Dear Colleagues:  

Last week I wrote about the broad outlines of the EANS program that is providing assistance to private schools in their efforts to meet the needs of their students due to the pandemic.  Today I’d like to continue with that topic but focus on the contents of the application that private schools need to complete to request EANS services and benefits. 

First, let’s look at the federally required content of the application.  Please note that the Governor of your state may add other elements to the application—this list is a minimum requirement as prescribed by EANS.   

  • The number of percentage of students from low-income families enrolled in the 2019-20 school year. 
  • Available free or reduced-priced lunch data; 
  • Scholarship or financial aid data; 
  • E-rate data; 
  • Other relevant data, such as provided to the SEA for state programs. 
  • If complete actual data is not available, data can be extrapolated. 
  • If data is not readily available, new or unnecessary data collection should be avoided: 
  • Use Census data; 
  • Use proportionality. 
  • Information regarding the impact of COVID-19 on the school. 
  • The emergency services being requested. 
  • Whether the private school received a PPP loan before 12/27/2020 and the amount of the loan. 
  • An assurance that the private school will not apply for or receive a PPP loan on or after 12/27/2020. 

    • Secondly, in the FAQs about EANS released by the U.S. Department of Education (ED), ED made clear that an entity that represents a group of private schools can apply on behalf of those schools.  Specifically, question C-3 asks if an SEA may permit an organization that has governing authority over a group of non-public schools to submit an application on behalf of its member schools.  The answer is “yes.”  The organization must clearly indicate for which schools it is applying and provide supporting data and other information requested on the application for any and all schools for which it applies. 

    Thirdly, if you are curious as to the amount of EANS funds that your state will receive, you can go to https://oese.ed.gov/files/2021/01/FINAL_GEERII_EANS-Methodology_Table_1.8.21.pdf for a state-by-state listing. 

    Finally, remember that the funds must be obligated within 6 months of the SEA receiving the funds, so the clock is ticking.  Anything you can do to prepare prior to receiving the actual application from your state will help with that timeline.  Also keep in mind that funds are considered “obligated” as follows: 

    If the obligation is for—   The obligation is made—
    (a) Acquisition of real or personal property   On the date on which the State or subgrantee makes a binding written commitment to acquire the property.  
    (b) Personal services by an employee of the State or subgrantee   When the services are performed.  
    (c) Personal services by a contractor who is not an employee of the State or subgrantee   On the date on which the State or subgrantee makes a binding written commitment to obtain the services.  
    (d) Performance of work other than personal services   On the date on which the State or subgrantee makes a binding written commitment to obtain the work.  
    (e) Public utility services   When the State or subgrantee receives the services.  
    (f) Travel    When the travel is taken.  
    (g) Rental of real or personal property    When the State or subgrantee uses the property.  
    (h) A pre-agreement cost that was properly approved by the Secretary under the cost principles in 2 C.F.R. Part 200, Subpart E—Cost Principles   On the first day of the grant or subgrant performance period.  


    A    ll the best, I hope that this information helps you prepare to complete the EANS application when it is available in your state.      As always, if you have any questions, please go to www.equitableservicesmdec.com and click on the “Ask Michelle” button.  

    Michelle L. Doyle 

    Michelle Doyle Educational Consulting