Fact Sheet for Repurposing Federal Equipment and Supplies to Combat COVID-19

Generally, equipment and supplies purchased with Federal funds may only be used to carry out the purposes of the Federal program for which they were purchased and for intended Beneficiaries (2 C.F.R. § 200.403(a))

The U.S. Department of Education (ED) has released new guidance (Fact Sheet for Repurposing Federal Equipment and Supplies to Combat COVID-19) that allows grantees and subgrantees to repurpose federally purchased equipment and supplies that are not currently in use to carry out a Department grant program to meet the general education needs of students, including students with disabilities and English learners, and the instructional needs of teachers, related services providers, and other educational personnel during the national emergency caused by COVID-19

When the national emergency ends, schools reopen, and students once again begin attending schools in person, the equipment and supplies that are not consumed must be returned for use in the Department grant programs for which they were purchased

To take advantage of this flexibility, grantees and subgrantees must clearly mark the equipment and supplies being repurposed with pertinent identifying information. In addition, grantees and subgrantees must maintain an inventory of the equipment and supplies being repurposed to facilitate proper return, including the following:

• a description and itemization of the type of equipment or supplies being temporarily repurposed
• the source (Federal program(s) funds involved) from which the temporarily repurposed equipment or supplies were purchased and the amount of Federal funds used for the purchase
• where the equipment or supplies are assigned for use during the duration of the COVID-19 national emergency
• the date on which the equipment or non-consumed supplies are returned for Federal program purposes

Grantees must maintain these records for a minimum of 3 years and until the resolution of any audit, monitoring, or oversight that is being conducted relative to the repurposed equipment or supplies, as required by 2 C.F.R. §§ 200.302 (financial management) and 200.333 (retention requirements for records)

Equipment and non-consumable supplies that are lost or damaged must be replaced with non-Federal funds to ensure continued benefit to the Department grant program

Please Note: This authority does not permit grantees and subgrantees to use unobligated grant funds to purchase new equipment and supplies for purposes not aligned with the allowable activities of the program under which funds are available.

Grantees should not assume additional funds will be available should the repurposing of equipment and supplies result in any type of shortage to a program

The U.S. Department of Education (ED) released the following guidance regarding how to calculate proportionate share for equitable services (and the provision of those services by school districts) for ESSER Fund-participating non-profit private schools:

• Providing Equitable Services to Students and Teachers in Non-Public Schools Under the CARES Act Programs

ED also released the following FAQ with guidance on how states must calculate ESSER Fung LEA allocations for LEAs that received FY20 Title I funds:

• Frequently Asked Questions about the Elementary and Secondary School Emergency Relief Fund (ESSER Fund)