Tennessee opens revised ARP ESSER and ARP Homeless liquidation-extension process; first submissions due May 30

The Tennessee Department of Education on April 15 opened a revised application process in ePlan for late liquidation-extension requests for ARP ESSER and ARP Homeless funding and asked local education agencies (LEAs) to submit initial requests by May 30.

The change follows a March 28 letter from the U.S. Department of Education that rescinded prior automatic acceptance of late liquidation extensions and requires states to resubmit or reconsider requests on a project-by-project basis. The state said it will review LEA submissions and forward them to the federal agency for final action.

Debbie, a Tennessee Department of Education staff member, said, "The department has to make the request. We are the kind of that first line of review prior to it being able to be submitted." Julia Hudson, Tennessee Department of Education staff, explained that the revised instrument in ePlan is live under fiscal year 2026 and that LEAs can copy prior fiscal-year details into the new form: "you can copy over your information from the previous fiscal year." Debbie added the timeline: "We opened it today on April 15, and we will be asking that everyone submit their first submission to us no later than May 30."

What changed and how LEAs should apply LEAs should log into ePlan, select fiscal year 2026 and open the ARP ESSER liquidation-extension request or the ARP Homeless request (both instruments are now present). The instrument allows applicants to copy prior fiscal-year entries, but both capital and noncapital projects require new, additional information specified in the revised form.

Key documentation and fields required - Amounts liquidated: LEAs must enter the amount liquidated as of March 28, 2025 (previous instruments used a Sept. 30 snapshot). If a district received reimbursements after Sept. 30, that will affect the March 28 value. The instrument will auto-calculate any amount to be released. - Vendor names: contracts and purchase orders tied to projects must list vendor names (the state recommended creating one line per vendor for multi-vendor programs such as high-dosage tutoring). - Justification and project-level descriptions: for each project applicants must provide a justification explaining why the U.S. Department of Education should exercise its discretion to approve the extension and describe how the extension is necessary to mitigate COVID’s effects on student learning; this is required for every listed project. - Capital projects: for each capital project applicants must provide the project location, a brief description, the percentage completed and an explanation of that completion status. - Supporting documents: previously uploaded documentation for projects already in ePlan should carry over; new projects will require uploaded supporting documents (purchase orders, contracts, proof of delay) that are legible and clearly labeled.

Deadlines, approvals and reimbursements Tennessee will collect submissions on a rolling basis but asked LEAs to provide an initial submission no later than May 30 so the department can batch and forward requests to the U.S. Department of Education. The state emphasized that its approval and submission do not guarantee federal approval; the U.S. secretary of education and federal reviewers will make the final determinations and may spot-check or return items for clarification.

The department clarified reimbursement status: ARP ESSER reimbursement requests submitted between March 4 and March 28 that were accepted and paid do not need resubmission. By contrast, all ARP Homeless requests must be resubmitted because, the department said, none of those were paid during that window.

Timing guidance and recommended planning State staff encouraged LEAs to choose realistic extension deadlines for each project. Although federal guidance permits approvals that could extend through March 2026, reviewers said they prefer realistic timelines tied to when work and services will actually be completed. Presenters recommended LEAs build 30–60 days of padding into an extension date to allow for invoicing and reimbursement processing rather than automatically selecting the maximum liquidation end date.

Assistance and next steps The state posted revised slides, a new FAQ and direct instructions under the TDOE resources section for relief and spending (the revised ARP ESSER liquidation-extension materials are in the ePlan resources). TDOE staff will hold office hours and said the webinar was recorded and will be distributed. LEAs may update or resubmit applications as needed; the department said it will work with districts if projects are initially disapproved by the U.S. Department of Education and may assist districts in moving expenditures among allowable funding sources.

Questions raised by LEAs During the webinar LEA attendees asked whether completed and already-reimbursed projects should be removed (yes), whether allocation amounts on older forms should match the new instrument (they generally should; the state will verify any discrepancies), and how many vendor lines to submit for multi-vendor programs (the state advised separate lines per vendor). District-specific reimbursement questions will be followed up individually by department staff.

The state urged LEAs to use the release-of-funds form if they choose not to reapply for any remaining dollars and reminded attendees to ensure contact fields (director of schools, ESSER/ARP contacts) are accurate because the department will use those contacts for follow-up.

The webinar concluded with an offer of follow-up support from TDOE staff and scheduled office hours to walk districts through the instrument and address individual questions.