Letter to the Hon. Miguel Cardona, Secretary of Education - Manchin Urges Administration to Implement $800 Million Fund to Support Children and Youth Experiencing Homelessness

Letter

Dear Secretary Cardona:

Thank you for your commitment to working with us on implementation of the $800 million in K12 funding from the American Rescue Plan Act (ARP; P.L. 117-2), reserved for identifying children and youth experiencing homelessness. These funds are critical to supporting an underserved population and will provide them with the wrap-around services and assistance needed to succeed in school and participate fully in school activities.

Every Member of the Senate joined us in adopting the bipartisan amendment because they recognized the devastating impact the COVID-19 pandemic has had on children, youth, and families experiencing homelessness. Prior relief funds have not served these students effectively. In a survey of 1,444 school district homeless liaisons conducted by SchoolHouse Connection and the University of Michigan in September and October of 2020, only 18 percent indicated that CARES Act funds were being used to support homeless children and youth. In addition, an analysis conducted by the Center for Reinventing Public Education found that only 17 percent of the districts' COVID-19 plans they analyzed described strategies to support homeless students, "signaling that these students are not being prioritized for assistance." Consequently, one in four homeless children and youth (420,000 homeless students) have gone unidentified and unenrolled in public schools. These students are disproportionately students of color, English learners, and students with disabilities; homeless children and youth in our tribal and rural communities have also been left behind. Without dedicated funding, these populations have not received the support they need from our education system. At the same time, children, youth, and families experiencing homelessness also have faced barriers in accessing COVID-19 relief funding from other federal agencies due to differences in definitions of homelessness, priorities, and the system used to disburse funds.

The formula for allocating funds to state and local educational agencies, the uses of funds, and the timing of awards are of great importance to us as you work to implement the awarding of these funds, and we appreciate the opportunity to express our priorities. Of particular concern is the use of funding at both the state and local levels to identify and engage children and youth experiencing homelessness. The drop in the number of homeless students who have been identified by their school districts is an alarming crisis that must be prioritized with all Elementary and Secondary School Emergency Relief (ESSER) funds. Further, State Education Agencies (SEAs) and Local Education Agencies (LEAs) must prioritize finding youth and families experiencing homelessness in order to help them access summer school, afterschool programs, mental health support, and all the other resources provided through the ARP and prior COVID-19 relief legislation. Identifying students and providing them access to services will require increases in staffing and support, such as communication devices and transportation.

We also want to make clear our intention that these funds should be administered by the Office of State Coordinator for the Education of Homeless Children and Youth (EHCY), typically the only SEA office with knowledge of, and experience with, assisting communities to identify and serve children and youth experiencing homelessness, and ensuring their rights under the McKinney-Vento Act. Therefore, we request that the Department of Education (ED) clarify that these funds must be administered by the EHCY State Coordinator and require SEAs to ensure the full inclusion and involvement of LEA homeless liaisons in decisions about use of funds at the local level. Partnerships between SEAs, LEAs, and community-based organizations are vital to ensuring wrap-around services for homeless children and youth.

Rural and tribal communities and communities of color have been disproportionately impacted by the COVID-19 pandemic. Tribal communities experience housing conditions that are substantially worse than for other U.S households; therefore it is essential that tribal consultations take place to ensure the best path forward for tribes to receive targeted funds. Rural communities have unique transportation and technological needs that make it difficult to identify and provide services to children and youth experiencing homelessness. As such, these communities must remain part of the conversation so their needs are fully understood. Across every measure -- health, employment, housing, and education -- the pandemic has taken a disproportionate toll on communities of color. In light of the disparities for rural and tribal communities and communities of color, we urge ED to prioritize equity in its directives and guidance, and assist SEAs in providing specific support to these communities.

In addition, children and youth experiencing homelessness need comprehensive, wrap-around services in order to recover from the loss and disruption caused by the pandemic. For these reasons, we ask ED to encourage flexible use of funds beyond what is typically allowed through the EHCY program, and make clear that SEAs and LEAs are encouraged to partner with community-based organizations through grants or contracts where it is advantageous to do so. Relatedly, it was our intention that these dedicated dollars supplement, not supplant funding provided by ESSER, and be coordinated with those funds to maximize their reach and impact.

Finally, we recognize the tension between the urgent needs that exist now and the imperative of planning for thoughtful, strategic use of funds over the next school year when we expect to see even greater levels of homelessness and student need. For this reason, we strongly encourage ED to explore a number of options for distributing these funds to ensure that both the immediate and larger, long-term needs are met. We strongly encourage ED to allow SEAs to provide subgrants by formula directly to the LEAs on the front lines, including those that have been unable to receive McKinney-Vento subgrants due to low funding levels. Any formula should take into account/not disadvantage rural LEAs that have great need, but low numbers of identified homeless students.

Thank you again for your commitment to working with us, and to ensuring that the dedicated homeless education funding in ARP is implemented with fidelity to promote equity, access, and support for some of our nation's most vulnerable students. We look forward to working with you to lay the groundwork for systemic changes in how communities respond to child and youth homelessness in the future.

Sincerely,