ARP Revision letter

1. Dear Dr. Townsend,
Thank you for submitting North Carolina’s American Rescue Plan Elementary and Secondary School
Emergency Relief (ARP ESSER) State plan. Although the email is coming from a different address, this is
your former Title I program officer, Evan Skloot, and I am leading the review of your ARP ESSER State
plan. It is nice to speak with you again.
After reviewing North Carolina’s plan, we noted the items in the table below that require revision in order
to sufficiently meet the requirements outlined in the ARP ESSER State plan template. Please review these
items carefully. Unless otherwise noted, the State educational agency (SEA) should revise its plan
accordingly for each item in the table.
We are happy to schedule a call to discuss these items in more detail if that would be helpful. If so, please
provide a few times when you are available and we will work to accommodate your schedule.
We ask that you resubmit North Carolina’s ARP ESSER State plan within 5 business days. Please let us
know if you need additional time. Please submit both a red-lined/track changed version of your ARP
ESSER State plan that addresses the items below, as well as a clean version with an updated signature and
date that can be posted on the U.S. Department of Education’s (Department’s) website. Please submit the
revised plan to ESSERF@ed.gov, and copy me (Evan.Skloot@ed.gov) and your State mailbox
(NorthCarolina.OESE@ed.gov).
Finally, please note that the Department will follow up with each SEA separately regarding the
requirement to make information on the mode of instruction and student enrollment publicly available on
its website no later than June 21, 2021.
Best,
Evan Skloot
Evan Skloot
Education Program Specialist (PMF)
Office of School Support and Accountability
U.S. Department of Education
400 Maryland Ave. SW | Rm. 3W112 | Washington, DC 20202
Phone: (202) 453-6515 | evan.skloot@ed.gov
Requirement Feedback for State
A3. Identifying
Needs of
Underserved
Students
Section A.3. of the ARP ESSER State plan template requires the SEA to
describe its 2-3 highest priority needs related to the impact of COVID-19 for
each required subgroup. Although the North Carolina Department of Public
Instruction (NCDPI) provides data sources for each subgroup, it does not clearly
describe the 2-3 highest priority needs for students from each subgroup. Please
identify the highest priority needs for students from each subgroup.
Additionally, NCDPI references a “Youth Risk Behavior Survey” in footnote 8;
however, footnote 8 is blank. Please revise to include the correct footnote.

2. B1i. Support for
LEAs – COVID-19
Prevention Strategies
Section B.1.i. of the ARP ESSER State plan template requires the SEA to
provide a description of how the SEA will support its LEAs’ implementation of
prevention and mitigation practices in line with the most up-to-date guidance
from the CDC. While NCDPI provides documents that are responsive to the
prompt, NCDPI provides a link to its reopening guidance (“Lighting Our Way
Forward: North Carolina’s Guidebook for Reopening Public Schools”) and
public health toolkit (“Strong Schools NC Public Health Toolkit”). Please
submit either the entire document or relevant parts of these documents as
attachments to your State plan, rather than links.
B1ii. Support for
LEAs – Statewide
Reopening Plans,
Policies, etc.
Section B.1.ii. of the ARP ESSER State plan template requires the SEA to
describe any Statewide plans, policies, estimated timelines, and specific
milestones related to reopening and operation of school facilities. While NCDPI
describes documents that are responsive to the prompt, NCDPI provides a link
to a policy related to remote instruction plans (footnote 12) that appears to be
broken. Please submit this document as an attachment to your State plan, rather
than a link.
C1. Consultation Section C.1. of the ARP ESSER State plan template requires an SEA to describe
how it engaged in meaningful consultation with the required stakeholder groups.
NCDPI did not provide a response to this question. Please describe how the
SEA engaged in meaningful consultation with each of the stakeholders listed in
C1. of the ARP ESSER State plan template, as well as how the SEA
incorporated input into its plan. The description must also include how the SEA
provided the public the opportunity to provide input into the development of the
plan, a summary of the input (including letters of support), and how the SEA
took such input into account.
D1(i and ii). Impact
of Lost Instructional
Time – Evidence-
Based Interventions
and Address Student
Groups
Section D.1.i. and D.1.ii. of the ARP ESSER State plan template require the
SEA to describe how it will use the funds it reserves under section 2001(f)(1) of
the American Rescue Plan Act of 2021 (ARP) (totaling not less than 5 percent
of the State’s total ARP ESSER allocation) for activities to address the academic
impact of lost instructional time, and how such evidence-based interventions
will address the disproportionate impact of the COVID-19 pandemic on specific
subgroups of students listed in question A.3.i.-viii. NCDPI indicates on page 20
that it plans to allocate funds under this reservation to LEAs “based on need, as
demonstrated by the expenditure of existing federal funding received for
COVID-19 related impacts.” It is not clear that prioritizing LEAs to receive
reserved funds based on LEAs’ expenditures of existing Federal COVID-19
funding will ensure that students who were disproportionately impacted by
COVID-19 receive services. Additionally, NCDPI does not describe how it will
ensure that LEAs will use these funds for evidenced-based interventions that
address the academic impact of lost instructional time. Please describe how
NCDPI will ensure these reserved funds are (1) used for interventions that
address the disproportionate impact of COVID-19 on specific groups of
students listed in question A.3.i.-viii and (2) used only to address the academic
impact of lost instructional time through evidence-based interventions that
respond to the academic, social, emotional, and mental health needs of students.

3. D2(i, ii and iii).
Summer Learning –
Evidence-based
Interventions
Section D.2.i requires the State to describe how it will use the funds it reserves
under ARP section 2001(f)(2) (totaling not less than 1 percent of the State’s total
ARP ESSER allocation) for evidence-based learning and enrichment activities
during the summer. NCDPI indicates that it will use the reservation to fund a
grant to expand school extension and enrichment programs (i.e., summer
learning programs) that are required by the State and funded through other
sources once it has analyzed the outcomes of the Summer 2021 program.
Although no action is required at this time, NCDPI will be required to revise its
plan once it selects its evidence-based interventions.
D3(i and ii).
Afterschool
Programs –
Evidence-based
Interventions and
Address Student
Groups
Section D.3.i. and D.3.ii. of the ARP ESSER State plan template require the
SEA to describe how it will use the funds it reserves under section 2001(f)(3) of
the ARP (totaling not less than 1 percent of the State’s total allocation of ARP
ESSER funds) for evidence-based comprehensive afterschool programs, and
how such evidence-based interventions will address the disproportionate impact
of the COVID-19 pandemic on specific subgroups of students listed in question
A.3.i.-viii. NCDPI indicates that it plans to allocate funds under this reservation
directly to LEAs. However, it does not describe how it will allocate funds in
such a way that will ensure that students who were disproportionately impacted
by COVID-19 receive the services, or how it will ensure that LEAs will use
these funds exclusively for afterschool activities. NCDPI must describe how it
will ensure these funds are (1) used only for evidence-based comprehensive
afterschool programs that respond to the academic, social, emotional, and
mental health needs of students, and (2) address the disproportionate impact of
COVID-19 on specific subgroups of students listed in question A.3.i.-viii.
E1. LEA Plans for
Use of Funds
Section E.1. of the ARP ESSER State plan template requires the SEA to
describe what it will require its LEAs to include in the LEAARP ESSER Uses
of Funds plans consistent with the ARP ESSER requirements for the use of ARP
ESSER funds, as well as how the SEA will ensure such plans are made available
to the public and the deadline by which LEA plans are due to the SEA. While
NCDPI describes how it will require LEAs to include most of the required
information, it does not address E.1.iv, how it will require LEAs to ensure that
the interventions it implements respond to the academic, social, emotional, and
mental health needs of all students, and particularly those students
disproportionately impacted by COVID-19. Additionally, NCDPI does not
describe how the SEA will require LEAARP ESSER Use of Funds plans to be
made available to the public and the deadline by which each LEA must submit
its ARP ESSER plan to the SEA. Please provide a description that addresses
these requirements.
E2. LEA
Consultation
Section E.2. of the ARP ESSER State Plan template requires the SEA to
describe how it will ensure that, in planning for the use of ARP ESSER funds,
each LEA engage in meaningful consultation with stakeholders, as well as
provide the public the opportunity to provide input on its plan for use of ARP
ESSER funds and take such input into account. While NCDPI indicates that it
required each LEA to post its ESSER II plan for 30 days, and that the SEA will
host public engagement events, NCDPI does not describe how it will ensure that
each LEA will meet the stakeholder consultation requirements for its ARP
ESSER Use of Funds plan, as well as provide the public the opportunity to
provide input in the development of its plan and take such input into account.
Please provide a description that addresses these requirements.

4. Description for
Section 427 of
GEPA
As described in Appendix D of the ARP ESSER State Plan template, section
427 of the General Education Provisions Act (GEPA) requires each applicant for
Federal education funds to include in its application a description of the steps it
proposes to take to ensure equitable access to, and participation in, its Federally
assisted program for students, teachers, and other program beneficiaries with
special needs. NCDPI does not provide a description of how it is meeting this
requirement. Please provide a description to address this requirement.