ESSER III carryover funds after-school programs represent one of the last significant opportunities for districts to deploy pandemic relief dollars before the federal liquidation window closes. With the September 30, 2024 obligation deadline now passed and the liquidation period extended through January 28, 2025 — and with many states operating under their own carryover provisions — business managers and curriculum directors across the country are sitting on unspent funds they may not realize they can still use. The stakes are straightforward: spend it on allowable activities or send it back. This post breaks down exactly what qualifies, what documentation you need, and how after-school enrichment fits into a compliant, defensible spend-down plan.
Understanding the Carryover Window Most Districts Are Getting Wrong
The confusion typically starts with conflating two separate deadlines: the obligation deadline and the liquidation deadline. The obligation deadline was when districts needed to have committed funds — meaning contracts signed, purchase orders issued, or services formally authorized. The liquidation deadline is the later date by which the actual payments must be made against those obligations.
Under ESSER III, the federal obligation deadline was September 30, 2024. The liquidation deadline — the point at which funds revert if not spent — was January 28, 2025 under the original federal timeline, though states that applied for and received extensions may have different windows. Some states, including California, Texas, and New York, negotiated extended carryover periods that push liquidation timelines into mid-to-late 2025. If your district is in one of those states and your business manager has been operating on the federal default timeline, you may have more runway than you think — or less, if you have not yet verified your state’s specific provisions.
The critical action here is to contact your state education agency directly and pull the specific carryover authorization letter for your district. Do not rely on second-hand summaries. The variation between states is significant, and audit findings related to ESSER spending have been on the rise. Knowing your exact liquidation date is the foundation of every other decision in your spend-down plan.
Allowable Uses That Cover After-School Enrichment
ESSER III was written with broad allowable use language, and after-school enrichment programs fall squarely within several of the explicitly authorized categories. Here is where the alignment is strongest:
Academic Recovery and Extended Learning Time
ESSER III explicitly covers activities designed to address learning loss, and extended learning time — including before- and after-school programs — is a defined allowable use. This covers vendor contracts for academic enrichment programs, tutoring-integrated enrichment, and curriculum materials used in out-of-school-time settings. Programs that combine coding instruction with math skill reinforcement, for example, document this alignment clearly in their program design. Kodely’s STEM and coding programs are structured to connect to grade-level academic standards, which makes the learning loss rationale straightforward to document.
Mental Health, Social-Emotional Learning, and Student Well-Being
Social-emotional learning programs qualify under ESSER III’s well-being provisions. This includes after-school programming specifically designed to build self-regulation, relationship skills, and resilience — competencies the research literature consistently ties to post-pandemic recovery. Districts that have added structured SEL enrichment as a standalone after-school offering have used this category to cover both the vendor and the staff coordination costs.
Extracurricular and Enrichment Activities That Address Equity Gaps
ESSER III allows funds to be used for programs that address educational inequities exacerbated by COVID-19. For Title I schools in particular, this is a strong basis for enrichment activities in arts, culinary education, robotics, environmental science, and entrepreneurship — areas where access gaps between high-need and wealthier districts are well documented. The Department of Education has confirmed in multiple guidance documents that enrichment activities serving high-need populations can qualify under this rationale when the equity connection is documented.
Vendor Contracts and Staffing
Both vendor contracts and staff costs associated with enrichment programs are allowable. This includes contracts with outside enrichment providers, stipends for teachers running after-school programs, and coordinator salaries. Materials, equipment, and professional development for program staff also qualify. The key is that costs must be reasonable, necessary, and tied to an allowable purpose — all of which are documentable for structured after-school enrichment.
The Compliance Documentation You Need Before You Spend
Auditors reviewing ESSER spending are looking for a clear paper trail that connects each expenditure to an allowable use, a documented need, and evidence of implementation. For after-school enrichment programs, that documentation package should include:
- A written program rationale that connects the enrichment activity to an ESSER III allowable use — specifically referencing learning loss recovery, student well-being, or equity — and citing the student population served
- A signed vendor contract or purchase order dated within the obligation window
- Attendance records showing which students participated and at which schools
- Evidence of alignment with district improvement goals or the ESSER III plan already on file with your state
- Invoices and payment records tied to the specific program dates and deliverables
- For SEL programs specifically: a brief description of the program model and how it addresses student well-being outcomes
Do not treat documentation as an afterthought. Districts that have faced audit findings on ESSER spending typically had the right activities but incomplete records. The program rationale document in particular is something many districts skip — and it is the single most important piece when an auditor asks why a specific vendor was paid with federal relief funds.
A Spend-Down Checklist for After-School Enrichment Categories
If you are working through a carryover spend-down plan right now, use this checklist as a starting framework organized by enrichment category:
STEM, Coding, and Robotics
- Confirm vendor contract is signed and dated within the obligation window
- Document alignment with math or science learning loss goals
- Collect student roster and attendance by session
- Retain curriculum materials and lesson descriptions showing academic content
Social-Emotional Learning and Arts
- Document the SEL framework or standards the program references
- Note how the program addresses well-being outcomes tied to pandemic disruption
- Retain any pre/post surveys or behavioral data if available
- Collect attendance and session logs
Culinary, Environmental Science, and Entrepreneurship
- Write a short rationale connecting the program to equity access gaps at your school
- Document the academic content embedded in the program (math, science, literacy connections)
- Confirm materials and supply costs are itemized in the vendor contract or purchase order
- Retain invoices showing costs within the liquidation window
How Kodely Works With Districts on Compliant Enrichment Contracts
Kodely has worked with hundreds of Title I schools and districts that use federal funding — including Title IV-A, 21st CCLC, and ESSER dollars — to run after-school enrichment programs. When we contract with a district, we provide documentation support that is designed to hold up to auditor scrutiny: clear program descriptions tied to allowable use language, session-by-session attendance tracking, alignment summaries for each program category, and invoicing structured to match the liquidation timeline.
For districts working against a carryover deadline, we can move quickly. Program contracts can typically be structured, executed, and implemented within a matter of weeks — meaning even districts with tight remaining windows can obligate funds and begin delivery before the deadline closes.
The window to act on ESSER III carryover funds after-school programs is narrow, but for districts that move now, it represents a real opportunity to build enrichment infrastructure at Title I schools that can sustain beyond the federal funding cycle.
Frequently Asked Questions
When is the ESSER III spending deadline?
Districts must obligate ESSER III funds by September 30, 2024 and liquidate by January 28, 2025 (or March 30, 2026 with approved extension).
Can ESSER III funds be used for after-school enrichment?
Yes. Allowable uses include expanded learning programs, summer enrichment, extended day, and staff training for after-school programs.
What happens after ESSER III sunsets?
The “ESSER cliff” — districts must transition to state funding (ELOP, ASES) or find replacement grants. California districts with strong ELOP practice are best positioned.
What are common ESSER III audit findings?
Missing supplement-not-supplant documentation, lump-sum vendor invoicing without allowable-use coding, missing evidence of spending on ESSER-eligible activities.
Related reading from Kodely
About the author
Sri Akash Kalimili is the founder of Kodely, a MWBE-certified K-8 STEM and arts enrichment provider currently operating at 40+ California districts across ELO-P, Prop 28, CCSPP, and LREBG. Kodely delivers school-day, afterschool, and non-schoolday coverage with itemized session-level invoicing coded to specific funding lanes and supplement-not-supplant memos included in every scope of work.
This post is a working operator’s reference based on programming we run daily at California district partners. It is not legal or fiscal advice. Every statute citation has been verified against primary sources (leginfo.legislature.ca.gov, CDE.ca.gov, EAAP.ca.gov). Always verify current law with your CBO and district counsel.