Sneak Preview: ED Updates MOEquity FAQ To Address Reliable Data
(The following was excerpted from a recent Thompson Grants 360 article.) The Department of Education (ED) recently updated its Frequently Asked Questions (FAQ) document concerning its maintenance of equity (MOEquity) requirements under the American Rescue Plan Act (Pub. L. 117-2) Elementary and Secondary School Emergency Relief (ARP ESSER) Program to clarify what data state educational agencies (SEAs) and local educational agencies (LEAs) can rely on when determining per-pupil funding for needy schools.
ED’s MOEquity requirements, detailed at section 2004(b) and (c) of ARP, ensure that if funding reductions are necessary, each SEA and LEA does not disproportionately reduce per-pupil funding for education in those LEAs and schools in the state with the highest percentages of students from low-income families. The MOEquity requirements differ from ED’s maintenance of effort (MOE) requirements, which are addressed in section 2004(a) of ARP and ensure that a state maintains overall financial support for elementary and secondary education and for higher education.
Specifically, MOEquity ensures SEAs do not disproportionately reduce per-pupil state funding to “high-need” or “highest-poverty” LEAs below their federal fiscal year (FY) 2019 levels. In addition, it requires that LEAs do not disproportionately reduce state and local per-pupil funding in high-poverty schools, nor disproportionately reduce the number of full-time-equivalent staff per pupil in high-poverty schools. Accordingly, if state or local funds are cut, the MOEquity provisions ensure that LEAs and schools serving a large share of students from low-income backgrounds do not experience a disproportionate share of such cuts in FYs 2022 and 2023, and that the highest poverty LEAs do not receive a decrease in state funding below their FY 2019 levels.
ED has updated certain responses in the FAQ, while adding some new questions and answers. One new question asked what enrollment data SEAs can rely on when determining their per-pupil amount for high-need LEAs and highest poverty LEAs for each fiscal year. The FAQ explains that SEAs may use the most appropriate available enrollment data for the applicable fiscal year, which could be the same enrollment data it relied on to appropriate or allocate state funds for the applicable fiscal year. These data may include, among other data, prior year enrollment data, projected enrollment data for the next fiscal year, an average of multiple prior years’ enrollment or some other enrollment formula established by the state.
(The full version of this story has now been made available to all for a limited time here.)
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