Getting to Yes on Covid Relief Spending

The U.S. Education Department’s December 2022 and  May 2021 guidance on spending Covid relief aid for K-12 schools provides a detailed explanation of how states and school districts should manage the use of nearly $190 billion allotted in the American Rescue Plan and two earlier relief packages. The 61-page document also answers a number of questions about what the money can be spent for: Construction projects, vaccinations for students and staff, child care for teachers, and adult learning, among other things, all make the cut with certain limitations. The frequently-asked-questions sheet covers both money provided under the Elementary and Secondary Schools Emergency Relief fund (ESSER) and the Governors Emergency Education Relief fund (GEER). We’ve excerpted key questions and answers on how these funds can be used.

Guidance released in November 2021 clarifies that districts can use the relief aid for a variety of transportation needs, including dealing with the shortage of school bus drivers.

May ESSER and GEER funds be used in combination (‘braided”) with other funding?

Yes. ESSER and GEER funds may be used in combination with, but not blended with, funding under ESEA, IDEA, AEFLA, Perkins V, and McKinney-Vento, or any other education funds.

To improve cybersecurity?


For COVID-19 testing for students and staff?


To provide COVID-19 vaccinations to LEA teachers, staff, and eligible students?

Yes. Vaccination outreach efforts in general could include activities to create awareness and build confidence, facilitate clinics, and provide incentives such as paid time off for staff to get vaccinated.

For personal protective equipment (PPE), cleaning and sanitizing materials, and related supplies necessary to maintain school operations during and after the COVID-19 pandemic?


To provide local matches required for federal projects?


To provide subgrants to other organizations?


For video security systems?

Yes, with appropriate protections for privacy and civil rights.

To support early warning indicator systems?



To address a shortage of school bus drivers?


To provide student transportation to and from school or reimburse families?


To provide transportation for students to and from afterschool and enrichment programs offered by the district?


Capital Projects

All capital expenditures are subject to prior approval by the governor or state education agency, as well as federal procurement rules under the Uniform Guidance.

For construction?

Yes. The broad Impact Aid definition of “construction” includes new construction as well as remodeling, alterations, renovations, and repairs under which many activities related to COVID-19 would likely fall. However, the Department discourages LEAs from using ESSER and GEER funds for new construction because this use of funds may limit an LEA’s ability to support other essential needs or initiatives. Remodeling, renovation, and new construction are often time-consuming, which may not be workable under the shorter timelines associated with ESSER and GEER funds.

For such projects as making improvements to a school facility to improve indoor air quality (such as heating, ventilation, and air conditioning (HVAC) systems), and projects that would promote social distancing and safe in-person instruction?

Yes. This might include renovations that would permit an LEA to clean effectively or create a learning environment that could better sustain social distancing. This might also include, school facility repairs and improvements to reduce the risk of virus transmission and exposure to environmental health hazards, as well as Inspection, testing, maintenance, repair, replacement, and upgrade projects to improve the indoor air quality in school facilities.

To purchase trailers or modular units?

Yes, if necessary to create additional safe learning spaces due to the COVID-19 pandemic.

For athletic facilities, stadiums and swimming pools?

No, unless there is a connection between the expenditure and preventing, preparing for, or responding to COVID-19.

To address damage from floods, tornado and other natural disasters?

Yes, but districts should first tap FEMA dollars.

Student Populations

To support 2020 and 2021 high school graduates who have not yet successfully transitioned to college or careers?

Yes. For example, an LEA may provide college or career counseling, assistance with college applications or entry into job training programs, job training, post-secondary counseling and related services, including for associate and baccalaureate degree programs, and financial literacy.

To support for distance learning, including the purchase of educational technology for student use?

Yes. These activities might include providing online learning to all students, including students with disabilities, English learners, students experiencing homelessness, and students in foster care; and training educators in the effective implementation of online learning. To support the continuity of learning, an LEA may use ESSER and GEER funds to purchase educational technology for student and educator use.

To fund pre-kindergarten or other early childhood education program?

Yes. This can include Head Start programs, state licensed or regulated child care programs; programs that addresses young children’s cognitive, social, emotional, and physical development; a state prekindergarten program; a program authorized under IDEA or operated by an LEA.

To serve adults, including English learners, eligible under the Adult Education and Family Literacy Act?


For career and technical education?


To re-engage students?

Yes. LEAs may use indicators such as chronic absenteeism to identify students in need of targeted support and services, as well as more generally identifying which students have lost the greatest number of in-person instructional days since the beginning of the COVID-19 pandemic. Funds may be used to provide academic, social, emotional, behavioral, and, in particular, mental health supports to address the impacts of isolation during this period. In addition, ESSER and GEER funds may be used to conduct child find activities to identify, locate, and evaluate students who are suspected of having disabilities and need special education and related services under the IDEA. Funds may not be used to pay incentives to students and parents for attendance.

To implement community violence intervention strategies?

Yes. Community violence intervention strategies address students’ social, emotional, mental health, and academic development and are especially important in the context of the disproportionate impact of the COVID-19 pandemic on previously underserved groups of students.

For summer job or service-learning programs for high school students?

Yes. Funds may be used both to support the training that high school students receive and to supplement the pay provided to students by employers that participate in the summer jobs program. Funds may also be used to support service learning or other volunteer opportunities for high school students.

For art, music and theater classes?


To provide meals for students?

Yes, but districts should first tap money from other federal programs.

To waive the lunch balance costs for low-income students?


For paying students to attend school?


Supporting Educators

To stabilize and support the educator workforce?

Yes. This may include using funds to pay teacher salaries and avoid layoffs. Funds may also be used to address educator shortages exacerbated by the pandemic by hiring new teachers, including expanding student access to a well-prepared and diverse educator workforce through pipelines and other strategies. Funds can also used to support teacher and staff well-being.

To hire additional health-support staff?

Yes. Funds may be used to hire new counselors, nurses, social workers, and other health support staff to help students and staff with their emotional and physical well-being and help students and staff deal with the impact of the COVID-19 pandemic. An LEA should consider how to use the funds in ways that will build its short- and long-term capacity and be sustained after the funding is no longer available.

To pay employees and contractors, to the greatest extent practicable, during the period of any disruptions or closures related to COVID-19?


To pay overtime to its salaried custodians and other staff in order to prepare for a safe reopening of schools and sustain safe school operations?


To provide childcare services or instructional supervision to children of teachers and staff in order to enable them to return to teaching or other school responsibilities?

Yes, so long as certain conditions are met. For example, an LEA might contract with a daycare provider to make spaces available for teachers with young children whose regular daycare services are unavailable due to the COVID-19 pandemic so that those teachers can continue to provide educational services to students. An LEA might also provide a retention incentive to teachers with young children that could offset the cost for childcare in order to retain those teachers, which is an allowable use of funds under part A of title II of the ESEA, if teacher retention is a challenge due to the COVID-19 pandemic.

To provide “premium pay” or other additional compensation for teachers, principals, and other school personnel, including school nutrition staff and custodians?

Yes, consistent with applicable collective bargaining agreements and other relevant policies and requirements.

These are just a few of the questions addressed in the guidance. Read the full May 2021 document here, the November guidance on transportation here, and the December 2022 update here.

[Read More: What Congressional Covid Funding Means for K-12 Education]

[Read More: Education Department Perspectives on Covid Relief Spending]