Allowable Uses of COVID Relief: Technology and Construction


States, school districts, and schools have significant flexibility in spending federal COVID relief funds announced last spring.   

Public and private schools have $190 billion from three rounds of federal funding grants from March 2020 to March 2021. More importantly, states and districts are only planning to spend a small portion of these funds. 

Restrictions on how districts can spend federal money, called "allowable use of funds," are typical. However, in the case of the three major Elementary and Secondary School Emergency Relief (ESSER) grants, minimal limits exist.  

  • At least 20 percent of $122 billion in American Rescue Plan (ARP) Act ESSER III funds designated for districts must be spent on programs to reduce learning loss
  • State Education Agencies (SEAs) can reserve up to 10 percent of the ESSER III funds granted to them 
  • SEAs must spend 5 percent (half of their reservation) on programs and activities to address learning loss, at least 1 percent on summer learning, and another 1 percent on afterschool programs

Beyond those stipulations, districts can spend the funds within broad categories, such as:  

  • Programs and activities to meet the unique needs of at-risk student groups, including Multilingual Learners (MLs aka ELs), and students experiencing homelessness 
  • Maintaining healthy facilities such as upgrading ventilation systems in a school to improve heating or air conditioning, roof repairs 
  • Technology, including devices, software, and broadband access that improves digital equity and access (additional funding is available for broadband access via the Emergency Broadband Benefit)  
  • Expanding summer programs or early childhood programs  

Spending Must be COVID-Related 

The one common thread of all ESSER funds is that spending must tie in with the impacts of the pandemic. According to an EdWeek article, state auditors will watch districts to ensure they do their "due diligence,” to ensure they are actively trying to find cheaper solutions to their problems, and that districts document their spending to ensure it is COVID-related.  

The federal government put out a Fact Sheet in December 2021 that confirms these funds are for priorities that existed before the pandemic, provided that those priorities help with pandemic recovery. That still leaves room for interpretation.  

A complete list of allowable uses for these funds is available in each bill's "Uses of Funds" education sections (CARES Act page 285, CRRSA Act page 749, and ARP Act page 17).  

Districts can use these funds to purchase products from the TransACT product family, including ParentNotices, AfterSchool21, Travel Tracker – Routes, Travel Tracker Field Trips, Facility Tracker, and Homeless Information Management System for Students (HIMSS).   

Dr. David Holbrook

About The Author

Dr. David Holbrook is a nationally recognized leader in federal programs administration and monitoring with expertise in Title I, Title III, Native American Education, and Federal Programs. Dr. Holbrook has also worked as a consultant with Title III of the US Department of Education and now serves as Executive Director, Federal Compliance and State Relationships with TransAct.