Institute of Museum and Library Services 2020 Grants to States All States Conference May
12, 2020 Virtual Proceedings by: CASET Associates, Ltd. caset@caset.net
P R O C E E D I N G S (1:00 p.m.) Agenda Item: Welcome and IMLS Updates: COVID-19
and the CARES Act MS. DEVOE: Welcome, everybody. This is Teri,
from IMLS, and Grants to States specifically. We are so glad you're here, and we're keeping
the chat box open a few minutes. If you're just arriving, tell us who you are, where
you're from, and maybe something about your favorite superhero. We are going to have a
superhero theme this conference. We're going to do just a few housekeeping
announcements and then we'll dive right into our topic of the hour, because we may well
take the full hour. Just a few announcements. We do have all the
attendees' microphones muted during the virtual conference, so you'll only be hearing from
the presenters. We will have these chat sessions open where you can see each other's comments.
It's open right now, and we're going to have them open during the breaks. But then they're
going to change to just the Q&A box, which will allow you to submit questions to us,
and we'll see them on the presentation side, but you won't see each other's comments. So
that will function just a little bit differently once we get started with just the Q&A.
We're typically going to take questions at the end of the session. That doesn't mean
you can't type in questions throughout a session. Type in any questions as you have them. It's
just that we'll pool them and answer them in one block towards the end. If you're having
any technical assistance issues, you can also type into that Q&A box. We've got folks standing
by to help you with that. We're going to have some of these sessions using polls, so we
look forward to your participation in those. And all of our sessions are going to be recorded.
So we'll send out details about how to access those once the conference is over. For this
presentation, we will actually have a couple of blocks to pause and take questions, because
we've got a couple of chunks of content that we want to go through, and make sure everybody's
clear about that. To welcome you officially, here's the Grants
to States team. We can't be together in person this year, and we're admittedly a little sad
about that, but we're all working from home, and we are so glad that you are being flexible
with us and joining us through this virtual format. From left to right on the slide, it's
myself, Teri, the associate director for Grants to States. We've got Madison Bolls, one of
our program officers; Deirdre Gonsalves, our program specialist; Dennis Nangle, a program
officer who is at this moment on paternity leave. Congrats to Dennis and his new baby
boy. And then we've got Michele, who is our third program officer for the Grants to States
program. And that is our team. We hope you are all safe and well out there,
wherever you're tuning in from, and because of the heroic efforts that you have been through
over these past few months, we have designated our theme for the year as superheroes. We
did a little icebreaker at the beginning around that. You won't hear a whole lot about it
in this particular session, but we will have some superhero themes emerging later on.
This session we are going to sort of do a little bit of IMLS updating because a lot
has happened since we met last year in April, for those of you who were with us in person
in Denver. We're going to talk through some of the COVID-19 response flexibilities that
you have as folks administering grants. And we're going to talk about those new and exciting
CARES Act funds, which is unprecedented in the history of our program. So it's very exciting.
We're all learning and going through this together, so we want to be sure to cover these
important topics right at the outset. Just to give you a recap of the past year,
a lot has happened since April. We got a new deputy director for library services, Cyndee
Landrum, over the summer. Shortly after she arrived, the discretionary program issued
our first Accelerating Promising Practices awards. These are designated for small and
rural libraries, and we know that many of you reach small and rural libraries, but it
was new and exciting for IMLS to do this grant program as a direct grant program through
our discretionary team. And we thank you for all the work that you did to help amplify
and coach small libraries to the finish line, and we saw that those efforts really paid
off, so thank you. In October, we rolled out a whole new system,
our electronic grants management system, and all of you came on board with us for that.
We launched the system, had a rollout, had a webinar, and it has been going really well,
which is thanks to you, learning this system and navigating it with us for the first time.
But in January we got a new director, Crosby Kemper. As many of you know, the IMLS directorship
is a four-year term with, now, a one-year sort of option year, and our director rotates
back and forth between libraries and museums. So Crosby comes to us from Kansas City Public
Library, and represents the library side of the house for the next four years. He of course
represents museums, too, and he's learning and has been thrust into really exciting stuff,
ever since January, as you can imagine. Also in January, we issued our first Grants
to States award, under the new Museum and Library Services Act. This had been an act
and been authorized since the year prior, but it wasn't until this year that we were
able to implement it, because we got a higher program budget, which meant that we could
kick off giving the states a higher base, and we also rolled in for the first time three
freely-associated states into the program. This was Palau and Marshall Islands and Micronesia.
They had been part of our Pacific competitive award program up until this point, but now
for the first time they're getting their own allotment. So it's a really exciting moment
for the program. In February, we were working with our SPR
vendor, and migrated the system to the cloud, which probably affected you very little, but
on the back end it was one of the last remaining systems that we had in a server onsite. So
for the agency it weas a really big milestone, and it went pretty darn seamless. So we're
excited about that. And then we started responding to coronavirus,
and by April of this year, we had sent out to you $30 million in CARES Act funds through
the Grants to States program, and we're going to talk more about that. But it has been quite
a year, and you should all be very proud of yourselves.
The one thing we would have touched on probably in more detail if we'd had a traditional conference
and more time, but we just wanted to touch on it here, is that in the space of a year
we've gone from just kind of talking about our eGMS system in the abstract to all of
us fully using it. This is a system where you can manage awards, we can see award details,
you can request payments instead of sending us separate emails, you can see the progress
of those payments. It's a place where you can send official grant communications to
us, and it gets appended to the grant award, and it's there for perpetuity, and it's a
place where you can access reporting schedules, and so much more. We thought it was worth
revisiting one guidance area that is pretty specific to Grants to States and eGMS.
Basically, when do you use eGMS to communicate with us, and when is it better to just use
something like email? For us, as we think about eGMS, it's really the record level activity
for the program. It's the kind of thing that we used to print out on paper and put in our
paper files. For us, that is things like equipment requests, when you come to us for prior approval,
when you want to buy something for over $5,000 for one single item. It's when you submit
your certifications for the year, when you submit to us a maintenance of effort waiver
request. As I said on the last slide, eGMS is now where you make your payment requests.
If you have any other official requests that require IMLS approval, we want you to be using
eGMS Reach. It's not the end of the world if you don't. We can always append our email
chain of conversation with you to eGMS on our side, but it's just kind of a helpful
concept to think about, that this is a record-level correspondence.
Email is perfectly fine for a lot of other things. If you have allowable costs questions
that you want to bounce off of us, we're happy to answer those through email. If you're having
SPR issues or want to send us general feedback. If you need to make contact changes to the
personnel that we send messages to occasionally, there's a designated form for that in the
state program report, so continue to make those changes in the SPR. We don't want you
to have to redundantly make those changes in eGMS and SPR. So just make them in the
SPR, and then notify us through email, because unfortunately we don't get push notifications
that those changes have happened. We still have a designated email box for quarterly
grant accrual reports, and that's here on the slide, the LSTA-QRTA email address. And
we still want your Grants to States report to go through the SPR. There is a module in
eGMS for reports, and we know that it can be confusing, but for us, we want you to submit
through the SPR only, and then we do a little back-end work to reflect things in eGMS for
you. For your purposes, reports still go through the SPR. So we thought this slide might help
clear up when to use eGMS and when to just use other channels.
Now we're going to get into the first major topic that we want to cover here, and once
we're done with this topic we'll pause for questions. COVID-19 has had an understandable
impact on how we all do business. It's affecting our conference right now. It has also affected
how you all carry out existing grant awards. So we are going to revisit some of the flexibilities
that are available to you as passthrough organizations. You have a very specific type of grant that
is different from a lot of other IMLS grants. So we just want to differentiate what IMLS
as an agency is telling grantees and what you need to pay attention to as Grants to
States grantees. A lot of this is going to recap some of the
information we've already sent you. Most specifically, probably most pertinently, the early April
message that came from me called "COVID-19 guidance for your open Grants to States awards".
That is the specific Grants to States lens on all of the COVID-19 flexibility stuff.
If, for some reason, you did not get this message, it would have gone to your chief
officer, your LSTA coordinator, and your designated library development contact. Those may not
be job roles at your agency, but they are job categories that we have defined at IMLS.
So ask one of those folks if they can forward the message to you or connect with your program
officer, and we can make sure you get a copy of that.
Basically, this message was our interpretation of information that IMLS put on its website.
You are of course welcome to see the information that IMLS put on its website. It's just that
that information is often couched in a discretionary grant lens, so it's not all going to be applicable
to Grants to States, and the website information that we have up for our agency is sort of
another lens. It's an interpretation and our implementation of what we heard from our Office
of Management and Budget, which sent out a memo to all federal grantmaking agencies about
the new flexibilities that they have offered us. And of course, your program officer is
always a resource on these issues. A lot of what we're covering is on a case-by-case basis.
We hesitate to make blanket statements about what you can and cannot do, because there
are often so many nuances to how you're carrying out your programs. So we encourage you at
the end of the day, if you have questions, just to come to us and we will try to get
them clarified. The scope of what we're talking about here
are your two open awards that were happening as of late March, because that's when we got
the guidance from OMB. So this is open awards for fiscal 2019. That's the grant that's coming
up with an end date of this September, and then your fiscal 2020 award, which will end
next September. So a reminder that anything on our website
around COVID-19, and there is a whole FAQ page on this, is targeted to IMLS discretionary
awards. So where on the website it's going to talk quite a bit about no cost extensions,
because that's a very common thing for discretionary grants. Extensions, we want you to know, are
quite rare for Grants to States. You get awards every single year, and you have overlapping
and parallel awards to keep track of, so as much as possible we're trying to have you
use the flexibility within those multiple awards that you have, rather than asking for
an extension, which starts to throw off the whole cycle. They are possible, and we'll
talk about that a little bit at the end. The other thing on the website is that you're
going to see some references to things like approval requests and asking your program
officer for approval. The flip side of the extension coin is that you actually have a
lot of flexibility when it comes to doing things without IMLS approval, with the Grants
to States program. So that is a plus. There are a few exceptions. We have some new
flexibilities in particular, and we're going to cover those on later slides, but we've
already approved your five-year plan, so that is the stamp of approval for the 2018 to 2022
cycle, for you to make the kinds of adjustments that you need to make at your own discretion.
The other thing the website will talk about, if you look at the COVID-19 FAQs, are change
requests in eGMS. And we are not using, in the Grants to States program, eGMS change
requests so that you would need to initiate one of those to ask for this kind of flexibility.
Instead, we will document some things on the back end, and we just want you to know that
that's not a mechanism that you need to use. First, let's talk about that existing flexibility
that you already have in Grants to States. We have some kind of broad guidelines within
which you are operating, and as long as you're adhering to those, you can consider making
changes on your own. Those broad principles come from the Grants to States statute, so
those are some of the certifications and assurances that you have signed off on. Your five-year
plan that IMLS has approved is another kind of broad umbrella under which you're operating,
and you need to be adhering to allowable costs, which, for us, include a lot of things. You
can pay for salaries, you can pay for services, you can pay for programs. We don't want you
to pay for things like advocacy or entertainment. So there's a few unallowable costs, and as
long as you're steering clear of those, you can make some of these decisions on your own.
We know with COVID-19 we've heard a lot about folks having to make alternate plans for in-person
events, so that's fine. If you need to pivot from, much like we did for this conference,
an in-person event where people would travel and be together in a space, that's not healthy
at this time that we're in, and you need to make that a virtual event, that is perfectly
acceptable for you to make that decision and go forth and do it. You can also make in-scope
changes at the state or subrecipients level, and for us in scope, again, kind of points
back to your five-year plan. Are you still adhering to the goals that you told that you
were going to tackle for this five-year period? If so, then you're probably working within
a scope where you don't need to ask our permission to do different things.
We do have some new flexibility. This is from our Office of Management and Budget. It applies
to multiple grant agencies across the federal government. If you have these kinds of needs,
we would just ask that you reach out to us for prior approval, because they are exceptions
to a lot of what we've talked about so far. One of the areas we realize may need to be
charged to a grant is if you've done everything you can possibly do to pivot away from an
in-person meeting, but you've still got some unrecoverable costs. That is one of the areas
that you can write to us and ask for that to be charged to the grant, and we just need
to document that on our end. The second area is around salaries and benefits
that would be charged under unexpected or extraordinary circumstances. These need to
be, if they're going to be charged to the grant, consistent with the institution's own
policy of paying salaries, so if an institution is not paying folks salaries whose work has
been disrupted by COVID-19, but you want to come and ask the salaries to be charged to
a grant, then that would not be an acceptable approval that we could make. It has to be
consistent with the institution's own policies. And these don't necessarily have to be formal
and codified and in writing in a very formal way, but as long as there is some semblance
of a policy -- we realize a lot of this stuff was happening quickly at the local and the
regional and state levels, and so some of these things just may be written down in an
email, for example, but if you give us a semblance that there's a policy there, then we can approve
also charging things like that to the grant. So with these types of questions, we want
you to reach out to your program officer and they'll tell you the specific things that
we need to know. Basically, it's things like the estimated dollar amount that you'll be
charging to the award, which grant year this is going to apply to, and then if you're charging
salaries and benefits, whether it's consistent with the institution's policy.
The OMB has given us, for now, and this may change, but for now we know that we have these
flexibilities for 90 days. The memo was issued March 19, so that gives us through mid-June
to be able to approve these new types of charges to grant awards.
So, if you find yourself in the situation where you think you might have some of these
costs that need to be approved by IMLS before you can move forward and charge them to the
grant, what we're asking is that you do this as soon as you can and reach out to us so
that we don't find ourselves in a position at the end of June saying, oh, I'm sorry,
you came to us too late, and we can no longer give you approval for these kinds of flexibilities.
So we've got through June 17 at the moment, and if this changes, we will let you know.
But for now, maybe check with your subrecipients, do a little due diligence, so that we can
smooth this transition and give you the approval you need to charge things to the grant award.
On the COVID-19, just to wrap up, I have communicated on the one hand that you have a lot of discretion
to make your own decisions. That's not to say that we don't want to hear from you. We're
always happy to hear your questions and help you think through options. It's just that
we want to empower you to know that your program works a little bit different than IMLS programs
in general, and you do have some decision-making discretion. Most of the scenarios that are
happening out in the field have a lot of case-by-case aspects to them, so we have not gone here
into making blanket statements about what is and isn't allowable, but we're happy to,
again, talk through options with you and help you figure out what might be the best course
of action. Then, on the extensions front, if you are
doing everything you can do in this fiscal 2019 grant period in particular, and this
ends the end of September this year, if you've moved money around, if you've thought about
different projects, and you're still finding that you cannot complete your activities by
September 30 of this year, please reach out to us before September so that we can formalize
-- we can consider and we can give you approval as needed for an extension to the Grants to
States program. It's rare, but it is possible, and we just ask that you would do that early
enough so that we can weigh everything and give you a good answer.
With that, I want to pause and see if there are any questions on anything we've covered
to date, before we jump into the CARES Act portion. I see we have a few questions, and
I'm going to turn it to Deirdre to help me moderate this section.
MS. GONSALVES: Absolutely, thank you. So we do have a question about the salaries. With
covering the salaries specifically for SLAA staff only.
MS. DEVOE: OMB did not differentiate between SLAA staff or any other kind of staff, so
if you have subrecipient staff that need to invoke this flexibility, we can consider that.
It's not restricted to just one type of staff. MS. GONSALVES: Okay, our next question. Regarding
the policy on salaries, is this a long-term or a longstanding policy to be put in place,
or is this just short term for this circumstance? MS. DEVOE: If I am understanding this right,
the charging salaries to the award under extraordinary circumstances, that language that I put up
on earlier slides, that is a very temporary flexibility that the Office of Management
and Budget has given us for 90 days. If folks are unable to perform their duties because
of COVID-19, that is what it is supposed to be responding to. It's a temporary situation
that we're in, theoretically. If we hear it's going to be extended, we'll let you know.
But for now, that's a 90-day flexibility. It's not something that we'll have forever
and always. MS. GONSALVES: I am going to read this next
question. We have someone who wants to know if you can elaborate about the grant-funded
meetings specifically, can grantees get reimbursed for costs associated with sending staff to
conferences, which are normally charged to the grant, or is this just for meetings that
grantees hold for themselves or are hosting, and if it's the former, would a request for
approval need to be submitted to the program officer with the specifics for the conference?
MS. DEVOE: There is existing flexibility in the program. I hope I am answering this question
correctly. You can always get reimbursed for sending staff to conferences and for meetings
that you're hosting. Right now what's happening is COVID-19 is throwing a monkey wrench into
a lot of these plans. So OMB has given us new flexibility allowing us to charge atypical
costs, like sunk cost for conferences, to grant awards, for the first time, knowing
that COVID-19 is new and different. If I'm answering your question, hopefully, you can
charge -- those costs could be both for travelers traveling to conferences, or for meetings
that you're hosting yourselves, or for meetings that some of your subrecipients are hosting.
Basically, the whole gamut of conference-related costs that might be sunk costs.
And then, if the former, would we need to submit a request for approval? Yeah, if these
are of the sunk cost variety, it's not normally something we'd be able to give you as an allowable
cost, we do want to hear from you and give you prior approval before you make those charges.
We need to document that in writing, because with this flexibility that OMB is giving us,
they're going to want a report from us as to how many of our grantees took advantage
of these flexibilities, and so we're documenting them on the back end. So we do in these cases
want you to come to us for prior approval. I hope that answers the question.
MS. GONSALVES: Someone wants to know if a library is currently furloughing staff, if
salaries can be charged to the grant. MS. DEVOE: This is probably one of those case-by-case
basis things, but I'll speak in broad brushstrokes. If the library has an existing grant award,
and they had existing grant funds paying for salaries, and because they're now being furloughed
they're unable to carry out the grant-making activities as originally outlined, then you
could come to us and ask for some of these flexibilities around charging those salaries
to the award, as long as that same institution would do the same kind of thing if they were
not paying for salaries on grant funds. If they were paying for those salaries on their
own institution funds. So there's a couple of flavors of that. But come to us with anything
like that, and if we don't have enough information right off the bat from you, we'll ask a few
more questions. MS. GONSALVES: Another salary question. Is
flexibility regarding salaries not previously covered by the grant?
MS. DEVOE: This exact type of flexibility, which is very much related to COVID-19 response,
has not been covered by the grant in the past. And because OMB only issued its memo as of
March 19, we would only be able to grant retroactive prior approval back to March 19, because that's
the first day that we had the flexibility to make those requests. So yes, it has not
been previously covered by the grants. COVID-19 has kicked off a new wave of flexibilities
for us. MS. GONSALVES: Okay. A different type of question
regarding extensions. If a grantee is granted an extension, is there a usual set amount
of time for the extension? MS. DEVOE: That's a great question. This has
to be determined by you as the SLAA. So there's no set time period that we recommend. We want
you to be able to finish all of the activities that you have outlined for that grant year,
so if you think that's going to take an extra month, you can ask for a month extension.
If you think that's going to take an extra three months, you can ask for a three-month
extension. However long you think you're going to need, we want you to determine that time
period and to come to us with that time period in your request. And remember that whatever
extension amount you ask for will then kick off an additional sort of reporting extension,
because you get three months after the end period of performance to submit your reports.
So you tell us what you think you need, and we will consider it based on your information.
MS. GONSALVES: There are currently no additional questions at this time.
MS. DEVOE: That is great. Thank you all for those great questions. And if you have more
on COVID, go ahead and continue to ask them, and whatever we don't get to during the presentation,
we will follow up with you afterwards. Now let's move into CARES Act funds. This
is part of one of the waves of stimulus packages that Congress has authorized in response to
COVID-19, and I think it speaks very highly of all your work in the field and your reputation
as good stewards of funds that IMLS was given $50 million to administer as part of this
package. What I will say at the outset, that this slide deck was finalized late last week,
and on that very same day IMLS announced its new discretionary opportunity through the
CARES Act, and I do not have any slides on that, so I'll talk about it just super briefly.
We've got two kind of pools of funds going right now at CARES Act and IMLS. $30 million
was originally granted out to all of you, and I will be talking about that. An additional
$15 million was just announced last Friday in the form discretionary competitive awards.
Those are going to be available to libraries and museums to apply to IMLS directly. The
deadline for that is going to be June 12, so it is a rapid turnaround program, sort
of in keeping with the emergency response nature of the funds. All of you are technically
eligible for these grants, and many of your stakeholders and libraries that you work with
will also be eligible for these grants. There will be a webinar this Thursday at 2
p.m. Eastern time, so if you haven't gotten enough IMLS on Tuesday and Wednesday of this
week for the virtual conference, you can tune in again on Thursday at 2 p.m. Eastern, when
there'll be a webinar specifically around this discretionary pool of funding. The grants
are going to be in the amount of $25,000 up to $500,000. And the broad-brush scope, and
this is where my expertise will stop, but it's broadly around recovery and adaptation.
So again, how have libraries and museums had to adapt based on their response to COVID-19?
So that is what I can tell you about discretionary funds, and just sort of reiterate that everything
I talk to after this point is going to be about the Grants to States portion of the
CARES Act funds, which is the $30 million that went out in April.
We also sent some prior information about this. On April 13, the chief, the LSTA coordinators,
and the library development folks, would have gotten a message from me called "IMLS CARES
Act funds for Grants to States". A lot of that language was reiterated when we sent
out your grant awards the following week. The language is in the award document itself,
your notice of action, as well as in a decision letter that accompanies the awards.
So both of these documents are in eGMS in your documents tab. As long as you are an
authorized user in eGMS and attached to the CARES Act award and your other open awards
with Grants to States, you'll be able to see these. And if you were one of a select group
of contacts, you would have also gotten an email on the day the awards were issued. That
was April 21. In addition to that language that we've sort of got written down, your
program officer, again, is a wonderful resource, and we're happy to talk through any CARES
Act questions you might have. This is a new and different grant, essentially.
We've never in the Grants to States program in my time had a separate grant like this,
but it's new legislation, and therefore, it is a new and different award that is separate
from your fiscal 2020 award although it has the same end date. So it's sort of running
in parallel right now to your fiscal 2020 award, so both end next September.
The CARES Act came with a couple of special provisions. Specifically, and excitingly,
there is no match requirement for CARES Act, so whereas you have to bring a portion of
state and local dollars to your traditional Grants to States awards, these funds come
with no match requirement. They also have a special purpose, we should say, and we've
sort of shorthanded this as the spending priorities. Whereas your normal Grants to States awards
sort of invoke the LSTA purposes and your five-year plan, these funds have a very specific
spending purpose and we'll talk about those in a minute.
But apart from these CARES Act provisions, no match and the purpose, the existing Grants
to States statutory provisions still apply to these CARES Act awards. So the CARES Act
stuff still comes under the banner of your five-year plans. They still need to adhere
to the certifications and assurances that you signed earlier this year, and that includes
things like the Children's Internet Protection Act, and they still follow our traditional
IMLS guidance around things like allowable costs and 4 percent administration, and other
things. So we're going to dive a little deeper into these as the slides go along.
So the purpose. This is the language that was both in the email that I sent you, and
all the award documentation that you've received. You've probably seen it already, but it's
just worth underscoring here. CARES Act is Public Law 116-136, and its purpose is to
prevent, prepare for, and respond to coronavirus, including to expand digital network access,
purchase internet-accessible devices, and provide technical support services. For the
Grants to States program we said that primarily we want you to focus on digital inclusion
and related technical support. That is the primary purpose of this funding.
The three bullets in that section are very much data points to help you inform how you
determine the need for this digital inclusion focus. We are not saying that you have to
do anything with the SNAP program or your unemployment offices. Just that these are
data points. There is poverty data out there. SNAP data is a bit more broad. It can help
you inform the needs in your state and point to the areas of greatest need. Same with unemployment
data. This is changing by the day, but there is unemployment data out there, so that when
folks come to you and say how did you determine how you were using your CARES Act funds, you
can say, well, we looked at the poverty data and the unemployment data and the broadband
data. I will say, about this data, it also is being
invoked in the discretionary form of the CARES Act funds that IMLS is administering, and
when we announced the availability of those funds on Friday, our colleagues, Lisa Frehill,
who's going to be speaking to you this afternoon, and Matt Birnbaum, put together what they're
calling an IMLS indicators workbook, and this has some of this type of data in it. We know
that you probably have a lot of this data at your fingertips for your states, but the
workbook that IMLS put together has state and county data in it. It is linked to our
website now, under the data area of our website, and then the data catalogue, and it's basically
an Excel spreadsheet that has Bureau of Labor Statistics data in it, Census data in it,
and broadband data in it. So if you have been puzzling about this data
and would like to access the digest that our colleagues put together, it's there and available
to you, and I believe Matt Birnbaum is going to talk about again tomorrow, with some screenshots
and slides, so that you can see where this is located. But basically, the data, again,
is just a tool to help you make decisions. The funding, again, primarily around digital
inclusion. So that is effort number one. And then secondarily, we want you to address
other efforts that prevent, prepare for, and respond to coronavirus. And the third issue
here is new and exciting for Grants to States. We have asked, to the extent that you can,
to reach out and include museum and tribal partners where appropriate. And the caveat
language there is really where appropriate. We know that not every state allows these
types of institutions to be part of their eligibility, and we still respect that. There
is probably some creative ways that you can partner with them, but again, it's not required.
Because we know that these funds, we're anticipating that they're going to be watched with more
close scrutiny than our usual grant programs, one thing our leadership asked was rather
than wait for Grants to States to do its traditional reporting cycle, which comes after the fact
-- you know, we wouldn't hear from you until December 2021 how you were spending your CARES
Act funds, unless we asked you earlier. So we went a few weeks ago to the chief officers
of all the states and asked if you could give us just a high-level, really preliminary,
overview of how you plan to spend the funds. We wanted to keep that information internal
to IMLS for the most part. We're not going to out any states, because a lot of those
plans are super-preliminary, but what we can do with it is a really quick-and-dirty digest
of the types of things that you're thinking about. Very broadly, this is not even an exhaustive
list of topics, you came up with a lot more exciting things that we could talk about,
but just to see that you were tracking with the language in the CARES Act, we pulled together
this slide. Really the first three areas, connectivity,
digital content, and online reading programs, I think really speak to that digital inclusion
and related technical support focus. So it's really heartening to see how much emphasis
that gets in terms of the count that we did. A lot of you also invoked unemployment-related
needs, specifically around things like databases and training support and having librarians
assist with unemployment-related things. A lot of you talked about COVID response supplies
and things you would need to purchase to help your physical spaces in your libraries reopen
and get back to a new and different way of business. We looked at how many of you had
explicitly mentioned museums, and there were 13 states that had. That doesn't mean that
more of you won't end up working with museums, but just in the very quick count from these
preliminary plans, that's what we saw. And seven of you mentioned tribes explicitly.
The last category here isn't really a topic, but it was interesting as a mechanism to see
that 19 of you were thinking about subawards, and I have seen that some of you have already
deployed these subaward programs and have worked just really rapidly to get this funding
out the door, which is outstanding, and we applaud all the efforts that you're doing
on this front. Of these topical areas, our colleagues suggested
it would be great if you could pull a few examples just so people could see, like connectivity.
For us, encompasses a very large range of things. It's everything from hotspots to devices
with data plans to wifi extenders and repeaters, all the way up to equipment upgrades and so
much more. So if there's anything around internet access, people being able to access the internet,
we included it broadly in this category. Digital content, probably not surprisingly,
centered around ebooks, audiobooks, and databases. We have some examples here of the unemployment-related
things that you're thinking about in advance. The COVID response supplies range from sprays
and wipes to masks and gloves and sneeze guards and keyboard covers. And other materials that
would help libraries do a staged reopening of their physical spaces.
For those of you mentioning museums, we took one example from a state that was thinking
about summer learning and virtual programming where they could partner with museums if possible,
to make those virtual programming opportunities happen. Another state that mentioned tribes
specifically talked about targeting grants to the four tribal college libraries in the
state. And one of the states that was going to pursue a subgrant program outlined grants
of $250 to $1,000, and these would be for public libraries to help address digital inclusion
needs. Again, these are just examples. I would say
our communications manager at IMLS who saw this very initial digest of information was
very excited. She's always looking for stories to showcase, and we know that many of you
are in super preliminary stages of rolling out your CARES Act funds, but if you have
programs or projects that you have already kind of gotten off the ground, even in sort
of a conceptual format, if you want us to potentially showcase those on our website,
she would be interested in reaching out to you. If you are interested, if you are willing,
reach out to me or your program officer. This is Teri, it's tdevoe@imls.gov, and you can
tell me, hey, we'd like to have your communication manager reach out to us and showcase this
great thing we're doing with CARES Act funds. The more of those great stories that we can
start sending out will sort of be a return on investment for those folks that granted
us these funds and trusted us to do great things with them. So we're excited to start
showcasing things. And even if it's just a news release that you've already issued yourself,
send it our way, and we'll amplify those things through social media and find a way to showcase
them. I just wanted to put in a little plug from a communications standpoint.
All right, I just want to quickly revisit this idea that while the CARES Act funds have
their own little special purpose and waived match, if you think about CARES Act and Grants
to States as an overlapping Venn diagram, CARES Act largely comes under the umbrella
of Grants to States, and most of the Grants to States statutory provisions still apply.
So we've still got your five-year plan in play, you want your CARES Act funds to still
reflect that. The LSTA priorities are what the five-year plan reflects, so that's still
in play. If you have SLAA-determined eligibility, that is where we wouldn't force you to make
grants to museums and tribes if they are not part of your existing eligibility requirements.
But maybe think about partnering with them. Four percent administration is an optional
but allowable part of the CARES Act grants, just like they are with Grants to States.
So if you need to reserve a portion of CARES Act so that you can report on them at the
end of the cycle, pay your LSTA coordinator, et cetera, that is still part and parcel of
this grant program. Allowable costs are still in play. So, we
don't want you again to be doing things like throwing entertainment banquets or lobbying
with CARES Act funds. Just as they are not appropriate for Grants to States, they're
not appropriate for CARES Act. And things that you certified and signed off on, like
Children's' Internet Protection Act and non-construction still apply to CARES Act. So I'm going to
give those two topics a little bit of extra time on the next slides.
Essentially, Children's Internet Protection Act continues to apply to the CARES Act because
all of you, as state library administrative agencies, SLAAs, are subject to it. If you're
thinking about giving CARES Act funding or devices to libraries, if they receive E-rate
funds, then they are already subject to CIPA. The ones you need to worry about a little
bit more are the other libraries who don't already receive E-rate funds, and in that
instance, the SLAA needs to ensure that the recipient library or the recipient institution
has an internet safety policy in place for its devices. So we realize there's probably
more nuance to questions around this. Feel free to write to us with those questions,
and we will do our best to answer them. But that's kind of the high-level deal on CIPA.
And then we've got just a word on connectivity and construction. Construction is still unallowable
under the CARES Act. It's unallowable under the Grants to States statutory provisions,
which extend to match funds. We realize CARES Act does not have match funds attached to
it, but we always like to remind folks that we don't want to see construction invoked
in any part of your SPR report, whether it was paid for by federal dollars or state dollars
or local dollars. Just construction should not be reported there.
This includes things like broadband infrastructure projects that would require major construction
equipment or trenching or construction-related trades. There are a number of federal agencies
out in the universe that can fund last-mile projects, but IMLS at this moment is unfortunately
not one of them. So we just encourage you, especially with the digital inclusion focus
of the CARES Act, to proceed with caution with any kind of infrastructure upgrades that
you may be making. They have to adhere to our statute and avoid construction.
I'm going to go through just a visual here to show that you have at any given time overlapping
Grants to States awards. That is always the case. But what's happening now is that you've
also got a CARES Act award running in parallel with your 2020 Grants to States award, and
although it began at a slightly different period, it will end at the same time, September
30 of next year. And then you'll report on that in the SPR, together with your other
award. So I'm going to do a few slides quick on SPR reporting, and then make sure that
we have a little bit of time for questions. For CARES Act, we want you to report in the
SPR as you would for your normal Grants to States funds. The first reporting that we're
going to see on this will actually be this coming December, and it's financial only,
because you will report on both your fiscal year 2020 and your CARES Act awards in your
interim federal financial report. There is a space for log numbers to fit multiple ones,
and we've got an illustration of that on the slide. And again, this particular financial
report goes through the SPR. There's report language that is sometimes shown up in the
eGMS, but we want you to report this data in the SPR.
When it comes time to report your final CARES Act award, that will be next December of 2021.
They're going to be, again, reported alongside -- CARES Act and FY2020 awards will all be
reported together. The way we want you to differentiate any of your CARES Act awards
in the SPR, by giving them a title prefix of CARES Act. On the slide there's two examples
of projects that don't have that prefix, so presumably they're part of your fiscal 2020
allotment, and then there's a couple of examples that do have the CARES Act prefix.
So that would tell your program officer and the general public, when this gets out into
the SPR public view, that you've got a couple of different kinds of projects going on here.
And for any of your CARES Act projects, they work a little differently than your other
projects. The Act wasn't in place until this spring, and we didn't issue your awards until
April 21, so for any CARES Act projects, your start date should not be before April 21.
And your end date can be shorter. If you do some rapid response projects and they end
this fall, make sure that your end date in the SPR reflects that.
A note on the financials for the final report. This is your financial status report. So once
again, it's going to be combined funds for fiscal 2020 and CARES Act with two log numbers.
As much as possible, we want your CARES Act projects reported separately, but we realize
there might be some instances where a project that you report on next year uses both fiscal
2020 funds and CARES Act funds, and if that's the case, there's only one column for federal
funds in the SPR, in the budget area, so you can put your combined total in the numerical
field, but be sure in the description that you differentiate the CARES Act funds from
the fiscal 2020 LSTA funds so that we can know which funds were going where, as we're
reviewing those projects. So just as a summary, again, this coming year
you'll only need to report on some financial data around your CARES Act funds, and next
year you'll do the full reporting in the SPR and your CARES Act funds. And just a note
about maintenance of effort, because we know some of you have had questions about this.
MOE is always based on your three-year average. So we are not expecting you to report more
MOE funds next year because you received additional CARES Act funds this year. It's still based
on a three-year average, and we'll still have the future MOE waiver process for any states
whose budgets were affected this year and in future years. We understand that budgets
are very much in flux right now, and we will have the existing mechanisms of the MOE waiver
process to address those. And just a final note in the SPR system. We
know that especially with the financial status report, the FSR, there are some auto calculations
that happen around match in particular, and we are already working with our vendor to
make sure that things are appropriately reflected there next year. This will not affect your
interim FFR, but it is a note for the final, so we have time to work it out.
This is, at the end of the day, an unprecedented moment in the history of our program, and
we know that you are all rising to the challenge like superheroes. So we'll just end by saying
we're close to the end of the hour. We're probably not going to get through a lot of
questions, but we're happy to talk through individual concerns. We'll follow up after
the conference with individual questions that you've asked here, and we just want to thank
you now for all that you do to serve communities in need. It is more important than ever.
Deirdre, with our last two minutes, would you like to surface a question or two?
MS. GONSALVES: Sure. I have two questions regarding construction costs. One is is labor
for installing sneeze guards and other protective devices covered by this funding, and is internal
cabling allowable or is it construction? MS. DEVOE: This might be case-by-case questions.
We tend to say that if things can be installed without specialized labor, like if a staff
member could install something with a screwdriver and if it's moveable and could be disassembled
and taken to another place, then it could possibly be allowable. But as soon as you
start to invoke specialized construction trades and construction equipment, you're probably
tipping into the balance of unallowable. So if you want to follow up with a specific example,
your program officer can help you make that call.
MS. GONSALVES: And a broader question is the CARES Act apply to both libraries and museums?
MS. DEVOE: Yes. The broader CARES Act, which was the public law, mentioned both libraries
and museums, and also tribes. The Grants to States portion of the CARES Act is administered
by all of you, so we, because it's statutory, defer to your eligibility requirements. And
you set that eligibility. So if you can make grants to museum libraries, for example, then
they would be eligible entities if you determine that that's how you want to use the money.
But ultimately a lot of that eligibility is up to you.
MS. GONSALVES: Just one last question. Would you be able to share any examples of rapid
response projects? MS. DEVOE: Rapid response projects. I think,
given our time, I won't fumble around, but I know that some of you are already doing
response projects and buying devices and deploying devices to the field, so it runs the gamut,
and I have a feeling we're going to start to see a lot of coverage of these exciting
projects. With that, I'll just thank you again. Let
you know that we have a ten-minute break coming up, and after the ten-minute break is over,
you're going to hear, if you come back, reflections from our program officers, Michele and Madison,
about the SPR. So thanks for hanging in there with us, and again, if your questions wasn't
answered, we'll follow up with you after.