Frequently Asked ARP-HCY Questions and Answers

This page contains responses to common ARP-HCY questions.  This page will be updated periodically as the Department fields additional questions about the implementation of the ARP-HCY program.  (The dates in parenthesis after each question indicates the date that the question and corresponding response were added to this webpage.)  If you have a question about the ARP-HCY program, please contact the Department’s program team at


Questions About ARP Homeless I funds awarded to State educational agencies on April 26, 2021

Which provisions of the Education for Homeless Children and Youths (EHCY) program apply to the ARP Homeless I funds disbursed on April 26, 2021?

(Date published: May 2021)

The ARP Homeless I funds were released as a supplement to States’ EHCY grants. Accordingly, all of the provisions of the EHCY statute (Title VII-B of the McKinney-Vento Homeless Assistance Act) apply to the ARP Homeless I funds.


Does the ARP’s maintenance of effort requirement in section 2004(a) apply to the ARP Homeless I funds?

(Date published: May 2021)

Yes. A Maintenance of Effort update is available at


What provisions of the ARP do not apply to ARP-HCY?

(Date published: May 2021)

The requirements in section 2001(c)-(i) do not apply to ARP-HCY funds. For example, while section 2001(d)(2) of the ARP requires SEAs receiving grants under the Elementary and Secondary School Emergency Relief (ARP ESSER) fund to award funds to LEAs within 60 days, this requirement does not apply to ARP-HCY funding.

In addition, ARP ESSER grantees are required to submit a State plan by June 7, 2021. While the SEA is required to include in its plan a description of how students experiencing homelessness will be served through the ARP ESSER program, it is focused on the ARP ESSER funds, not the ARP-HCY program. More information will be forthcoming about the State plan process for ARP-HCY.


What is the timeline for obligating and drawing down ARP Homeless I funds?

(Date published: May 2021)

Funds appropriated under section 2001 of the ARP are available through September 30, 2023. Under section 421(b) of the General Education Provisions Act, funds not obligated and expended prior to the beginning of the fiscal year following the fiscal year for which funds were appropriated remain available for obligation and expenditure for an additional year. Accordingly, funds appropriated under the ARP-HCY program will be available until September 30, 2024. The deadline for drawdown of obligated funds is 120 days later, or January 31, 2025 (see 2 C.F.R. § 200.344(b)). This applies to both awards of funds under the ARP-HCY program (i.e., ARP Homeless I, awarded in April 2021, and ARP Homeless II, to be awarded this summer).


May SEAs reserve costs for direct administrative expenses for the ARP Homeless I funding?

(Date published: May 2021)

As mentioned in the Dear Colleague Letter on April 23, 2021, available at, an SEA may reserve up to 25% of its ARP Homeless I allocation for State-level activities, consistent with section 722(e)(2) of the McKinney-Vento Homeless Assistance Act (McKinney-Vento Act). The SEA may use part of that reservation for direct administrative costs that are not already included in the indirect cost rate it may charge for the program.


What must be included in an LEA subgrant application and competition for the ARP Homeless I funds?

(Date published: May 2021)

The subgrant application and award requirements in section 723(b)-(c) of the McKinney-Vento Act apply to any new subgrant application and competition for ARP Homeless I funding. The Department encourages SEAs to award ARP Homeless I subgrants to LEAs as soon as possible, but SEAs may award these funds to continuing EHCY subgrantees, hold a new competition, or supplement new EHCY awards made on or after July 1, 2021.

Last Modified: 05/25/2021