School building

Public schools across the United States received additional federal COVID-19 relief funding through the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), signed into law on Dec. 27, 2020. The CRRSAA provides an additional $54.3 billion for the Elementary and Secondary School Emergency Relief Fund (ESSER II). Allowable expenditures under the CRRSAA are similar to eligible uses under the Coronavirus Aid, Relief, and Economic Security (CARES) Act (i.e., ESSER I), however this additional round of funding also allows for expanded uses and timing. 

CARES Act funding initially provided to schools allows for allocations to be used toward preventing, preparing for and responding to COVID-19. CRRSAA funds can also be used to cover such costs dating back to March 13, 2020, when the national emergency was initially declared. Additionally, eligible uses for ESSER II include addressing learning loss, preparing schools for reopening, and testing, repairing and upgrading infrastructure to improve air quality in school buildings.


Specific examples of allowable CRRSAA capital and operating costs could be:

  • HVAC/mechanical repairs and/or upgrades
  • Education and assessment technology
  • School facility repairs to limit health hazards
  • Activities allowed under other federal programs
  • Coordination activities with local health department in response to COVID-19
  • Academic resources to support individual student needs
  • Mental health support
  • Summer school programs
  • Purchase of and training for sanitation/cleaning materials


An important distinguishing characteristic of the CRRSAA funds is timing when funds must be obligated. The CARES Act has an obligated deadline of Sept. 30, 2022, whereas the CRRSAA obligation deadline is one year later, Sept. 30, 2023. 

How should schools prioritize funding allocations?

Relief funding from the federal governments through the CARES Act and CRRSAA should be viewed as one-time distributions. Consider the timing requirements and eligible uses for both ESSER I and II funds as you plan expenditures:

  • With the shorter duration of when funds can be expended, CARES Act funding should focus on the costs aligned with preparing for and preventing COVID-19.
  • CRRSAA funding, with the expanded use and timing allowances, can have an academic and/or operational focus.

Districts should leverage internal processes and proven communication methods to evaluate how these funds should be used to best address student, faculty and staff needs. School districts with limited cash reserves may want to consider using these funds to supplement budgeted costs to strengthen cash reserves in the short-term as long-term strategies are developed to increase balances. School districts with limited capital resources may want to strongly consider using these funds toward capital needs.

What should you do to prioritize use of federal funds?

Consider the following:

  • Identify organizational impacts that have occurred or are anticipated to occur
  • Identify current or anticipated costs that align with the allowable uses above
  • Understand the compliance requirements associated with any funds expended (i.e., single audit requirements)
  • Determine how this funding fits into your organization’s current and future financial plan and what it means for your school community


There are additional accounting and compliance factors to consider related to CARES Act and CRRSAA funds, including:

  • These funds are required to be accounted for separately.
  • Federal compliance audit (i.e., single audit) determination may be impacted. If the district currently receives less than $750,000 annually without CARES Act and CRRSAA funding, the additional ESSER distributions may require the district to complete a federal compliance audit. 

As a best practice, maintain your internal controls and develop documentation for grants and expenditures to ensure proper reporting and continued compliance with federal and state accounting requirements.

Lean on Baker Tilly as your Value Architects

The mission of our public sector practice is to help you build strong communities. We continue to monitor the latest information on the funding packages, what is being proposed and how we can partner with you to navigate through the complex compliance requirements and strategize how to maximize your funding sources. Lean on us as your Value Architects™ to protect and enhance your organization’s assets. You can count on our experience from the previous rounds of COVID-19 funding to assist your school district.

Please visit our Coronavirus Resource Center for current and comprehensive news, programs, insights and other information to assist schools with the organizational and community impact of this pandemic.

For more information, or to learn how Baker Tilly's school districts specialists can help, contact our team.

Brock J. Bowsher
Bird's eye view of a college campus
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