Scan of Variation in State Implementation of the 21st CCLC Community Learning Programs

We reviewed 38 state plans to identify the length of their grant awards. Most plans reviewed are from 2023/2024 although 2 are from earlier years. Overall 9 plans offered 3 year awards, 2 plans offered 4 year awards and 27 offered 5 year awards. Of the total plans reviewed, 24 percent offered 3 year and 71 percent offered 5 year grants.

Additionally 15 plans offering 5 year awards had some type of contingency for continuing to receive grant funding for all 5 years. These contingencies included “Continuation of funding within the five-year grant cycle is contingent upon compliance with state and federal guidelines, including student attendance and data requirements, use of funds and adequate progress towards program goals. Programs will be required to submit an End-of-Year Report and budget prior to receipt of funding each year” (CT). “Continuation from one funding year to the next, within the five years, is contingent upon program performance and appropriations by Congress” (KS).

In our assessment, we analyzed 35 plans to assess their sustainability policies. Among these, 17 plans specifically addressed sustainability in their RFP. The requirements for sustainability varied greatly. Most of the plans (18) had broad criteria, asking applicants to outline their sustainability plans to earn points on the RFP scoring rubric. This often involved programs detailing their partners, volunteers, and those partners' contributions to sustainability. For example, AL requires a provider to specify the investments (time, capital, contributions, etc.) each partner will make to the program. Meanwhile, NJ requests a description of how the applicant will coordinate with federal, state, and local programs and make the most effective use of public resources.

Seven plans called for additional stakeholder engagement. KS, KY, NJ, and WV requested that applicants consider the role of their advisory group in sustainability. NH requires subgrantees to establish a written plan to be disseminated through community outreach and engagement strategies, communicating the benefits of programs and persuading community leaders and entities to provide in-kind and/or financial support to sustain and expand access to community learning centers for low-income students. NC asked grantees to “use their annual data collection plans and program evaluation reports as evidence of success to engage potential donors and apply for additional grant funds”, along with sharing how “the impact data will be analyzed and disseminated to staff, students, and stakeholders”. OH recommended hosting significant community fundraisers and events, celebrating the work and progress of students and inviting community stakeholders.

Some sections referred to the sustainability plan as a living document that can be adjusted as necessary (MT, NC), including keeping the plan up to date and available during annual state monitoring. For instance, KY only requires an initial preliminary plan, with a detailed sustainability plan not due until 6 months before the end of the third year of the grant. NH stipulated that “subgrantees should update their sustainability plan yearly within their APR, due at the end of each fiscal year”. NC required subgrantees to make their current Comprehensive Program Sustainability Plan available to NCDPI during annual 21st CCLC program monitoring events.

Three states provided more detailed accountability requirements. For example, FL asked grantees to identify positions responsible for engaging in sustainability activities and to include progress indicators in their sustainability plan. NC's subgrantees should identify 21st CCLC staff responsible for collecting data, building relationships, and applying for grants. MO cautioned applicants that they would need to address the success of their sustainability plan for each continuation year of the awarded 21st CCLC proposal. Some states referenced declining grant funds in later years of the grant cycle as a mechanism for encouraging grant sustainability (CT, MS, OK, OR).

A few states considered how long programs are expected to maintain sustainable programming after the grant ends. For instance, IL asked grantees to explain how they plan to maintain and continue the size and scope of their funded programs for a specified period after 21st CCLC funding ends.

At times, policies conflicted across states. For example, AL and KY do not allow funds to be collected via a fee structure for program sustainability. In contrast, TN permits applicants to propose generating program income or collecting program fees as part of their sustainability plan.

Very few states seem to provide state technical assistance for grantees on sustainability. AR mentioned that assistance, training, and support by DESE would be provided to all subgrantees to help programs build capacity to support sustainability once the grant period ends. SD stated that "grantees may receive resources from after-school networks and alliances that offer support for sustainability plans."

The assessment of sustainability policies across 35 plans reveals a diverse landscape shaped by varying approaches and requirements. While some states emphasize detailed sustainability plans with specific stakeholder engagements and accountability measures, others prioritize flexibility and adaptation over time. Conflicting policies, such as those regarding fee structures for sustainability, underscore the challenges of achieving consistency across jurisdictions. Furthermore, the limited provision of state technical assistance highlights potential gaps in supporting grantees beyond the grant period. Moving forward, fostering collaboration among states and enhancing support mechanisms could strengthen the effectiveness and longevity of sustainability efforts within the realm of community learning centers nationwide.

After carefully evaluating 38 transportation plans, we found that 36 of them include specific information about transportation. However, one plan does not mention transportation at all, while another mentions transportation but lacks details beyond the necessity for a plan. Furthermore, five plans have budget constraints in place. For instance, AL applicants can allocate up to 25% of the grant for transportation, while AZ has a maximum of 4% when deemed necessary. Additionally, IA allows up to 8% of each site's total budget. Currently, three states offer transportation allowances for certain circumstances. KS is eligible to receive an annual transportation allowance of $25,000, in addition to the maximum 21st grant award. Meanwhile, WV can receive an extra $10,000 if transportation is provided. AR is entitled to an annual transportation allowance of 25,000. However, any amount exceeding this will require approval from DESE.

When planning transportation, it is important to consider the specific policies and preferences of each state. For instance, AL strictly prohibits the use of vans, but if a bus is used, safety drills and training must be scheduled and implemented for emergency situations. GA and MS encourage the use of vehicles that meet school bus or multi-function school activity bus standards, but they also allow the option to use non-traditional buses. WI prohibits relying on students to be picked up by their guardians or walking to school, so they may consider contracting with local transportation companies, providing passes for public transportation, or leasing a van.

When discussing school bus funding, it's important to note that different states have varying requirements regarding how funds can be used for driver salaries and related expenses. For example, in AL, the budget must encompass driver salaries, benefits, fuel expenses, and other associated costs. On the other hand, in AR, it's specified that 21st Century funds may not be utilized for salaries, fuel, or the use of buses.

Transportation time cannot be counted in program hours. For example, in TX, the total transportation time for students from school dismissal to center arrival using buses cannot exceed 30 minutes. However, in KY and AL, departure time to transport students home is not included in program hours.

Only 12 out of the total 38 RFP documents include specific mentions of staff-to-student ratios. Despite the considerable variations across states, among states offering ratio guidance or requirements, there is a general consensus that the ideal staff-to-student ratio should not exceed 1:20 for all activities. For example AR allows programs to have a minimum ratio of 1:10 up to a max of 1:15. Other states like Iowa make allowable larger ratios for 21st CCLC programs (1:20) but mention programs also abiding by state child care licensing regulations must meet lower ratios (1:15). Some states simply point out that lower ratios (where possible) support strong programs. A few states (KY) discuss how high school student workers (16 to 18 years old) should be counted as staff in the ra Texas similarly mentions for any high impact tutoring a ratio of 1:3. WV specifically mentions a different ratio of 1:8 for any water activities such as swimming or canoeing. States vary in regarding their ratio as “requirement” or a “recommendation.”

5 states provide any mention of paid planning time for staff. Of states who make mention all make this an allowable expense for grantees. WA specifically says grantees should budget for planning time and professional learning for staff when programming is not in session. OK allows payment for “reasonable planning time.” Some states mention the planning that a staff or a program on an on-going basis to strengthen the program and responding to evaluation results as an allowable expense (OR). For example, Illinois allows four weeks of pre and post program planning based on a staff member's normal weekly hours throughout a year. A few states, such as Arkansas, require submitting separate documentation for hours working during non-program times. Arkansas also allows program directors or site coordinators who are not district employees to work a maximum of 2 hours before the start of the program, subject to submitting a documented form.

In 33 out of 38 request for proposals (RFPs), there is a mention of advisory groups in their plans. Among these, 14 plans mandate the inclusion of an advisory group, while 4 plans encourage but do not require the inclusion of an advisory group. 18 plans suggest including parents or students in their advisory groups. For instance, PA recommends that “applicants are strongly encouraged to convene a focus group of parents, students, community leaders, etc”. Furthermore, OK states that “members should include parents/family members not employed by the LEA, students, etc”. When discussing advisory groups, it's important to note that certain states have specific requirements or recommendations regarding how often these groups should meet. For example, AL, advisory groups are mandated to convene every 6 months. In DE, the recommendation is to hold meetings at least 4 times per year or as needed. In LA, it’s suggested to hold 3 meetings per year, although this is not a requirement. Meanwhile, in NJ, advisory groups are required to regularly, specifically once every quarter. Although PA and LA strongly encourage advisory groups, both states don't allow grant funds to convene any meetings. The NH plan emphasizes the significant role of the advisory board in providing guidance and input to the program. It is mandatory for the advisory board to be acknowledged annually in the Annual Performance Report (APR). Additionally, NH aligns its advisory group with its sustainability plan by leveraging its members support in securing resources to ensure the program's continuity.

When analyzing 34 RFPs regarding funding per grant, it was found that 26 states specify a minimum grant amount of at least $50,000, while 8 states set a higher minimum value. For instance, NJ offers a minimum grant amount of $250,000. In this analysis we found that 24 states have a maximum funding limit of $500,000 or less. Additionally 6 states have a limit that exceeds $500,000, with the highest being $1,200,000 (LA), and 2 states (MN, TX) do not specify a maximum amount for funding.

Only 4 of the state RFPs reviewed allowed for grantees to receive funds ahead of starting their services to youth. Alabama allows programs to request advancement of funds prior to the start of the grant for up to $25,000 for 3 months. Pennsylvania allows  a “one-time advance payment of 25 percent of the approved annual grant amount” which must be requested as an attachment to the grant application to be initiated after the grant is signed.  Florida has a policy known as Federal Cash Advance which seems to allow grant recipients to request minimal amounts of cash as needed. And Iowa, mentions that contractors may be eligible for advance funding in certain circumstances but should otherwise be prepared for quarterly reimbursement. Meanwhile, other states which do not offer forward funding, provide information on program readiness to apply for grants. For example Arkansas advises “new subgrantees will need to obtain initial start-up funding to cover program expenditures and two to three months of payroll until the entity completes all the DESE requirements to receive funding.” Colorado mentions reimbursement “normally takes 30 days after the 15th of each month.”

A number of states in our count (15)  simply prohibited the charging of any fees or collection of program income. Alabama makes this clear “Programs are not allowed to collect funds to create additional program income in any method, such as in participation fees or fundraising.” Some states mention that programs charging fees as part of their on-going operation may not charge for the 21st CCLC activities and components. About 13 states allow parent fees of some form. For example, Ohio has a detailed policy for grant applicants interested in charging parent fees. “When advertising the parent fees, a subrecipient must include, in writing, that no child can be excluded from the program even if a child’s family cannot pay the nominal fee. If a child is eligible for or receives free lunch; he or she shall not be charged for any 21st CCLC program in Ohio. Programs will be required to develop and implement policies and demonstrate accounting tracking methods showing how fees are collected and spent annually.” Parent fees must be used for the purposes of the award, should be nominal, and can be spent as allowable program income over the life of the grant.

North Dakota’s Education Agency reviews grantee program fee requests annually to “determine if the fee is reasonable, necessary, and allowable for the purpose of the 21st CCLC program”. The state also mentions it can reach out to programs for additional questions and disallow any requests that don’t meet program objectives. Montana distinguishes how its no fee 21st CCLC policy does not mean the provider must stop collecting fees from all of their programs saying, “This does not prevent community organizations who receive 21st CCLC funds from generating income or charging for fees for other programs that they administer. Rather, it requires a clear delineation in budgeting between 21st CCLC Programs, from which no revenue may be generated, and other programs, from which revenue may.”

Donations are often mentioned as not constituting program income. All states that speak to program income and parent fees emphasize not turning away youth for any inability to pay.