U.S. Department of Education General and Technical Frequently Asked Questions (FAQs) for CARES ESSER, CARES GEER, CRRSA ESSER, CRRSA GEER, CRRSA EANS, ARP ESSER, and ARP EANS Liquidation Extension Requests - January 9, 2024

Oct 15, 2026

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Guidance explains how State-administered formula grant obligations may be liquidated after the carryover/Tydings period for COVID-relief funds under CARES, CRRSA, and ARP programs. It describes the 120-day automatic liquidation timeframe and the Department’s process for extending liquidation for allowable, timely obligated projects up to an additional 14 months (and up to 18 months for certain contracts). It also states that extensions are not automatic, require Department approval, and prohibit new ARP-related contracts after September 30, 2024.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages6

Reading Time15 min

AccessFree to download

Introduction

Carryover/Tydings and 120-day liquidation period

Liquidation extensions up to 14 months

Frequently Asked Questions

Q1 Requests through the Liquidation Extension Request template

Q2 Submitting requests for ARP Act ESSER funds

Q3 Cover letter requirements

U.S. Department of Education General and Technical Frequently Asked Questions (FAQs) for CARES ESSER, CARES GEER, CRRSA ESSER, CRRSA GEER, CRRSA EANS, ARP ESSER, and ARP EANS Liquidation Extension Requests January 9, 2024 84.425C-GEER Grantees 84.425D, 84.425U-ESSER Grantees 84.425R, 84.425V-EANS Grantees Introduction For the Department’s State-administered formula grant programs (Part 76 of the Department’s regulations), obligations must be made by the grantee or subgrantee by the end of the“carryover” or Tydings Period, which allows funds to be obligated for an additional fiscal year beyond the fiscal year for which they were appropriated. These timely obligations may be liquidated for up to 120 days after that period without requiring Department approval. Beyond that point, after reviewing a request from a grantee, the Department may extend the period for costs associated with certain timely obligated projects to be liquidated in accordance with regulation and policy as discussed below. More specifically, subject to other requirements discussed in this document, it is the Department’s longstanding approach that, under circumstances such as those related to the COVID-19 pandemic, for timely and allowable obligations, services and payments associated with those services may extend through the end of the 120-day liquidation period and, upon request from a grantee, be approved for up to an additional 14 months beyond this date, provided a timely and valid obligation had been made pursuant to 34 C.F.R. § 76.707. For example, States (and, if applicable, their subgrantees) can continue contracted activities under American Rescue Plan (ARP)-funded contracts during ARP’s liquidation period if: 1) the binding written contract was made by ARP’s obligation deadline of September 30, 2024; 2) the project relates to an allowable activity; and 3) the additional time to liquidate funds is consistent with all State, local, and federal spending rules. Under a liquidation extension of up to 14 additional months if approved by the Department: • States (or subgrantees) will have additional time to draw down COVID-relief funds so timely obligated activities can be paid; and • States (or subgrantees) will have additional time to carry out contracts, or other properly made obligations, for allowable activities when those obligations were made on or before the statutory deadline (September 30, 2024, for ARP funds) . As an example of how liquidation extension approvals may work in practice for ARP funds, if a school district (subgrantee) contracts with a tutoring services vendor prior to September 30, 2024, and that contract meets the requirements described in this document, it is permissible for the district to both receive services and liquidate funds for up to 18 months (i.e., the initial 120-day liquidation period, plus the additional 14 months, if approved) past that date under the contract finalized on or before the obligation deadline. A liquidation extension beyond the initial 120-day liquidation period is not automatic. Grantees must submit required information and obtain approval from the Department to receive a liquidation extension for themselves or on behalf of their subgrantees. Under no circumstances may a State or subgrantee enter into new contracts—i.e., incur new obligations—relating to ARP after September 30, 2024. As previously communicated, the Department will continue to help ensure that auditors are aware of this guidance. The Department is also available to speak to State or other auditors with fact-specific questions. Under the circumstances described above with regard to COVID-relief funding, while all Departmental review is fact-specific and would be considered on a case-bycase basis, the Department would not sustain an audit finding related solely to the continuation of services beyond the carryover period under an approved COVID-relief funding liquidation extension, so long as funds were used consi

FAQs

What is the baseline liquidation period for timely obligations after the carryover/Tydings period?

Obligations may be liquidated for up to 120 days after the carryover/Tydings period without requiring Department approval.

How can a grantee obtain an extension beyond the initial 120-day liquidation period?

The grantee must submit required information and obtain approval from the Department; the extension applies to allowable, timely obligated projects and is not automatic.

Can a State enter into new contracts related to ARP after September 30, 2024?

No. A State or subgrantee may not enter into new contracts (incur new obligations) relating to ARP after September 30, 2024.

Oct 15, 2026

Uploaded by Fahsai