3.     Are subgrantees permitted to operate 21st CCLC programs during times that schools are closed?

All 21st CCLC subgrantees should adhere to internal guidelines established by their Local Educational Agency (LEA) or parent agency (non-LEAs) when establishing procedures for 21st CCLC program operation.

6.     Will 21^st CCLC subgrantees be allowed to pay staff during the time that schools and programs are closed?

Yes. Georgia 21^st CCLC programs may continue to pay staff for their efforts during program closures. All subgrantees should exercise good-faith efforts for developing alternate work strategies for staff during extended program closures. Staff should be assigned projects and activities related to program planning and aligned with approved grant objectives.  Subgrantees must maintain detailed work logs to document staff activity and should continue to pay employees in a manner consistent with established LEA or agency (Non-LEA) policies for program operation and employee compensation. Examples of allowable staff activities include:

·      Virtual Professional Development Sessions

·       Data Entry for Administrative Purposes 

·       Virtual Program Management Duties

·       Virtual Programming for Students

·       Lesson, Curriculum, or Evaluation Planning

·       Tasks deemed reasonable and necessary as associated with 21st CCLC job duties

Grantees must maintain appropriate records and cost documentation as required by 2 CFR § 200.302 - Financial management and 2 CFR § 200.333 - Retention requirement of records to substantiate the charging of any salaries and benefit costs related to interruption of operations or services. However, there will not be additional 21st CCLC funds allocated to support additional staff requirements.

7.     May subgrantees conduct virtual 21^st CCLC learning activities for students outside of normally scheduled hours of operation during extended periods of program closure?

All 21^st CCLC subgrantees should adhere to the hours of operation detailed within the approved grant application. If, however, subgrantees are able to add additional hours to those in the approved grant, they may only add hours to make up those that have been lost due to the extended periods of program closure.  Any such additional hours should address the approved program goals and objectives and not overlap with or otherwise interrupt local school programming occurring during the regular school day.

·      No. Lesson plans are not considered detailed work logs.                Detailed work logs provide an hour by hour breakdown of tasks that an employee completed in planning for, or delivering services to students, or participating in virtual professional development.

·      Lesson plans may be used to supplement time documentation. Another example of supplemental documentation includes detailed agendas outlining an hour by hour breakdown of professional development activities.

The Georgia Department of Education (GaDOE) recognizes that extended program closures have impacted the ability of 21^st CCLC subgrantees to adhere to data collection deadlines. At this time, the US Department of Education has not waived data reporting requirements for 21^st CCLC programs.

The GaDOE is still awaiting guidance regarding annual 21APR data reporting guidelines. 21^st CCLC subgrantees currently operating virtual learning programs are requested to enter student program attendance data into the Cayen Data System.

Annual 21^st CCLC Survey Data:

Where feasible, subgrantees are encouraged to administer annual 21^st CCLC teacher, parent, and student surveys; however, additional guidance is pending regarding annual reporting requirements for survey data. 

21^st CCLC Subgrantee External Evaluation Procedures: Guidelines have not yet been amended for annual external evaluation requirements. Additional guidance regarding procedures for external program evaluation is forthcoming. Extended program closures will likely impact timelines for external evaluations. Subgrantees are encouraged to maintain communication with designated 21^st CCLC External Evaluators to ensure that updated guidance is shared when available.

10.  How should 21^st CCLC subgrantees document attendance for virtual program activities?

Program sites that are serving students virtually should keep attendance records in the Cayen Data System. Subgrantees providing virtual programming should set up new sessions for each activity being offered and label each session “Virtual-Activity". Days missed due to extended program closures and lower average daily attendance totals will not negatively impact 21^st CCLC subgrantees.

12.  Are 21^st CCLC subgrantees required to offer virtual programming for students?

21^st CCLC subgrantees should adhere to established internal Local Educational Agency (LEAs) and agency (non-LEAs) guidelines for program operation when establishing schedules for virtual learning opportunities. Virtual learning activities should align with objectives outlined in the subgrantee's approved 21^st CCLC grant application.

The GaDOE will waive the annual 15% carryover percentage limitation for FY20 Title, IV, Part B – 21^st Century Community Learning Centers (CCLC) subgrants.  21^st CCLC subgrantees are permitted to carryover all unexpended funds from FY20 into FY21.