Answer: Yes, with a caveat. With schools closed and students engaged in distance learning (whether optional or required), internet connectivity is essential.  Most districts are providing these resources using regular district funds, or Title I funds. Students experiencing homelessness should receive whatever other students are receiving, before going into the Title IA homeless set-aside or McKinney-Vento subgrant funds. Also, technology and connectivity are allowable uses for the $13 billion CARES Act Elementary and Secondary School Emergency Relief Fund.

If internet connections are not available through other means, in terms of McKinney-Vento funds, internet connectivity in the current circumstances falls under two allowable uses of funds in 42 USC 11433(d):

“(7) The provision of services and assistance to attract, engage, and retain homeless children and youths, particularly homeless children and youths who are not enrolled in school, in public school programs and services provided to nonhomeless children and youths.”


“(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.”

In terms of Title IA set-aside funds, the internet connection falls well within ED’s guidance:

“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.”

Internet connectivity is absolutely necessary for students to take advantage of educational opportunities at this time.  If a company in your area is offering free internet, and your homeless students are able to access that service, then you should not use Title IA funds to pay for internet. However, often, students will need to pay a connection fee or some monthly fee for internet, which they are unable to afford. No other resources are reasonably available.

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