COVID-19 Finance Questions and Answers

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May districts be reimbursed for transportation costs associated with delivery of meals and/or instructional packets?

Route expenditures include those associated with transporting students from home to school, school to school, and school to home. These expenditures are reimbursable expenditures through the CDE-40 transportation reimbursement process.

During this period when in-person learning has been suspended, the delivery of instructional packets is simply an alternative form of route transportation. Therefore, delivery of instructional packets is considered a route expenditure. This is true if instructional material and meals are being delivered with the instructional materials. Delivery of only meals to students is not considered a route expenditure.

The following outlines how to track supporting information for various scenarios:

Delivery of Instructional Materials to Students or Delivery Instructional Materials and Meals Simultaneously to Students

• Driver salaries and benefits are treated as a route expenditures and can be claimed as a direct cost
• Miles can be claimed as route miles

Delivery of Meals to Students

• Driver salaries and benefits can be claimed on a pro-rata basis based upon the district's percent of route mileage to total mileage
• Miles cannot be claimed as route miles, include these miles as admin miles. Districts will need to apply a reasonable cost per mile (e.g. 20 cents per mile for small vehicles and 59 cents per mile for school buses) to these miles and reduce this amount from prorated costs.

No Transportation Performed

• Driver salaries and benefits can be claimed on a pro-rata basis based upon the district's percent of route mileage to total mileage
• No miles are being incurred
• Districts or charter schools who contract with service providers to transport students for routes may be contractually obligated to pay whether students were transported or not. These expenditures can be claimed as a direct cost

Fuel expenditures will continue to be claimed as a prorated cost in all of the above scenarios.

Will districts receive less in transportation reimbursement because they transported students fewer days during the 2019-20 school year?

Given that all districts experienced similar reductions to the number of school days, we do not anticipate a change to the level of funding to be distributed to districts as a result of the pandemic.

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How do districts code revenue and costs associated with emergency feeding (grab-n-go/curbside meals)?

Reimbursement rates for these meals can be found at: Reimbursement rates for Summer Food Service Program.  

The related expenditures should be coded under Program Code 3100 – Food Service Operations. 

Note:  A grant code is not required for expenditures coded to the Food Services Fund.  Therefore, if you wish to isolate the COVID activities from the normal activities, please use SRE Code 94.  You may also wish to use the SRE Code 94 as a method to isolate the emergency feeding revenue from the normal revenue reported under the same grant code.

Please visit the School Nutrition Unit – How to Claim page for more information.

School Nutrition Grant Codes

Do districts still need to submit meal reimbursement claims within 60 days?

Claims for reimbursement are required no later than 60 days following the last day of the full month covered by the claim, unless otherwise authorized by CDE. CDE expects that districts will continue to make timely claims submissions to the greatest extent practicable. However, the USDA recognizes current challenges may delay the submission and/or adjustment of claims for reasons falling beyond the local agency's control. Contact CDE for any exceptions.

Please note that All March claims are coming from the CARES Act Funding.  If you have already received reimbursement for March claims, and have coded differently than what is shown above, please change the codes accordingly.  We apologize for this inconvenience and any confusion on the previous guidance given around grant codes

How does a district record donations to help pay for emergency feeding costs?

Monetary donations must be deposited outside of the Food Service Fund (e.g. the General Fund) and then transferred into the Food Service Fund as needed.

If a district receives a food donation, this can be recorded in the Food Service Fund. Districts should record the monetary value of the food donation at fair market value, using source code 1920 and object code 0630.

Can a district offer meals to Emergency Feeding volunteers?

Districts may serve meals free of charge to staff and volunteers directly involved with the Emergency Feeding operation. All other adult meals being served cannot be covered by the Food Service Fund. Districts should use the General Fund to cover the cost of these meals.

Should districts request that families update their free and reduced lunch status at this time?

Districts can promote families to re-apply for free/reduced meal benefits if families have experienced changes to their income as a result of COVID-19. More accurate free/reduced (F/R) percentage data can affect school nutrition programs in the following ways:

1. Additional sites across the state could become eligible for emergency feeding. The state currently has an eligibility waiver, but sites under 50 percent F/R eligibility must still describe how they are targeting students that qualify for F/R meals. Sites at 50 percent or higher are automatically eligible for emergency feeding.
2. Once emergency feeding is no longer allowable and districts move into the summer, the ‘normal' Summer Food Service Program can resume across the state. Additional sites across the state could become eligible if their F/R rate changes.
3. Once districts are utilizing remote learning, they have the option to continue with emergency feeding or resume normal breakfast/lunch programs. If they choose to go back to normal breakfast/lunch programs, then they would need to be utilizing the free/reduced/paid categories again. Districts would want to be sure these were accurate to best meet the needs of their students and families.
4. Rural districts across the state may qualify for a new program calledMeals to You. The meals are only delivered to students that qualify for free/reduced meals. Students that fall under the ‘paid' category miss out on this meal program. Those districts that choose this option would want to ensure they are using accurate data to best meet the needs of the families they serve.

This decision is a local decision. There is no requirement to have families re-apply. This is an option if a district feels it would be helpful to their programs and their community.

Are there additional funds available to assist with the costs associated with feeding students?

The Colorado Education Initiative (CEI), in collaboration with CDE, administered a needs inventory. Responses will help CEI and CDE target local, regional and statewide support and will be shared with donors and others who can help meet your needs. Additionally, funding will be available for education and potentially child nutrition programs through the federal CARES Act. More information will be provided on these funding sources as they become available. Other funding sources specific to feeding students include:

• No Kid Hungry Coronavirus Grant
• CO COVID-19 Emergency Hunger Relief Fund

Who should districts contact if they have specific questions related to emergency feeding and school nutrition programs?

Questions related to emergency feeding or school nutrition programs should be directed to: [email protected]

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The Governor's Executive Order D 2020 021 suspended the provision in the READ Act that a local education provider may retain up to 15% of the per-pupil intervention money for use in the next budget year. What does this mean?

Section II of Executive Order D 2020 007 is amended to include the following:

K.: I temporarily suspend the provisions in C.R.S. § 22-7-1210.5(6)(b) that a local education provider may retain up to fifteen (15) percent of the amount of per-pupil intervention money it receives in a budget year for use in the next budget year, and that CDE shall reduce the amount of per-pupil intervention money that the local education provider is eligible to receive in the next budget year by the excess retention amount.

This section of the Executive Order suspends the provisions in C.R.S. § 22-7-1210.5(6)(b) which restricts districts from carrying over more than 15% of unspent READ per pupil intervention funds from one budget year to the next. This action will enable districts to carry over unspent funds from the 2019-20 budget year to the 2020-21 budget year without penalty.

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The Governor's Executive Order D 2020 021 suspended the requirement of C.R.S. § 22-54-129(4) which pertains to per pupil revenue (PPR) billing for approved facility schools through April 30th. What does this mean?

Section II of Executive Order D 2020 007 is amended to include the following:

J.: I temporarily suspend the requirement in C.R.S. § 22-54-129(4) that an approved facility school or a state program shall report to CDE the number of full-time equivalent students to which the approved facility school or state program provided such services.

This waiver provides flexibility to the manner in which the state allocated funds for approved facility schools are distributed. In an effort to sustain approved facility schools and the educational services and programs they provide, CDE will ensure each site receives the daily PPR for the months of March and April, 2020. The Governor's Executive Order is in effect through April 30, 2020. As that date approaches, CDE leadership will assess the situation and work with the Governor's Office to determine whether an extension should be recommended.

The department requests that approved facility schools continue to submit student counts and number of days to CDE using the existing process for PPR payments in March and April, 2020.

In addition, CDE requests facility schools submit the number of students with disabilities and days served for the month of April, 2020 as well as the tuition cost payments received for these services. This will allow CDE to track the impact that suspension of normal in-person instruction due to the presence of coronavirus disease 2019 has had on tuition cost payments received by approved facility schools.

Facility schools have moved to remote learning for many students and continue to provide in-person services for other students. School districts must continue to pay the tuition cost rate to facility schools for providing services, whether through remote or in-person instruction for special education students.

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What does the Executive Order on property tax collections mean for school districts?

Below is some explanatory wording from the Governor's Office to clarify the currentExecutive Order D 2020 012 (see section II, subsection I at the bottom of page 3/top of page 4):

The governor is doing everything he can to help businesses during the COVID-19 crisis.

Property owners have always had a choice under the statute to either pay half of their property tax in January and the other half by June 15, or pay the entire tax amount by April 30. The deadline for property owners to pay their property tax in one installment is the last day in April (April 30).

Current law allows taxpayers to split their property tax right now, with the second payment due June 15. Without the executive order, the first half would accrue interest dating back to February. With the executive order, the first half can be paid as late as April 20 without accruing interest.

Some county treasurers want to waive interest longer. We have reached out to let them know the governor's authority to waive interest (a statutory requirement) in an emergency only extends 30 days.

We have been engaged with CASE and looking closely at school district cash flows from the beginning of this discussion. We understand that school district fiscal years, unlike those of other local governments, end in June.

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What coding should a district/charter school use if they wish to track all activities related to COVID-19?

The Financial Policies and Procedures (FPP) Committee Membership has approved setting aside and using SRE code 94 for the tracking of declared emergency (such as COVID-19) activities.  This is an optional code for the districts/charter schools that want a method to track any and all activities (revenue and expenditures) related to COVID-19.  

The use of an SRE code does not impact the use of any other account code, such as grant codes.  The one exception is if the district is already using the ‘Consolidated School wide Program’ SRE code of 95.  In that case, the district will need to determine if the activity is more appropriately tracked under the Consolidated School wide Program code of 95 or under the use of SRE 94 for declared emergency tracking.

How should districts track the non-reimbursed costs related to the COVID-19 pandemic during FY 2019-2020?

Building off the work of the previous sub-committee on the 2014 flood costs that impacted school districts. we are recommending the following for the non-reimbursed COVID-19 cost impacts:

• Specific fund use not required – most districts will probably report in fund 18 for risk management.      
• Districts may apply the optional program code 5200 to expenditures for tracking such activities.  The use of this program code would be reported as “other source (use)”, for districts that believe they should be reported in such a manner.  Program code 5200 will be relabeled from ‘Flood Impact’ to 5200 – Non-reimbursed Emergency Cost Impact.      
• Reporting as an extraordinary item will be determined by each individual district/charter school and their auditor.

How should districts track grants related to the COVID-19 pandemic during FY 2019-2020?  

Specific State and/or Federal grant codes will be assigned as they become available.

Reimbursable costs under a State and/or Federal grant program may be reported in the fund normally used by the district, such as the food service activities noted below.  The appropriate program code (such as instructional and/or support) should be used for reporting such State and Federal grants.

If a district is eligible for any Federal grant funding, such as FEMA, they must ensure that they adhere to all requirements and regulations related to procurement and proper documentation under the Uniform Guidance.

For the curbside food service being provided by many school districts, per the School Nutrition Unit at CDE, that activity should be captured and reported as part of the Summer Food Service Program for Children under grant code 4559 in the food service fund (Fund 21).

• In addition, per the USDA guidance, there is no additional reimbursement for home delivery or mobile meals delivery, but related expenditures, such as delivery service fees, would be considered an allowable cost under this program.·        
• Delivery costs could also be paid with non-program funds such as State or local funds or private donations, but these non-program activities would be captured outside of the food service fund (Fund 21).

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Can districts use the TABOR 3% Emergency Reserve for COVID-19 related expenditures in FY 2019-20?​

Yes. Pursuant to TABOR: "To use for declared emergencies only, each district shall reserve… 3% or more of its fiscal year spending…. Unused reserves apply to the next year's reserve." Art. X, § 20 (5).

• Districts and other political subdivisions have the authority to declare an emergency for purposes of accessing TABOR reserves.
• The Governor has declared a state of emergency under § 24-33.5-704 (4), C.R.S., for responding to COVID-19, which is sufficient for the State to access its own emergency reserve under § 24-77-104, C.R.S.
• Whether it is sufficient for a district to access its TABOR reserve is a question of district fiscal policy.
• If it is determined that the district may use some or all of its TABOR reserve, the district must ensure that it has the spending authority as well.
• If the district is already including the TABOR reserve within its appropriation resolution, they should be fine.
• If not, the local board would need to approve a supplemental budget to provide for such additional spending authority.
• Districts would likely also need a resolution on the use of beginning fund balance.

What else should districts take into account when considering the use of the TABOR Emergency Reserve?

Districts and charter schools should evaluate any potential related accounting determinations, consistent with GASB guidance, including, but not limited to:

• Timing of expenditures from the emergency reserve if the declared emergency crosses into FY2020-21
• Timing of accounting transactions for replenishment of the reserves

School districts and charter schools should seek their own legal counsel on the possible application of the provisions under § 22-44-105 (1)(c.6), for replenishment of the TABOR 3% Emergency Reserve.

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For more information on finance related topics, districts may contact the following individuals: