School Bus Meal Delivery Could Be Allowable Cost Under Title I

April 9, 2020

An Evergreen Public Schools bus in Washington state delivers a meal to a homebound student during COVID-19 closures.

Guidance released by the U.S. Department of Education outlines funding flexibilities available to school districts to support continued student learning during the COVID-19 school closures, which could include the new school bus operating costs related to food delivery to economically disadvantaged students covered by Title I of the federal Elementary and Secondary Education Act (ESEA).

According to the guidance issued by Education Secretary Betsy DeVos on Monday, states can submit a brief form that the federal agency will respond to in one business day and determine if the state can receive the flexibility to use funds under Titles I, II, III, IV and V of ESEA as well as the McKinney-Vento Homeless Children and Youth Program.

Under normal operations, some school districts use student transportation as a service under their Title I programs.

But amid national school building closures in response to the coronavirus pandemic, school districts are now also utilizing their school buses or those operated by contractors for entirely new missions to support student meals and distance learning. School Transportation News asked the U.S. Department of Education if these considered allowable costs under Title I.

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“The answer would depend, for example, on whether the activity for which the bus would be used is an allowable Title I activity to improve the academic achievement of Title I students,” a U.S. Department of Education spokesperson responded in an email on Thursday, “and, if it is, whether there are other sources of funds available to the district to pay for the activity.”

The spokesperson pointed that while nutrition and other social services are usually not a part of a school district’s Title I program, student transportation services may apply in certain circumstances, such as using the school bus to deliver free or reduced meals, and potentially the delivery of school supplies to students who don’t have access to online distance learning programs.

“[I]f these services are not otherwise available to Title I students in the school district and no other funds from other sources are reasonably available to provide them to Title I students, then a school district may use a portion of its Title I funds as a last resort to provide Title I students with these services, if necessary to improve the students’ academic achievement,” the spokesperson added. “This could include the operating costs of transporting meals to Title I students, as long as the costs are reasonable and necessary to accomplish this purpose.”