Q. Our LEA has paid for professional development activities with federal funds (i.e., Title I or Title II) that are now cancelled or unable to be held due to COVID-19 restrictions. How should we proceed?
A. The LEA should attempt to recoup all fees paid so funding may be repurposed for an alternate activity. In the case where funds cannot be recouped due to vendors that will not refund the costs but will provide vouchers, consider rescheduling at a later date within the same project period. If rescheduling in the same project period is not possible, it can be paid in one fiscal year with the event happening in the following year. If it would get cancelled the following year, the LEA must keep documentation of the attempt to recoup the costs and may request to use the funds towards another allowable event or activity or refund the funds to the NDDPI. LEAs must maintain documentation to substantiate the charging of any cancellation or other fees related to the interruption of operations or services.
If the LEA later receives a refund from the vendor after already seeking reimbursement from NDDPI, this serves as a rebate or cash on hand, which must be either returned to NDDPI or proportionally reduce the next reimbursement under the same project. If this occurs across fiscal years, the LEA may have to revise their final financial report and final request for funds to correct this issue.
If additional flexibilities are provided by the USED, this guidance will be updated.
Q. Title II funding was used for conference registration and travel. The conference has been postponed from May 2020 to August 2020, which occurs in the next fiscal year. The conference registration transferred forward to August and the airline has provided a voucher. How should we proceed as this falls across fiscal years?
A. The USDE has recently provided guidance and flexibility around cancelled and postponed events. It would be acceptable for the LEA to use the travel voucher and attend the August 2020 conference. No additional adjustments would be necessary.
If the event ends up being cancelled and later receives a refund from the vendor after already seeking reimbursement from NDDPI, this serves as a rebate or cash on hand, which must be either returned to NDDPI or proportionally reduce the next reimbursement under the same project. If this occurs across fiscal years, the LEA would have to revise their final financial report and final request for funds to correct this issue.
Q. Following social distance guidance, or LEAs planned professional learning cannot take place, how might Title II funds be used when in-person professional learning cannot be the focus?
A. Many LEAs engage in job-embedded professional learning such as coaching, mentoring, and professional learning communities which require regular contact. The NDDPI encourages LEAs to consider how virtual tools might be used, where possible and appropriate, to maintain these collaborative learning opportunities for staff.
While travel to external professional learning may be restricted, LEAs might consider shifting the focus to internally supported professional learning and systemic planning. For instance, Title II allows districts to utilize funds to support flexible time for collaborative planning and curriculum writing as well as to development, implement, and improve rigorous, transparent and fair evaluation and support systems.
Q. Our LEA applied for Title II reallocated funding for activities that have been canceled due to COVID-19. Will we lose those funds?
A. No. Title II reallocated funds were prioritized and granted for high-quality professional development and leadership supports. Due to the COVID-19 pandemic, LEAs with unspent Title II reallocated funds will be allowed to carry them forward for use in the 2020-2021 school year. It will be expected these funds will be represented in the consolidated application and budgeted toward high-quality professional development and leadership supports.
LEAs may choose to do a budget revision and use their reallocated funds for alternate high-quality professional development and leadership supports at any time prior to submitting the final financial report and reallocated funds addendum.
Q. How will Title II carryover be impacted?
A. Current USDE guidance allows Title II, Part A funds to be carried over at 100% of the following year’s allocations. North Dakota will be implementing this provision for the 2019-2020 school year.