The purpose of the Rural and Low-Income School (RLIS) grant program is to provide poor, rural districts with financial assistance to address the unique needs of rural school districts that frequently lack the personnel and resources needed to compete effectively for Federal competitive grants and receive formula grant allocations in amounts too small to be effective in meeting their intended purposes. The grant is non-competitive, and eligibility is determined by statute. Awards are issued annually to state educational agencies (SEAs), which make sub- grants to local educational agencies (LEAs) that meet the applicable requirements. Awards are made to all SEAs with eligible LEAs that apply and meet the applicable requirements of the act (see legislative citation above).

This is one of a number of Department programs that provides funds that could be used to support broadband access. School districts may use Rural and Low-Income School funds to pay for activities that are allowable under Title I, Part A, Title II, Part A, Title III, and Title IV, Part A, as well as parental involvement activities. The allowability of costs is always situation and program specific.

For that reason, if you decide to use funds under one of these programs for costs related to device or mobile hotspot access, you must be sure that the use of the funds is, under the specific circumstances of the expenditure and the program authority selected, reasonable and necessary for the purposes of that program, and does not violate other program requirements, such as the “supplement not supplant” requirement. We also note that, while funds under one of these programs can be used on broadband access, the programs’ purpose is not primarily focused on that issue.

The use of Rural and Low-Income School Program funds for broadband infrastructure must be consistent with the definition of “minor remodeling” in 34 CFR Part 77. That definition of minor remodeling means “minor alterations in a previously completed building. The term also includes the extension of utility lines, such as water and electricity, from points beyond the confines of the space in which the minor remodeling is undertaken but within the confines of the previously

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