A catchy article about SNS – Supplement Not Supplant, Sorry Not Sorry written by Marguerite Roza, a research professor at Georgetown University, appeared in early 2019. As many of you are aware, the education field is often dominated and defined by acronyms: NCLB, ESSA, ESSERF, ESEA, RFP, and on and on. Dr. Roza described the SNS text as an appropriate fit for Supplement Not Supplant. Text messages by our youth may contain SNS connoting “sorry not sorry.” Young people may use this phrase when they know they might upset another person with their actions but aren’t actually sorry enough to change their plan. When we examine the changes of Supplement Not Supplant, we might also think of SNS: Sorry Not Sorry.
Definitions and Explanations
Let’s examine SNS: Supplement Not Supplant. It is a regulation requiring school districts receiving federal funds from replacing state, local, or agency funds with federal dollars. Consider the definition of supplement, which means something that completes or makes an addition. Supplant means to supersede and replace. When using funds for an educational project, existing funds may not be displaced (supplanted) by federal funds and reallocated for other organizational expenses. Rather federal agencies encourage adding federal funds to what is available in state, local or agency funds (supplementing). An example might be an educator paid by local sources. That position salary could not be transferred to federal grant funds. In that case, it would be supplanting. To illustrate the concept of supplementing, think about an existing program that has received federal funds. Perhaps the program needs enhancements by updating print or software materials to improve the quality of the student achievement. The school district has clearly articulated how federal funding “builds upon” these materials for the program.
History of SNS
For years, state and local decision makers followed the requirement that grantees may not use Title I funds to replace state and local investments. Then the Every Student Succeeds Act (ESSA) happened and conversations emerged about a change to the SNS requirement. Some school administrators remain in a holding pattern while others continued to apply the technical and methodological way they have always used to ensure compliance. In January 2019, a significant modification in a clarifying document was released by the U.S. Department of Education. Later in June 2019, the U.S. Department of again issued a statement about guidance on supplementing, not supplanting. This guidance promoted effective spending and flexibility.
Federal Program Directors Call to Action
David DeSchryver, a senior Vice President and Director of Research at Whiteboard Advisors, issues a call to action for “grant managers and school leaders to tell better stories about how they are using Title I, along with state and local funds, to improve educational opportunity for at-risk students.”
Instead of examining every item purchased with Title I to ensure compliance, districts now need to “demonstrate that the methodology used to allocate State and local funds to each school receiving Title I ensures that such school receives all of the State and local funds it would otherwise receive if it were not receiving [Title I, Part A funds].” In other words, the new rule, unlike the old one, ensures that districts cannot “backfill” state and local money with Title I dollars in a Title I school. The particular investments that school leaders make with Title I are not critical so long as the costs support the intents and purpose of Title I, Part A for eligible students…Now, all Title I schools, both schoolwide and targeted assistance, benefit from the flexibility. Under NCLB, most schools parsed out core instructional investments from supplemental investments because that’s what Title I has encouraged. That’s no longer necessary. Eligible schools can more easily use Title I to support strategic school-wide investments so long as the Title I contribution benefits eligible students. Should a school want to invest in personalized learning programs that are adaptive to the unique needs of each student, Title I is now part of the conversation, not a barrier to it.
With increased flexibility and effective spending, we are in a time where the days of regulatory uncertainty are, and should be, behind us. There are no traps to navigate. This should signal our leaders of school districts that we are in a new era to improve educational opportunity for at-risk students. Sadly, many good ideas for student services and programs still suffer under bureaucratic decisions. So even with the call to action to move forward, some view these sources as not legally binding and may still be stuck in, “sorry, not sorry.” As educational solution providers, you can be part of the meaningful and effective programming. Encourage and move school leaders forward to spend their funds effectively and flexibility to better meet the needs of our students.
Next Funding Wave: SNS and CARES Funding
As we enter this new era of SNS, suddenly comes COVID-19 and the Coronavirus Aid, Relief, and Economic Security (CARES) Act of March 2020 follow it. Congress set aside approximately $13.2 billion of the $30.75 billion allotted to the Education Stabilization Fund through the CARES Act for the Elementary and Secondary School Emergency Relief Fund (ESSERF). These grants are awarded to State educational agencies (SEAs) for the purpose of providing local educational agencies (LEAs), including charter schools that are LEAs, with emergency relief funds to address the impact of COVID-19 on elementary and secondary schools. ESSER funds are allocated in the same proportion as each State received funds under Part A of Title I in fiscal year 2019. Although these funds are being distributed within states according to existing district Title I allocations, do not confuse them with Title I. They are not Title I.
A major difference between these funds and Title I is no supplement not supplant provision. ESSERF does have a maintenance-of-effort requirement, but it also has a waiver option for this for places where state and district revenue for schools cannot remain at prior levels.
A statement from the U. S. Department of Education’s Frequently Asked Questions clearly underlines SNS for the ESSERF.
Are ESSER funds subject to a supplanting prohibition? No. The ESSER Fund does not contain a supplanting prohibition. As a result, ESSER funds may take the place of State or local funds for allowable activities. However, the program does contain a Maintenance of Effort (MOE) requirement, which is designed to keep States from substantially reducing their support for K-12 education
Since the CARES Act grant has no SNS clause, it becomes an Unrestricted Federal Grant. Once again, the message for the use of these funds is flexibility. Always remember when thinking about using federal funds, prudent cost principles should be applied. Costs should be:
- Reasonable: consistent with business practice and comparable current market value
- Necessary: required to carry out the intent and purposes of the program
- Allocable: costs should benefit the program.