The purpose of the Small, Rural School Achievement (SRSA) program is to provide small, rural local educational agencies (LEAs) 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. LEAs are entitled to funds if they meet eligibility and application requirements. Awards are issued annually, and award amounts are determined using a formula.

This is one of a number of Department programs that provides funds that could be used to support broadband access. School districts may use Small, Rural School Achievement funds to pay for activities that are allowable under Title I, Part A, Title II, Part A, Title III, Title IV, Part A, and Title IV, Part B of the ESEA. 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 Small, Rural School Achievement 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 completed building. The term does not include building construction, structural alterations to buildings, building maintenance, or repairs.”

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