Answer: For McKinney-Vento funds, yes. This expense would fall under allowable use (16) in the law:

“(16) The provision of other extraordinary or emergency assistance needed to enable homeless children and youths to attend school and participate fully in school activities.”

For Title I funds, the question is whether this is an “educational opportunity.” Arguably, if it is a school activity, it is an educational opportunity. Sports have lots of benefits related to attendance, academic achievement, and high school graduation. The Guidance from USED on this is:

“Two principles govern the use of Title I, Part A funds to provide such services to homeless students. First, the services must be reasonable and necessary to assist homeless students to take advantage of educational opportunities. (ESEA section 1113(c)(3)(A); 2 CFR § 200.403(a)). Second, Title I, Part A funds must be used only as a last resort when funds or services are not available from other public or private sources….”

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