About the Governor’s Emergency Education Relief (GEER) Fund

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The COVID-19 pandemic triggered unprecedented disruption across the United States education system in early 2020, affecting students and institutions from preschool through higher education. Widespread school closures forced a sudden shift towards remote learning, exposing and exacerbating pre-existing inequities. Challenges quickly mounted, including a significant digital divide, concerns about virtual instruction effectiveness, and the looming threat of learning loss.

In response to this national emergency, Congress enacted a series of legislative measures providing substantial federal aid. Central to this effort was the creation of the Education Stabilization Fund (ESF) under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, signed into law in March 2020. The ESF’s funding was later expanded by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act in December 2020 and the American Rescue Plan (ARP) Act in March 2021. The overarching goal of the ESF was to “prevent, prepare for, and respond to coronavirus” impacts on education.

The ESF was structured around three primary relief funds:

• Elementary and Secondary School Emergency Relief (ESSER) Fund
• Higher Education Emergency Relief Fund (HEERF)
• Governor’s Emergency Education Relief (GEER) Fund

While ESSER targeted K-12 schools through state and local educational agencies, and HEERF focused on postsecondary institutions, GEER possessed a unique characteristic: funds were awarded directly to state Governors. This design granted Governors significant flexibility to allocate resources across the entire education spectrum to address the most pressing pandemic-related needs within their states.

About GEER: Origins, Purpose, and Funding

Legislative Roots and Purpose

The GEER Fund emerged as part of the initial federal response to the pandemic’s educational disruptions.

GEER I (CARES Act): The foundation for GEER was laid in the CARES Act enacted in March 2020. Its core purpose was to equip Governors with a flexible pool of funds to provide emergency assistance to local educational agencies (LEAs), institutions of higher education (IHEs), and other education-related entities grappling with the immediate consequences of the COVID-19 pandemic. The funding aimed to support educational service continuity during closures and help maintain institutional functionality.

GEER II (CRRSA Act): As the pandemic persisted, Congress provided additional resources through the CRRSA Act in December 2020. This legislation created GEER II, offering supplemental funding to states that had already received GEER I grants. A critical distinction emerged with GEER II: the CRRSA Act mandated that $2.75 billion be specifically reserved for the newly created Emergency Assistance to Non-Public Schools (EANS) program. This carve-out provided dedicated support for private schools but reduced the amount of GEER II funds available for the Governor’s discretion.

The establishment of GEER alongside the larger ESSER fund represented a deliberate federal strategy. ESSER, distributed primarily to LEAs based on poverty indicators (Title I formulas), aimed to provide widespread relief through existing K-12 structures. GEER offered Governors a flexible tool to address specific state priorities, target entities perhaps missed by ESSER formulas, or pilot innovative responses.

Funding Amounts and Allocation

The GEER program represented a significant portion of the overall Education Stabilization Fund:

Total Appropriations:

• CARES Act (GEER I): approximately $3 billion
• CRRSA Act (GEER II): $4.05 billion, with $2.75 billion reserved for EANS I
• Total discretionary funding available to Governors: approximately $4.26 billion

State Allocation Formula: Funds were distributed to states via a statutory formula, with 60% based on each state’s relative share of the population aged 5-24, and 40% based on the state’s relative share of children counted under Section 1124(c) of the Elementary and Secondary Education Act (low-income students).

Timelines

Congress intended GEER funds to be deployed relatively quickly:

• GEER I (CARES Act) funds: available for obligation through September 30, 2022
• GEER II (CRRSA Act) funds: available for obligation through September 30, 2023

The “Tydings Amendment” typically allowed for a one-year extension. Governors were required to award funds to subrecipients within one year of receiving the state’s allocation; any funds not awarded within that timeframe had to be returned.

Eligibility Landscape: Who Could Access GEER Funds?

The GEER Fund offered Governors considerable latitude in selecting recipients, guided by broad categories and criteria in the authorizing legislation.

Eligible Subrecipients

Governors could distribute GEER funds via subgrants or contracts to three main categories:

1. Local Educational Agencies (LEAs): Public school districts, including charter schools that function as LEAs
2. Institutions of Higher Education (IHEs): Colleges and universities, both public and private
3. Other Education-Related Entities: A broad category encompassing organizations involved in supporting education. The Department of Education defined an “education-related entity” as any governmental, non-profit, or for-profit entity providing services that support preschool, elementary, secondary, or higher education. Examples included state agencies (early childhood education, vocational rehabilitation, mental health), public libraries, community centers, education-focused non-profits, non-public schools, charter management organizations, and child-care centers.

Key Eligibility Criteria

The legislation established two primary pathways for eligibility:

1. “Most Significantly Impacted”: For LEAs and IHEs to receive funds directly based on pandemic impact, they generally needed to be identified as being “most significantly impacted by coronavirus.” The authority for making this determination rested with the State Educational Agency for LEAs and with the Governor directly for IHEs.
2. “Deemed Essential”: Alternatively, Governors could support any LEA, IHE, or other education-related entity if the Governor “deems [it] essential” for carrying out specific emergency functions. These functions included providing emergency educational services, childcare and early childhood education, social and emotional support, and protecting education-related jobs.

Crucially, neither the CARES Act nor initial Department of Education guidance provided specific federal definitions for “most significantly impacted” or “deemed essential.” This lack of precise definition granted substantial discretion to Governors and SEAs to establish their own criteria based on state-specific circumstances.

The Non-Public School Question: Equitable Services

A complex aspect of GEER eligibility involved non-public (private) schools. The CARES Act included a provision requiring LEAs that received funds from the Education Stabilization Fund to provide “equitable services” to eligible students and teachers in non-public schools within the LEA’s boundaries.

The law stipulated these services were to be provided “in the same manner as” Section 1117 of the Elementary and Secondary Education Act (ESEA), the provision governing equitable services under Title I. This typically involves consultation between the LEA and non-public school officials to determine needs and services, with the LEA maintaining control of the funds.

Ambiguity arose regarding how to calculate the funding LEAs should reserve for these services. The Department of Education initially suggested LEAs calculate the proportional share based on total enrollment of non-public school students, rather than solely on low-income students (the standard Title I method). This interpretation would have significantly increased funding directed toward private school services.

This guidance sparked controversy and legal challenges. Federal courts ultimately agreed with the challengers and vacated the rule. The Department clarified that the equitable services calculation should follow the standard ESEA Section 1117 methodology, based on the proportionate share of low-income children.

Flexibility in Action: How GEER Funds Could Be Used

A hallmark of the GEER Fund was the significant flexibility granted to Governors in determining how funds would address the diverse educational challenges posed by the pandemic. While subrecipients had to adhere to the overall purpose of preventing, preparing for, and responding to COVID-19, Governors could tailor the use of funds to specific state priorities.

Governor’s Discretion

Unlike ESSER funds, where 90% was mandated to flow directly to LEAs based on formula, GEER funds provided Governors with a discretionary pool to target needs across the P-20 spectrum (preschool through higher education) and among various education-related entities. This allowed for potentially more nimble or targeted responses than formula-driven allocations.

Key Allowable Uses

The legislation and subsequent guidance outlined a broad range of permissible activities:

Supporting Continued Operations and Services: Providing general emergency support to help educational entities continue providing services and maintain basic operational capacity amid pandemic disruptions.

Technology and Remote Learning: A major investment area across many states, including:

• Purchasing internet-connected devices for students and staff
• Providing internet access through mobile hotspots, wireless service plans, or community Wi-Fi installations
• Acquiring hardware and software for remote teaching and learning
• Subscribing to or developing digital learning content and online tools
• Covering costs for accessible digital materials for students with disabilities and English learners
• Funding professional development for educators on effective online instruction
• Investing in broader technology infrastructure improvements

Addressing Learning Loss: Supporting summer learning and enrichment programs, afterschool programs, high-dosage tutoring, and other supplemental academic supports designed to mitigate the impact of lost instructional time.

Personnel Costs: Protecting education-related jobs, supporting personnel and payroll activities, or hiring additional staff needed for pandemic response, such as mental health professionals or tutors.

Childcare and Early Childhood Education: Supporting childcare and early learning programs.

Social-Emotional and Mental Health Support: Funding for counselors, psychologists, social workers, and programs designed to promote well-being.

Construction and Renovation: Minor construction, remodeling, and repairs necessary to respond to COVID-19, such as improving indoor air quality or renovating spaces for better social distancing.

Higher Education Specifics: Direct student financial aid, academic support services, institutional support for security and administrative functions, and student services focused on emotional and physical well-being.

Other Uses: Remote food services, cleaning supplies, personal protective equipment (PPE), support for homeless children and youth, workforce preparation programs, and controversial microgrants directly to parents.

Spotlight on State Choices

The broad discretion afforded by GEER led to widely varying implementation strategies:

• Pennsylvania: The state legislature directed $46 million in GEER II funds to specific sectors: Career and Technical Education Centers, non-public entities serving students with disabilities, Community Colleges, and the Pennsylvania State System of Higher Education.
• Kentucky: Governor Beshear allocated $30 million in GEER I funds to LEAs using the federal Title I formula, concentrating resources in higher-need districts for digital infrastructure and remote food services.
• Oklahoma: Launched several distinct initiatives alongside direct grants to LEAs, including the “Bridge the Gap” program offering microgrants to low-income families for educational expenses, the “Stay in School” fund providing tuition assistance for private school students, the “Learn Anywhere Oklahoma” initiative for online curriculum access, and the “Skills to Rebuild” program for adult job training.
• South Carolina: Governor McMaster attempted to use $32 million of the state’s GEER I allocation to create the “Safe Access to Flexible Education” (SAFE) Grants program for private school tuition vouchers. This was challenged and struck down by the South Carolina Supreme Court as violating the state constitution’s prohibition on direct aid to non-public schools.
• California: Combined state funds with federal GEER and Coronavirus Relief Fund money to create a $5.3 billion Learning Loss Mitigation Block Grant, distributing funds to LEAs based on vulnerable student concentrations to support supplemental learning.

These examples demonstrate the spectrum of GEER implementation, ranging from formula-based distributions for public school infrastructure to targeted support for higher education sectors, large-scale block grants addressing learning loss, and novel programs involving direct payments or private school support.

Ensuring Accountability: GEER Reporting and Oversight

Given the substantial federal investment and flexibility afforded to Governors, mechanisms for reporting and oversight were established to promote transparency and ensure funds were used appropriately.

Mandatory Reporting Requirements

Several layers of reporting were mandated for states receiving GEER funds:

Initial 45-Day Report: Upon receiving their GEER I allocation, Governors had to submit an initial report to the Department of Education outlining their planned process for awarding funds and describing the criteria used to determine which entities were “most significantly impacted by coronavirus” or “essential for carrying out emergency educational services.”

Annual Performance Reports (APRs): States had to submit these reports annually, detailing how both the state and its subrecipients expended GEER funds during the relevant performance period, typically aligned with the state’s fiscal year.

FFATA Reporting: Under the Federal Funding Accountability and Transparency Act, states receiving GEER funds were required to report monthly on any subawards valued at $30,000 or more through the federal System for Award Management (SAM.gov).

Other Reporting: States also had to assure compliance with any other specified reporting requirements and report specifically on any GEER funds used for administrative or executive salaries if permitted by the state.

Fiscal Guardrails

Several fiscal provisions were included to guide GEER fund use and protect state education budgets:

Maintenance of Effort (MOE): A key provision required states to maintain their own financial support for both K-12 and higher education in fiscal years 2020 and 2021 at least at the average level provided in the three preceding fiscal years. This ensured federal emergency aid supplemented, rather than replaced, state funding.

Continued Payment of Employees and Contractors: The CARES Act required all ESF recipients to continue paying their employees and contractors during any period of closure or disruption related to COVID-19, to the greatest extent practicable.

Allowable Costs: All expenditures had to comply with federal Uniform Guidance cost principles, meaning costs charged to the grant must be necessary, reasonable, allocable to the grant’s purpose, and adequately documented.

Oversight Mechanisms

Accountability for GEER funds involved multiple layers of oversight:

• U.S. Department of Education: Established guidance, collected and reviewed state reports, provided technical assistance, and took enforcement actions if necessary.
• Office of Inspector General (OIG), ED: Conducted independent audits and investigations, specifically targeting pandemic relief funds, including GEER. They conducted audits of GEER I grants in several states, notably Michigan, Missouri, and Oklahoma.
• Pandemic Response Accountability Committee (PRAC): Coordinated oversight efforts among federal Inspectors General regarding pandemic-related spending.
• Government Accountability Office (GAO): Conducted broad oversight of federal programs, including pandemic relief efforts.
• State-Level Monitoring: States were expected to monitor their own subrecipients to ensure compliance with grant terms and federal regulations.

Despite these mechanisms, OIG audits and other investigative reports often emerged well after the initial disbursement of GEER funds, identifying problems after they occurred rather than preventing them in real-time.

Making a Difference?: The Impact of GEER Funds

Assessing the precise impact of GEER funds is challenging, given its distribution alongside much larger federal relief streams like ESSER and HEERF. However, available data point to several key areas where GEER funds likely made a difference.

Supporting Learning Continuity

A primary focus, especially in the early pandemic stages, was ensuring education could continue despite physical school closures:

• Bridging the Digital Divide: GEER funds were widely used to purchase devices and secure internet connectivity for students and educators lacking access at home, enabling remote and hybrid learning models.
• Teacher Preparedness: Funds were invested in professional development to equip teachers with skills for effective online instruction.

These investments likely had impacts beyond the immediate crisis, potentially improving capacity for blended learning, personalized instruction, or future responses to disruptions.

Addressing Pandemic Impacts

As the pandemic persisted, focus broadened to mitigating its effects on student learning and well-being:

• Learning Loss Mitigation: GEER funds contributed to high-impact tutoring, summer learning programs, afterschool support, and other supplemental instruction, often targeting students disproportionately affected by the pandemic.
• Mental and Physical Health: Funds supported social-emotional learning programs, increased access to counselors and psychologists, and addressed basic needs like food security.
• Supporting Specific Populations: Governors often targeted funds toward student groups facing greater barriers, such as students with disabilities, English learners, low-income families, students of color, first-generation college students, foster youth, and homeless students.
• Higher Education Impact: In the postsecondary sector, GEER funds played a role in supporting student retention and success through direct financial aid, mental health counseling, and basic needs support.

Challenges and Controversies: Scrutiny of GEER Implementation

Despite its intended purpose as emergency relief, GEER implementation faced significant challenges and controversies. The flexibility granted to Governors, while allowing tailored responses, also opened the door to questionable allocation decisions, mismanagement, and lack of transparency in some states.

Allocation Decisions and Priorities

The discretion afforded to Governors led to several high-profile controversies:

Private School Funding:

• Oklahoma: Governor Stitt allocated $10 million to the “Stay in School” program for private school tuition assistance. Investigations by the ED OIG and a state Multi-County Grand Jury found significant issues, including preferential early access for certain schools and funds awarded to families that didn’t experience pandemic hardship.
• South Carolina: Governor McMaster allocated $32 million to the SAFE Grants program for private school tuition payments. This was challenged and ultimately struck down by the state Supreme Court as unconstitutional.

Parent Microgrants (Oklahoma): The “Bridge the Gap” program provided $1,500 microgrants to low-income families for educational materials but became notorious for misuse. The ED OIG identified over $650,000 in non-educational purchases, with subsequent reviews suggesting the total misused amount could exceed $1.7 million. The core issue was a profound lack of controls over the ClassWallet platform, essentially allowing recipients to purchase almost anything from approved vendors.

Higher Education Allocations: Some states directed GEER funds exclusively to certain higher education sectors, raising questions about equitable distribution.

Oversight Failures and Mismanagement

Independent audits and investigations revealed significant lapses in oversight and management in several states:

OIG Audits:

• Oklahoma: The OIG found the state couldn’t adequately support or document its processes for awarding $31 million across four initiatives. They confirmed widespread questionable purchases under Bridge the Gap due to failed controls and found failures in adhering to federal requirements.
• Michigan: The OIG found the state couldn’t support its eligibility determinations for entities receiving funds under five programs totaling $5.4 million and lacked adequate monitoring plans.
• Missouri: While finding better compliance, the OIG determined that Missouri didn’t correctly implement its own methodology for one initiative and initially lacked robust monitoring protocols.

Oklahoma Grand Jury Report: A Multi-County Grand Jury investigation, concluding in October 2024, characterized the state’s handling of GEER funds as “irresponsible, disappointing, and indefensible” and “grossly negligent.” It highlighted the lack of internal controls, bypassing the experienced State Department of Education, delegating authority to unvetted private non-profits, and wasting millions in emergency aid.

Transparency and Effectiveness Concerns

Broader concerns included:

• Lack of Transparency: Insufficient transparency in how some Governors’ offices made allocation decisions, particularly when deviating from established educational agencies or formulas.
• Effectiveness Questions: Documented misuse and mismanagement raised questions about whether GEER funds achieved their intended purpose when spent on ineligible items or managed through ineffective programs.
• Administrative Burden: The complexity of managing and reporting on federal grants during a crisis posed real challenges for state capacity.

These controversies illustrate the potential downsides of granting broad flexibility without robust accountability structures. The significant differences in outcomes between states like Missouri (relatively compliant) and Oklahoma (widespread issues) indicate that state-level governance and oversight capacity were critical factors in determining effective GEER administration.

Lessons from the Governor’s Emergency Education Relief Fund

The Governor’s Emergency Education Relief Fund emerged as a distinct component of the federal response to the pandemic’s impact on education. Designed to provide Governors with approximately $4.3 billion in flexible funding, GEER aimed to empower state leaders to address urgent and diverse needs across education, complementing the larger ESSER and HEERF programs.

In many instances, GEER funds supported critical initiatives: bridging the digital divide, enabling remote learning, providing crucial financial aid and mental health support in higher education, and launching targeted programs addressing learning loss or supporting specific sectors like career and technical education.

However, the GEER story is also marked by significant challenges. The very flexibility that defined it proved to be a double-edged sword. Investigations documented alarming instances of mismanagement, waste, and lack of basic internal controls. Controversial allocation decisions led to misspent funds and raised serious questions about whether resources consistently reached intended beneficiaries or addressed the most pressing emergency needs.

The GEER experience offers several critical lessons for future emergency relief programs:

• Flexibility Requires Robust Guardrails: Broad discretion must be accompanied by clear federal expectations, strong state-level oversight capacity, and rigorous internal controls.
• Oversight Capacity is Paramount: The ability and willingness of state agencies to effectively manage federal grants and monitor subrecipients are crucial determinants of program success.
• Transparency is Non-Negotiable: Decisions regarding the allocation of public funds, especially discretionary emergency aid, must be made transparently with clear documentation of criteria and processes.
• Political Context Matters: Flexible funding streams can become entangled in state-level political dynamics and policy agendas. Mechanisms should encourage needs-based allocation aligned with emergency purposes.
• Measuring Impact Remains a Challenge: Evaluating the true impact of specific emergency funds amidst overlapping programs and complex societal factors is difficult.

The GEER Fund represented a unique experiment in federal emergency education aid, attempting to balance federal resources with state-level discretion. While it facilitated important responses to the pandemic’s immediate challenges in many areas, its legacy is significantly tarnished by documented failures in oversight and management in certain states. The lessons learned should serve as vital considerations in shaping more effective and responsible federal responses to future crises impacting America’s students and educational institutions.

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