schools that do not qualify based on F/R% are eligible to participate.

For more information, go to:

Feeding Children in the MDE Child Nutrition Programs During the National Public Health Emergency

Questions for Unanticipated School Closure SFSP

Accounting for USDA Unanticipated School Closure SFSP Funds

All revenues and expenditures during food service operations of the USDA Unanticipated School Closure Summer Food Service Program (SFSP) should be tracked and reported to the Summer Food Service Program grant code 858 in the Food Service Fund (Fund 25). These expenses will need to flow to the “All Other Programs” column on the FID School Meals Report. Coding to SFSP grant code 858 will accomplish that.

For more information see State School Aid Update April 2020

See all MDE memos related to updates for COVID-19: MDE COVID-19 Updates

Special Note Related to GASB

The Governmental Accounting Standards Board (GASB) has also been providing updates due to concerns with the COVID-19 pandemic. GASB is reviewing a proposed Statement that would postpone the effective dates of provisions in certain pronouncements. The proposal has tentatively identified provisions that became effective or will become effective for reporting periods beginning after June 15, 2018, through Statement No. 92, Omnibus 2020, and Implementation Guide No. 2019-3, Leases. Particularly for schools, this is important as that includes Statement No. 84, Fiduciary Activities, and Statement No. 87, Leases.

Our Governmental Audit team at Hungerford Nichols CPAs + Advisors will continue to monitor GASB changes and let you know when something has been finalized.