Federal COVID Relief Funding
State and local governments, K-12 schools, and higher education institutions are now receiving funds allocated by a series of three Coronavirus-related stimulus bills enacted by the U.S. Congress in 2020 and 2021:
Breaking It All Down
The web of underlying legislation, legislation incorporated by reference, and relevant guidance from federal agencies attached to these federal funds is complex and often confusing. Our goal here is to provide clarity and easy access to relevant documents that will aid our members in navigating this complicated environment. This page addresses:
- Total COVID relief dollars available to public sector entities. Read More>>
- Eligible uses of funds. Read More>>
- Deadlines to obligate the funds. Read More>>
- Uniform Guidance requirements. Read More>>
- Spending federal funds through Equalis Group. Read More>>
- Supporting documentation available from Equalis Group. Read More>>
- Request Uniform Guidance Compliance Checklist. Request Now>>
Navigating Federal Funding Complexities
Congress appropriated $635.1 billion for public sector entities into various funds through three pieces of legislation. The dollars are typically allocated by state based on defined formulas. Whether the funds are then distributed directly to the agencies to be spent or agencies have to apply for the funds depends on the rules established for the particular fund and by the individual state. See the breakdown of appropriated funds below.
* Program Overview
** Dollars allocated by state or territory
* Program Overview
** Dollars allocated by state or territory
* Program Overview
The guidelines regarding the types of products and services upon which federal fund recipients can spend those dollars are vague. Intentionally.
Congress wanted to provide recipients with a broad range of flexibility in how they choose to allocate the Coronavirus Relief Funds they receive. Equalis Group developed summaries of the types of expenditures authorized under SLFRF, ESSER, and HEERF. The source text from various federal agencies is cited in each summary. There may be additional requirements and guidelines associated with the various buckets of authorized expenditures. The following guides are intended to provide a clear path to navigating and understanding the types of expenditures that ARE in fact permissible.
Part of the intention of the COVID relief funding was to provide economic stimulus. As such, Congress set deadlines by which various funds must be obligated* by recipients:
- ESSER II funds from The Coronavirus Response and Relief Supplemental Appropriations Act must be obligated by September 30, 2022.
- ARP ESSER funds from The American Rescue Plan Act must be obligated by September 30, 2023.
- SLFRF funds from The American Rescue Plan Act must be obligated by December 31, 2024, and spent by December 31, 2026.
- HEERF funds must be spent within one year from the date the U.S. Department of Education processed the most recent HEERF award to the recipient. In other words, institutions that received a supplemental award under HEERF III have one year from the date of the HEERF III award to expend all remaining HEERF I, HEERF II, and HEERF III funds. No-cost extensions of up to 12 months are available as provided for in 2 CFR § 200.308(e)(2).
* “Obligated funds” means the recipient has committed the funds for a specific use, whether the funds will be expended immediately or in the future. Examples include signed contracts, purchase orders, requisitions, and credit lines established with vendors.
There are strict guidelines that apply to recipients spending SLFRF, ESSER, and HEERF funds. These requirements are defined in two sets of regulations:
- The Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly called “Uniform Guidance”, and
- The U.S. Department of Education’s Education Department General Administrative Regulations, usually referred to as “EDGAR”.
SLFRF funds authorized by The American Rescue Plan are subject to Uniform Guidance requirements. ESSER and HEERF funds are subject to both Uniform Guidance and EDGAR requirements.
Simply put, there are requirements that relate to the i) procurement of contracts through which federal funding recipients will spend federal funds, whether those contracts are procured by the recipients themselves or another public agency, such as an Equalis Group Lead Agency, and ii) actual expenditures of federal funds received.
Question 1: Can SLFRF, ESSER and HEERF dollars be spent through intergovernmental agreements, such as the portfolio of publicly procured, competitively solicited Equalis Group Master Agreements?
The short answer is: Yes
In fact, the use of state and local intergovernmental agreements and inter-entity agreements for the expenditure of federal funds is explicitly encouraged for non-federal entities receiving federal awards in 2-CFR § 200.318(e), which states:
“To foster greater economy and efficiency, and in accordance with efforts to promote cost effective use of shared services across the Federal Government, the non-Federal entity is encouraged to enter into state and local intergovernmental agreements or inter-entity agreements where appropriate for procurement or use of common or shared goods and services. Competition requirements will be met with documented procurement actions using strategic sourcing, shared services, and other similar procurement arrangements.”
Question 2: Do Equalis Group Master Agreements meet the procurement requirements established in Uniform Guidance and EDGAR?
Equalis Group Master Agreements are publicly procured contracts sourced by local governmental agencies and education service centers (Lead Agencies) in conformity with the regulatory requirements established for non-federal entities in Uniform Guidance and EDGAR. These Master Agreements are made available to public agencies across the country through intergovernmental agreements. Equalis Group provides the required procurement and contracting documentation for members’ records.
Expenditure Compliance Guides
Reference the following guides, which include citations to source text for your convenience.
Equalis Group and our Lead Agencies maintain extensive documentation for each publicly procured, competitively solicited Master Agreement available to Equalis Group members. The following documents are typically published on the contract page for each Master Agreement:
|Request for Proposal (RFP)||Proof of RFP Publication||Winning Supplier RFP Response|
|Bid Tabulation||Award Letter||Fully Executed Master Agreement|
Simply complete the form below to request a Uniform Guidance Compliance Checklist for a particular Equalis Group Master Agreement.
Uniform Guidance Compliance Checklist
Equalis Group developed a Uniform Guidance Compliance Checklist that is applied to individual Master Agreements. The checklist identifies applicable Uniform Guidance requirements relating explicitly to the procurement and establishment of each Equalis Group Master Agreement, provides a summary of how the Lead Agency that procured and awarded that Master Agreement conformed with those procurement requirements, and cross-references supporting RFP and contract documents for members’ records.
The checklist is an easy-to-follow tool for Equalis Group members to quickly validate their ability to make purchases using federal funds through Equalis Group’s publicly procured, competitively solicited Master Agreements in accordance with Uniform Guidance. It also serves as a guide for the procurement-related documentation members must maintain when spending federal funds.
Request Your Checklist
Please complete the following information to request a completed Uniform Guidance Compliance Checklist for a specific Master Agreement.