In a continuous effort to provide our students with the best possible access and opportunity to an enriched and Well-Rounded education, we are providing updated information made available to us regarding the new funding source known as the Student Support & Academic Enrichment Grants, or Title IV-A:
- The 15% Technological Infrastructure Rule (ESSA 4109):
- Well-Rounded Education, part of our students Civil Rights (ESSA 4107):
As previously understood, the 15% Technology Rule applied to all technological purchases; the 15% was derived from the portion of funds allocated toward the Effective Use of Technology portion of the grant.
Due to multiple inquiries from the field both in Arizona and across the nation, US ED has since provided clarification of this rule:
For the ‘safe and healthy’ and ‘well-rounded education’ content areas, technology purchases are not limited or restricted, but the technology purchase would need to be consistent with the purposes of the content area. What LEAs propose as activities will be informed by the comprehensive needs assessment (required for LEAs with an allocation of at least $30,000), stakeholder engagement, and prioritization of schools. The SEA’s determination of allowability of SSAE funds will depend on a number of factors, starting with whether all statutory requirements are met.
Generally, in reviewing an LEA’s application, an SEA will first consider whether a proposed activity is consistent with the purposes of at least one of the three content areas in the SSAE program (well-rounded education in section 4107, safe and healthy students in section 4108, or the effective use of technology in section 4109). Assuming that the activity is consistent with the purposes of one of the three content areas, as applicable, the SEA must make further determinations as to allowability of costs in accordance with the cost principles in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 CFR Part 200, Subpart E. Specifically, the cost of an activity is allowable under the SSAE program if it is reasonable and necessary for performance of the grant (i.e., it is of a type generally recognized as ordinary and necessary for operation of the grant) and allocable to the grant (i.e., it is chargeable to the grant award in proportion to the benefits received by the grant award as a result of the cost).
Also, because section 4110 of the ESEA prohibits supplanting, the proposed use of funds for the activity must supplement, and not supplant, other State or local funds that would otherwise be used to pay for the allowable activity. Finally, SEAs must check to ensure that the activity is not one of the prohibited activities in section 4001(b) or 8526 of the ESEA, as amended by the Every Student Succeeds Act (ESSA).
With this new understanding, you may be able to identify technological solutions for your Well-Rounded Education and Safe & Healthy Students needs and NOT activate the 15% Rule. The 15%, when activated, will still be derived from the portion of funds you allocate to the Effective Use of Technology category and NOT the total allocation.
As we all are aware, the transition from NCLB to ESSA came with the transition from research-based activities to evidence-based activities. Under ESSA, activities or programs funded through federal dollars must have an evidence-based claim that the strategy will improve student academic achievement.
Under Title IV-A, both the Safe & Healthy Students (ESSA 4108) and the Effective Use of Technology (ESSA 4109) sections of the grant come with the evidence-based requirement, however, the Well-Rounded Education section mentions no such language. Instead, the Well-Rounded Education section (ESSA 4107) emphasizes student access and opportunity to activities and programs that are defined as well-rounded (ESSA 8201). This in essence equates the Well-Rounded education prevision of Title IV-A as a Civil Right and therefore should be approached as such.
Please also understand that, while this allows for a certain increase of flexibility, it is best practice that evidence-based strategies are identified to support the development of our students.
We are excited about these developments and encourage LEAs to “revision” the capabilities of Title IV-A funds. Your ADE Title IV-A Program Area staff are dedicated to providing you the best resources, guidance, and technical assistance as you continue to identify innovative solutions to your local needs.
This information will soon be made available on our website, and will be shared in person at this year’s ESSA Conference on both Wednesday, November 14th and Thursday, November 15th.
Director of Arts Education & Title IV-A
Well-Rounded Education, Safe & Healthy Students, Digital Literacy
Arizona Department of Education