Vermont education officials scramble after federal "liquidation extension" letter imperils some ESSER reimbursements

Jill Brooks Campbell, deputy secretary of the Vermont Agency of Education, told the Senate Education Committee on April 10 that a federal letter released Friday at 5:03 p.m. put previously approved extensions of COVID-era grant reimbursements in doubt and imposed a shortened window for reimbursement requests.

The change matters because Vermont school districts and the state rely on three federal COVID-era funding streams — primarily ARP ESSER — to pay for interventions, summer programming and contracted services. Campbell said districts received about $256,000,000 in ARP-related funds overall and that, after accounting for earlier spending, state officials currently estimate between $10,000,000 and $16,000,000 in possible reimbursement exposure; the state itself has about $800,000 in incurred invoices that cannot be requested until a new waiver process is completed.

State officials described three groups of projects: (1) expenditures already submitted for reimbursement that the state may no longer be able to draw down, (2) activities that districts completed under previously approved federal extensions and have already paid to vendors, and (3) planned activities (for example summer programs or professional development) that were approved but not yet started and may be unable to proceed without a waiver.

Campbell said the agency and districts are preparing waiver requests but stressed that approvals are discretionary at the U.S. Department of Education. "I stood up, and I directly asked, can you please confirm for us that the COVID era funds will continue to be available for reimbursement for districts and for states? And she said unequivocally, 'yes. I can confirm that,'" Campbell said, recounting a meeting with Haley Sanon, an Office of Elementary and Secondary Education official. Campbell added that by Friday the department had issued a letter reversing that assurance.

Anne Bordenaro, director of federal programs, described the waiver criteria that the department is now emphasizing. Rather than asking only whether a cost was allowable under the original grant, reviewers must now evaluate how the project "mitigate[d] the harm of COVID-19 on American students" and make a case for why the secretary should use her discretion to allow an extension. That shift, officials said, requires districts to connect projects to reduced lost in-person student days or other measurable COVID-related harms.

Because the federal review will be concentrated at a small number of reviewers, and because approvals are discretionary, Campbell said Vermont will prioritize waivers that appear "airtight" and run workshops and office hours to help districts prepare stronger applications. The agency said it has recommended pausing contracted services where possible; Campbell said the Read Vermont Literacy Initiative's embedded coaches and other contracted work were paused last week, and staff advised districts to pause similar contracts while the waiver process is clarified. "We had to pause all contracted services," she said.

Officials said vendors have been generally understanding and that the agency is scheduling repeated workshops and office hours to help districts assemble the narrative and data that the department now requests. Campbell said the agency expects to refine the $10–16 million estimate after additional reconciliation with district submissions in the coming week.

The agency said next steps are to (1) complete a refined accounting of exposures, (2) help districts prepare and submit waiver requests as swiftly as possible, and (3) monitor federal signals about timing and approvals. Officials emphasized that final outcomes rest with the secretary of education and that the timeline and criteria remain uncertain.