On Wednesday, the U.S. Department of Education (ED) released a memo outlining answers to a series of critical questions related to the use of federal education grant funds (including, but not limited to, Perkins funds) during the COVID-19 pandemic. These questions deal with issues related to compensation, travel and conference costs that are otherwise allowable costs under applicable program statutes and regulations.
The first question dealt with whether or not a grantee or subgrantee (grant recipient) could continue to pay employees using grant funds during the period the employee is unable to work because of the closure of the organization due to COVID-19. ED acknowledged that organizations may still do so if the organization pays, consistent with its policies and procedures, similarly situated employees whose compensation is paid with non-Federal funds during an extended closure. However, an employee who is being paid with grant funds while the grant activities are closed due to the pandemic may not also receive pay from the organization or another organization for work on other activities that are not closed down. If a grant recipient doesn’t currently have a policy that addresses extraordinary circumstances currently in place, they may amend or create one to ensure staff can continue to be paid.
The second question dealt with the ability to use grant funds to reimburse nonrefundable travel for conferences, trainings, or other activities related to a grant that were cancelled due to COVID-19. ED acknowledged that a grant recipient may seek a reimbursement only after certain options are exhausted. First, the grant recipient must seek to recover the nonrefundable costs from the relevant entity that charged the fee (airline, hotel, conference organizer). ED mentions that some businesses are offering flexibility with regard to refunds, credits, etc. for losses caused by the COVID-19 outbreak. Additionally, if the agreement or contract for conferences, training, or other contained an emergency or “act of God” provision, the grant recipient must seek to exercise that clause prior to becoming eligible to use grant funds for reimbursement. If a grant recipient is unable to recover the costs after exhausting the aforementioned options, they are able to charge the cancellation costs to the appropriate grant, assuming the costs were both reasonable and were incurred in order to carry out an allowable activity under the grant.
ED also stated that those seeking reimbursements should not assume additional funds will be available if the cancellation or other fees result in a shortage of funds to eventually carry out the event or travel. Further, recipients must “maintain appropriate records and cost documentation.”
The final question dealt with future travel for events, and if funds under a grant could be used to purchase travel insurance. ED makes it clear in the beginning that grant-supported travel should generally not be occurring right now due to health concerns related to COVID-19. But, they go on to say that if travel is being permitted by Federal, State, and local directives and “is the only means to carry out an essential grant function that must be undertaken on a time-sensitive basis during the pandemic,” than then purchasing travel insurance is allowable provided the cost is reasonable and is allocable to the grant consistent with Federal cost principles.
This is already the second set of FAQ’s covered on the CTE Policy Watch Blog, with the first dealing with series of critical questions facing CTE leaders during the current COVID-19 pandemic. The Department acknowledged that there are more questions that will need to be answered as we progress. They will continue to add additional questions and answers as they become available, so please continue to check back on the CTE Policy Watch Blog for any new updates!
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