Paula Love 
This 2021 Building the Bridge episode has Wendy Oliver interviewing funding expert Dr. Paula Love about the first rounds of federal COVID-19 relief for schools. The section added below follows what happened to those funds after the deadlines discussed in the episode, using federal and education-association sources from 2025.
On this timely episode, renowned funding expert Dr. Paula Love shares a wealth of knowledge regarding the relevant funds currently available to districts as a result of the pandemic. In fact, Paula shared so much information, we’ll have even more from her next week for part two.
Building the BridgeEpisode 15 – Finding the Funds: An Interview with Dr. Paula Love, Part 1Play episode: Episode 15 – Finding the Funds: An Interview with Dr. Paula Love, Part 1 (17 minutes 50 seconds)Follow on SpotifyApple
The interview begins with a review of the funds designated for education from the Coronavirus Aid, Relief, and Economic Security (CARES) package in March (1:40). More than half of this funding is still available, and the allowable uses set up in March have set the pathway for the new funds that were designated in December. Paula gives important detail on several of the 12 allowable uses of these funds, which cover a broad range of needs for all districts.
The second half of the episode features discussion on the funds made available through the Consolidated Appropriations Act in December (9:25). This last round of COVID Relief designated four times as much for education, building on an already-sizable bucket of funding. Bringing more focus to the still-relevant 12 allowable uses, the new round of funds specifically highlights learning loss recovery, educational technology purchasing, and modifications to school facilities related to indoor air quality as areas of focus. The Department of Education has until September 2022 to obligate the CARES education stabilization funds and until September 2023 to obligate the funds from December.
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ESSER funds for schools: how the deadlines worked and where the money stands
ESSER funds for schools were the Elementary and Secondary School Emergency Relief money that Congress created in three COVID-19 laws, and the first two rounds are the ones Dr. Paula Love and Wendy Oliver walk through above. A Congressional Research Service summary from July 2025 lists the three: the CARES Act (ESSER I), the December 2020 law it abbreviates CRRSAA (ESSER II), and the American Rescue Plan Act (ESSER III). Together with related programs, the three laws provided $200.1 billion to states, $1.4 billion to outlying areas and $1.4 billion to the Bureau of Indian Education.
What the original deadlines meant
As the episode summary says, the CARES funds had a September 2022 date and the December 2020 funds a September 2023 date. Those are obligation deadlines, meaning the date by which a state or district had to commit the money to a specific purpose, such as a signed contract. The CRS summary gives the third date as well: September 30, 2024 for the American Rescue Plan money. A separate step, called liquidation, is the actual payment of the bill. Grantees had 120 days after the obligation date to liquidate, and could ask for an approved extension of up to 14 months, which makes 18 months in total.
The two steps matter because a district can have obligated every dollar and still have invoices unpaid. That situation produced most of the news about ESSER after 2024.
The 2025 dispute over late liquidation
According to the CRS summary, 47 states plus the District of Columbia, Puerto Rico and the outlying areas had at least one approved late-liquidation extension as of February 28, 2025. The approved requests covered $4.8 billion, which is 2.4 percent of state awards, and $3.3 billion of that was ESSER III money. On March 28, 2025, the U.S. Department of Education ended those extensions, describing the extensions as “a matter of administrative grace” and saying that extending COVID-related deadlines years after the pandemic was not consistent with its priorities.
Sixteen states and the District of Columbia sued on April 10, 2025. The Oregon Department of Justice litigation tracker records that the federal court in New York issued a preliminary injunction on May 6, 2025, and a second one on June 3, 2025 after the Department tried again to end access to the funds. Both blocked the action for the states that sued. On June 26, 2025 the Secretary of Education told all states they could keep spending under extensions approved before March 28 while the lawsuit continued. The AASA update of June 27, 2025 describes the same change from the district side: districts whose reimbursements had been cut off could request reimbursement again for previously approved projects until further notice, with timing depending on the litigation. The CRS summary adds that the Department said it would grant no liquidation extensions beyond March 28, 2026, the end date for the ESSER III extensions.
The same tracker says the government appealed on June 4, 2025, the Second Circuit denied its request to pause the injunction on June 20, the appeal was withdrawn by stipulation in an order dated August 11, 2025, and the district court approved a stipulation settling the case on November 17, 2025. The tracker does not state the settlement terms, and nothing later than its November 2025 entry was verified, so a district that still has unpaid ESSER invoices should confirm its current status with its state education agency rather than rely on this summary.
What school leaders can do with this
For a district that spent ESSER money, the practical questions are about records and about what the money bought. A business office can check that every ESSER-funded invoice was paid, or is covered by an extension the state approved, and that the documentation for each approved project is in one place. Curriculum, technology and facilities leaders can also list which recurring costs began with one-time relief money, such as additional staff, software subscriptions and tutoring contracts, and decide which of them the regular budget will carry. The episode summary notes that the December 2020 round highlighted learning loss recovery, educational technology and indoor air quality, and recurring costs often follow purchases in categories like those.
A board member or parent who wants to know where a district stands can ask three things: how much ESSER money the district received, how much it spent in each category, and which programs funded with it continue this year. The answers show whether a program was built to last or was a short-term response to the pandemic.
The first part of this conversation remains a useful record of how the CARES and December 2020 money was meant to be used. The deadlines it mentions have passed, and the lawsuit over the last payments was settled by stipulation in November 2025, with terms this section could not confirm.
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