How Governors Used GEER Funds During the COVID-19 Pandemic

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The Governor’s Emergency Education Relief Fund, or GEER, was a federal pandemic fund that let governors direct emergency support to schools, colleges and other education organizations. Congress provided $4.256 billion over two rounds, not counting a separate set-aside for private schools.

Governors used that freedom in different ways, and federal audits later found problems in some states. In Oklahoma, the Bridge the Gap program gave families $1,500 microgrants, small grants for curriculum, tutoring and technology. The Education Department’s inspector general found in an audit issued July 18, 2022, that 11 percent of what families bought, including Christmas trees, televisions and air conditioners, did not appear to be education-related. The spending deadlines have passed, but each state’s records can still be checked.

The fund governors could steer

The Coronavirus Aid, Relief, and Economic Security (CARES) Act, enacted on March 27, 2020, provided $2.953 billion for GEER I. The law directed the U.S. secretary of education to make grants to governors with approved applications. It was a federal grant with state-level choices about the recipients, rather than a uniform benefit that families could claim from Washington.

The Coronavirus Response and Relief Supplemental Appropriations Act, enacted on December 27, 2020, provided $4.053 billion for GEER II, including a $2.750 billion reservation for Emergency Assistance to Non-Public Schools, or EANS. After that reservation, ordinary GEER II funding was $1.303 billion, bringing GEER I and II to $4.256 billion excluding EANS.

Two other CARES Act education funds followed set formulas. Under the act’s Elementary and Secondary School Emergency Relief Fund, or ESSER, states had to distribute at least 90 percent to school districts in proportion to their existing Title I, Part A allocations. Title I, Part A supports supplementary education services for disadvantaged students in schools with relatively high concentrations of children from low-income families. The CARES Act’s Higher Education Emergency Relief Fund directed its principal allocation to colleges using enrollment and Pell Grant factors. Pell Grants are federal student grants, a form of aid that generally does not have to be repaid. GEER worked differently: it let governors target emergency education support instead of requiring the same district distribution formula.

The federal GEER allocation formula gave 60 percent weight to the population ages 5 through 24 and 40 percent to the number of children counted under Section 1124(c) of the Elementary and Secondary Education Act. That count covers children ages 5 through 17 from families below the poverty level, in certain institutions for neglected or delinquent children, in publicly funded foster homes and in some families above the poverty level that receive qualifying state assistance payments. For this law, the definition of a state included the District of Columbia and Puerto Rico.

Flexibility came with federal limits

The original law allowed emergency grants to school districts the state education agency deemed most significantly affected by coronavirus. It also allowed grants to colleges the governor determined were most significantly affected. A broader provision allowed support for education-related entities the governor deemed essential to emergency education, including child care, early education, social and emotional support, and protection of education-related jobs.

The Education Department’s guidance allowed districts to use GEER for distance education, technology infrastructure and educator training, including online learning for students with disabilities, English learners, students experiencing homelessness and students in foster care.

Department guidance said governors could not award GEER money directly to individuals. They could instead give a grant to an eligible organization that, in turn, provided scholarships, financial assistance or microgrants consistent with the CARES Act.

The department explained that spending still had to be necessary and reasonable for the grant’s purpose under federal grant rules. The CARES Act required recipients to continue paying employees and contractors during coronavirus disruptions to the greatest extent practicable. States also had to keep their support for elementary, secondary and higher education in fiscal years 2020 and 2021 at or above the average of the three preceding fiscal years. The secretary could waive that requirement for states with a precipitous decline in financial resources.

The original act required districts receiving GEER to provide equitable services to eligible private-school students and teachers, worked out in consultation with private-school representatives. In practice, the public agency arranged the help, kept control of the money and owned anything bought with it; control did not pass to the private school.

Under the separate EANS program, the state education agency provided services or assistance, including permitted reimbursements, but could not make subgrants to nonpublic schools.

States chose different kinds of help

In a May 12, 2020, announcement, Kentucky’s education department said Governor Andy Beshear directed $30 million toward district digital infrastructure and remote food services. The Southern Regional Education Board’s account described Kentucky’s distribution as following the Title I, Part A formula to concentrate resources on districts with greater need. Kentucky’s choice used the governor’s flexible fund to reinforce district operations rather than build a separate family application program.

Pennsylvania’s February 2021 Act 1 distributed GEER II money among the following education sectors.

That allocation treated the education emergency as spanning several kinds of institutions, not only school districts.

Oklahoma’s Bridge the Gap program offered $1,500 microgrants for educational expenses, including curriculum, tutoring and technology. Families qualified at or below 185 percent of the federal poverty line, or above that line with financial documentation showing the pandemic’s negative impact.

Its Stay in School program offered financial assistance of up to $6,500 to low-income families of students attending nonprofit private schools who experienced pandemic financial hardship. Oklahoma required family income at or below 350 percent of the federal poverty line, which was $91,700 for a family of four, along with enrollment requirements for the student and conditions the school had to meet. That was a pandemic-era program with its own conditions, not a general entitlement to have private-school tuition paid. Both programs put GEER money close to individual families, which made controls on eligibility and spending especially important.

South Carolina’s Safe Access to Flexible Education (SAFE) Grants program proposed $32 million in tuition assistance for students attending private and independent schools during the 2020-2021 academic year. In Adams v. McMaster, the South Carolina Supreme Court held that the governor’s allocation used public funds for the direct benefit of private educational institutions, which the state constitution prohibits, in an opinion refiled December 9, 2020, after rehearing. Federal eligibility was only one part of the legal question; a state’s own constitution could prevent a proposed use.

Oklahoma’s audit followed the money past the award

In its July 18, 2022, audit, the U.S. Department of Education’s Office of Inspector General said Oklahoma could not document the awarding processes for four of five initiatives. As a result, the audit said, the state lacked assurance that $31 million of its $39.9 million grant went to initiatives that fit GEER’s purpose. That finding concerned how recipients were chosen, not what any particular purchase bought. The same audit found Oklahoma had reasonably monitored one of the five, the CARES Act Incentive Grants initiative.

For Bridge the Gap, auditors identified $652,720 in apparently noneducational purchases, 11 percent of the $6,126,614 in Bridge the Gap purchases, including televisions, air conditioners and Christmas trees. For those identified purchases, the auditors recommended that Oklahoma return the $652,720 or provide documentation showing education-related use or purchase with personal funds. That left room for Oklahoma to show the purchases were allowable.

ClassWallet operated the digital wallet and online marketplace used to hold grant funds and make payments. Oklahoma limited purchases to approved vendors but did not use an available control that would have limited them to preapproved items, the audit said. ClassWallet’s chief executive told auditors the state education secretary declined to use the item restriction. The audit reported that the secretary relied on approved vendors to protect the education purpose. A vendor can sell both educational and unrelated goods, so approving the seller does not by itself establish the purpose of every item.

The inspector general recommended that Oklahoma review the remaining Bridge the Gap purchases and return grant funds spent on unallowable items. In its response, Oklahoma did not state agreement or disagreement with the recommendations, said its use was consistent with Congress’s purpose, and identified corrective actions taken or planned.

Oversight.gov’s published listing showed 14 open recommendations for the Oklahoma report. That was the listing’s status on October 3, 2026; an open recommendation does not establish that Oklahoma has taken no corrective action since.

Spending, compliance and learning are different questions

In a separate audit of Michigan’s GEER grant, the Education Department’s inspector general said Michigan could not support recipient eligibility for five of seven programs, involving $5.4 million and four entities, and lacked a written plan for monitoring subrecipients, the organizations a state passes grant money to. In another audit, the inspector general found Missouri had appropriate selection processes for two of three programs, but incorrectly implemented the methodology for the third, preventing auditors from determining whether recipients were among those most significantly affected.

In 2020, the Government Accountability Office, or GAO, reported that the Education Department was still developing a way to check whether grantees met GEER’s initial reporting requirements and had not yet announced how quarterly reports would be implemented. That was an early limitation, not a description of every later monitoring effort.

The department’s April 2024 GEER reporting guide required states to report grant amounts, expenditures and subrecipient information, including district and college names and award and spending figures. It instructed states to continue annual reporting until all GEER funds were liquidated, meaning paid out.

The guide also collected counts of students receiving GEER assistance and expenditure totals for the 2021-2022 and 2022-2023 school years. A count of assisted students measures reach; it does not say whether those students learned more than they otherwise would have.

An award shows who was promised funding, an expenditure shows how much was spent, and an audit asks whether decisions and charges followed the grant’s rules. None of those, on its own, establishes that GEER improved learning.

The deadlines passed, but the records still matter

Governors had to award their GEER I funds within one year of receipt or return them for reallocation. GEER II likewise had a one-year deadline for state awards.

Obligating money means making a binding commitment to spend it; paying the resulting bill is a separate step. GEER I funds had to be obligated by September 30, 2022. The corresponding GEER II deadline was September 30, 2023, a date that counted an extra period federal law adds to the time grantees have to commit money.

Department guidance generally allowed 120 days after the obligation deadline to liquidate funds, with case-by-case extensions for properly obligated spending. It said the department could not extend the statutory obligation deadline, and unobligated funds had to return to the U.S. Treasury.

The initial federal reporting requirements called for governors, within 45 days of receiving funds, to report their recipient-selection processes and criteria. To examine a state’s choices, start with the award list and the selection criteria, then look for the expenditure record and any audit of the same program. Keep the program name and funding round together when matching those records; EANS, GEER I and GEER II do not represent the same pot of money.

For a nationwide starting point, use the federal Pandemic Oversight website’s data download for the Education Stabilization Fund, the larger pandemic education fund that includes GEER. The site says that, effective July 14, 2025, its dashboards are no longer available, apart from a new one on Paycheck Protection Program loans, but the data can still be downloaded. For details about individual recipients, match the state’s award list to the subrecipient names and figures collected in the GEER annual reports. Pennsylvania’s education department, for example, publishes named recipients and their GEER II allocations.