American Rescue Plan: Safe Return to In-person Instruction and Continuity of Services Plans

American Rescue Plan: Safe Return to In-person Instruction and Continuity of Services Plans

The recently passed American Rescue Plan (ARP) provides substantial federal resources to support states and local school districts. Recent federal guidance clarifies expectations for states and districts, including the development of a state plan that must be approved by the U.S. Department of Education before the remaining one-third of the federal funds can be allocated. That state plan is under development and will be posted for public feedback in late May before submission to the U.S. Department of Education prior to the June 7 deadline.

The federal template also includes a requirement that districts and community schools receiving American Rescue Plan funds must publish local “Safe Return to In-Person Instruction and Continuity of Services Plans” by June 24, 2021. Each district and community school should post the plan on its local website and then submit the website address that links directly to the plan to by June 24.

Districts and community schools were notified of the requirement for establishing a Safe Return to In-Person Instruction and Continuity of Services Plan in a Comprehensive Continuous Improvement Plan (CCIP) note on May 7. The LEA ARP Elementary and Secondary School Emergency Relief Fund (ESSER) Application and CCIP Note 472 provide steps and instructions for addressing plan requirements. 

According to the U.S. Department of Education,

LEAs that receive ARP ESSER funds meet the requirements in section 2001(i) of the ARP Act and the requirements relating to the ARP ESSER funds published in the Federal Register and available at (ARP ESSER requirements) to either: (a) within 30 days of receipt of the funds, develop and make publicly available on the LEA’s website a plan for the safe return to in-person instruction and continuity of services, or (b) have developed and made publicly available on the LEA’s website such a plan that meets statutory requirements before the enactment of the ARP Act.

Required elements of local plans. The federal requirements go on to identify the elements of the most up-to-date Centers for Disease Control and Prevention (CDC) guidance that must be addressed in the plan:

  1. Each LEA plan includes, or will be modified to include, the extent to which it has adopted policies and a description of any such policies on each of the following mitigation strategies:
    • Universal and correct wearing of masks;
    • Physical distancing (e.g., including use of cohorts/podding);
    • Handwashing and respiratory etiquette;
    • Cleaning and maintaining healthy facilities, including improving ventilation;
    • Contact tracing in combination with isolation and quarantine, in collaboration with the state, local, territorial or tribal health departments;
    • Diagnostic and screening testing;
    • Efforts to provide vaccinations to educators, other staff and students, if eligible; and
    • Appropriate accommodations for children with disabilities with respect to the health and safety policies.
  2. Each LEA plan describes how it will ensure continuity of services including but not limited to services to address the students’ academic needs, and students’ and staff social, emotional, mental health and other needs, which may include student health and food services.
  3. The LEA periodically reviews, no less frequently than every six months for the duration of the ARP ESSER grant period (i.e., through September 30, 2023), and revises its plan as appropriate.
  4. The LEA seeks public input and takes such input into account on (1) whether revisions are necessary and, if so, (2) the revisions to the plan.

More information on the federal requirements is available in the interim final rule.

Federal Reporting. When LEAs submit the application to the Ohio Department of Education for ARP funding, it will include an assurance that the LEA will have a Safe Return to In-Person Instruction and Continuity of Services Plan posted on its website by June 24, 2021. The assurance also requires the LEA to periodically review the plan with its stakeholders. 

Practical Advice. As districts prepare plans, the Ohio Department of Education is sharing the following practical advice:

Build on existing plans. Districts likely have existing plans that address many of the elements of the federal requirements. This may include health and safety plans developed in collaboration with local departments of health. Districts may have existing remote learning plans, continuous improvement plans, strategic plans or other similar plans that encompass aspects of these requirements. Governor DeWine requested that districts submit extended learning plans to the state by April 1. The state leveraged federal funding for educational services centers to support the development of those plans, which are posted on the Ohio Department of Education’s Reset and Restart website. Districts should consider using those previously developed plans to meet relevant requirements of the federal assurances and add additional elements as necessary to meet the federal expectations.

Meeting CDC guidance. The interim final rule clarifies that:

The requirement does not mandate that an LEA adopt the CDC guidance, but only requires that the LEA describe in its plan the extent to which it has adopted the key prevention and mitigation strategies identified in the guidance.

Public reporting. In addition to the requirement that districts publicly post the continuity of service plans, the Ohio Department of Education will collect the website addresses for those plans and post them to the Ohio Department of Education website.

For questions about this requirement, please contact

Last Modified: 7/3/2023 1:37:24 PM