May a non-public school receive reimbursement for COVID-19-related expenses?
(Question D-2 from Department of Education FAQ Document)
Yes. A non-public school may request reimbursement in its application for expenses it has incurred or will incur for most allowable services or assistance. (See D-1). An SEA may reimburse a non-public school only for expenses for allowable services or assistance it incurred on or after March 13, 2020, to prevent, prepare for, and respond to COVID-19, that have not already been reimbursed with Federal funds, including PPP. Reimbursements under the EANS program do not make non-public schools 11 recipients of Federal financial assistance. (See D-7). With respect to a request in a non-public school’s application for reimbursement of future services or assistance, the SEA should have a process in place to review the requested services or assistance to ensure that they are necessary, reasonable, and allowable under the CRRSA Act, and approve reimbursement to the non-public school.
To maintain control over the EANS funds, the SEA must ensure that the non-public school’s expenditures are allowable expenses, that the non-public school has sufficient documentation supporting such expenditures, that the school actually received the services or assistance related to those expenditures, and that the SEA or another public agency gains title to materials, equipment, and property for which it provides reimbursement. For example, if a non-public school purchased laptops for students and teachers to facilitate online learning, the SEA may use EANS funds to purchase those laptops from the non-public school, thereby also obtaining title for the laptops from the non-public school. Provided these conditions are met, the SEA may continue to allow the laptops to be used by non-public school students and teachers.