Non-public schools have an opportunity to apply for federal funding through the Emergency Assistance to Non-Public Schools (EANS) Program. Virginia participates in this program and recently received specific funding. Administrators should act quickly as the funds are limited.

What is the EANS Program?

If EANS sounds familiar, that’s because it is: Congress first authorized the funding in the CARES Act. Supplemental EANS funding was made available in the Consolidated Appropriations Act at the end of December 2020. Federal assistance, administered through the U.S. Department of Education, is provided to state governors who apply for EANS funds.

EANS funds are intended to help non-public schools address educational disruptions caused by COVID-19. Non-public schools that enroll low-income students and are most impacted by COVID-19 will be prioritized in the award process. States have six months from receiving the funds to obligate them to eligible schools.

Virginia applied for EANS funding on February 19, 2021 and recently received the funds.

Non-Public School Eligibility Requirements

Non-public schools are eligible for EANS funds if they meet the following criteria.

  • Elementary or secondary school
  • Non-profit
  • Accredited, licensed, or otherwise operating according to state law
  • In existence prior to March 13, 2020
  • Did not and will not apply for a PPP loan that is made on or after December 27, 2020

Faith-based non-public schools are eligible; however, all services or assistance provided for with EANS funds must be “secular, neutral, and non-ideological.”

Factors such as loss of tuition revenue, enrollment declines, inability to offer remote learning, and information supporting data loss will be used to prioritize eligible non-public schools.

Virginia EANS Application Requirements

Following are the minimum application requirements.

  • Number and percentage of students from low-income families that were enrolled during the 2019-2020 school year. Can include: Free or reduced-price lunch data; scholarships or financial assistance; E-Rates; other relevant information as it concerns state or local programs. Schools can look for data points from the Census Bureau’s American Community Survey (ACS) or Small Area Income and Poverty Estimates (SAIPE), or by multiplying the number of Title I students by the percentage of public school students in the same area.
  • Information about the impact of COVID-19.
  • Description of requested services or assistance.
  • Affirmation about whether the non-public school received a PPP loan prior to December 27, 2020, and if so, the amount of the loan.

Having received prior PPP funding will not disqualify a non-public school from receiving aid through EANS. However, the non-public school must provide assurance that it will not receive future PPP funding.

Once received, states have 30 days to review an application.

How to Use EANS Funds

The following is a non-exhaustive list of allowable uses of EANS funds.

  • Cleaning supplies
  • Personal protective equipment (PPE) and other COVID-related expenses
  • Improvements to ventilation systems
  • Physical barriers to aid in social distancing
  • Educational technology
  • Transportation costs
  • Education and support services for remote or hybrid learning

EANS money may be used to reimburse a non-public school for other COVID-19 expenses incurred after March 13, 2020 if those services or expenses haven’t already been reimbursed – e.g. through a PPP loan. Certain expenses, though allowable prospectively under EANS funds, may not be reimbursed.

Allowable (but not as reimbursed) expenditures include:

  • Ventilation system improvements
  • Previously reimbursed expenses paid for with forgiven PPP funds
  • Staff training on sanitation, use of PPE, and COVID-19 protocols
  • Development of instructional plans for remote or hybrid learning
  • Education and support services for remote or hybrid learning or to address learning loss

Any equipment/supplies purchased through the program must be used by September 30, 2023.

Also, schools themselves would not be subject to Single Audits solely based on the expenditure of EANS funds. State governors are considered to be the recipient of these federal funds. Nonetheless, certain reporting requirements are applicable and school administrators should check with their state educational agency for details.

A myriad of funds are available through legislation signed over the past year to help offset COVID-19 expenses and tuition loss. To obtain funding, non-public school administrators will need to carefully evaluate eligibility and application requirements.

PBMares can help with the application process, funding allocations, and ongoing documentation for Emergency Assistance to Non-Public Schools and other COVID-19 funding. Contact your PBMares advisor or Bo Garner, CPA, MBA, Not-for-Profit Team Leader, for assistance.