December 16, 2024
As schools grapple with tightening budgets and competing demands, the complex web of federal grant regulations looms large. At the heart of this regulatory landscape is EDGAR—the Education Department General Administrative Regulations—a set of guidelines from the U.S. Department of Education (ED) designed to ensure responsible use of federal grants and assistance for grantees in achieving their intended outcomes.
On August 29, ED published revisions to EDGAR that went into effect on September 30, 2024. These are the first significant changes made to EDGAR in 11 years. As WestEd experts continue analyzing the changes introduced to EDGAR, Anthony Mukuna, Senior Project Director of School Finance at WestEd, has identified three key changes likely to have wide-reaching benefits for federal education grant recipients.
1. New Flexibility for Grant Recipients Under EDGAR
Perhaps the most notable change, according to Mukuna, is the new flexibility in the way federal award grantees can disburse funding. States, who are primary grant recipients of state-administered formula grants like the Individuals with Disabilities Education Act (IDEA) Part B or Title I, Part A, can now issue subgrants unless there’s an explicit prohibition against it under the applicable statutes or regulations.
In the past, states could not issue subgrants under a program unless it was clearly allowed under the authorizing statutes. Furthermore, states are now allowed to authorize subgrantees such as local education agencies (LEAs) to also issue subgrants. This shift empowers grant recipients to adapt their funding strategies to better meet local needs, whether at the state or district level.
“I think it’s a positive change because it gives states more authority to implement programs in a way that best fits their needs,” Mukuna said. “It’s good for reporting, and the flexibility to have a subgrantee help the primary grantee meet their goals can help increase their effectiveness.”
This change may allow educators and administrators to delegate some program implementation responsibilities and focus less time on administrative compliance and more time and energy on what truly matters: improving student outcomes.
2. More Consistency With Related Legislation and Regulation
Over time, portions of the language in EDGAR became outdated and inconsistent with newer legislation, such as the Every Student Succeeds Act (ESSA) and the Uniform Grant Guidance, another regulation that governs grant implementation. The changes to EDGAR included removing outdated terminology, erasing references to old sections or terms, and making references to other legislation consistent.
Uniform Grant Guidance, for example, was first issued in 2014 and has since been revised twice (2020 and 2024), rendering EDGAR’s references to the Guidance outdated.
“Making language consistent across complex legislation will make it easier for state, district, and school staff to comply with federal grant requirements and strategize on how to fund various programs and initiatives for students,” Mukuna said
3. Changes to the Appeal Process
When a federal award applicant is denied a grant by a state education agency (SEA), applicants now have new recourse for appealing the decision for all grants administered by the SEA. Before the revisions, the requirement for an appeal only applied to a select number of programs like IDEA Part B and Title I. It has now been expanded to all programs administered by the state. However, applicants who request an SEA hearing must provide a description of the federal or state statute, rule, regulation, or guideline governing the applicable program that the SEA might have violated with the denial.
This change will increase transparency between the SEA and the applicants by making sure the final grant approval decisions lead to the allocation of funds to students who need it the most.
Supporting Grant Recipients in Meeting Federal Requirements
The recent changes to EDGAR mark a pivotal moment for federal grant recipients, providing them with greater flexibility and adaptability in managing their funds. WestEd recognizes the significance of these changes and is committed to leading with inquiry, continuously asking how the new changes to EDGAR can be used to drive equitable access to resources and improve outcomes for all learners.
Experts like Mukuna say that robust, ongoing training will be key to understanding the myriad revisions to EDGAR and remaining compliant. As a NASBA-certified continued professional education (CPE) sponsor, WestEd provides training for education leaders to comply with federal regulations and will be updating the training content with the latest revisions to EDGAR.
With the right tools and knowledge, the educational community can harness these changes to improve programs that benefit students and families alike while lightening the load for educational administrators. To learn more about how you can partner with WestEd to navigate the new EDGAR guidance, email [email protected] or register for the upcoming federal finance training with our team.
