Thumbnail of OSEP Memo

Timelines for Obligating and Liquidating FFY 2021 Part C ARP and IDEA Funds

Authors: Bruce Bull, The DaSy Center; Leslie Fox, Center for IDEA Fiscal Reporting (CIFR)

On May 17, 2023 OSEP released a memo regarding the obligation of and timelines for liquidating FFY 2021 funds. The OSEP memo addressed questions OSEP had received about FFY 2021 IDEA funds including American Rescue Plan (ARP) funds. (If you missed this memo, it can be found here.) DaSy encourages Part C coordinators to read the memo carefully and share the memo with pertinent staff within your agency, particularly those involved with the fiscal management of the Part C program.

Many states have already obligated all FFY ARA and IDEA funds or have plans in place to obligate them before the deadline. However, if your state has not obligated all of these funds or does not yet have plans in place to obligate all of these funds, please read the remainder of this blog and read/reread the OSEP memo. Contact DaSy if you have questions or would like to discuss your situation.

Fund Obligation

If your state has not yet obligated all of these funds, you have until September 30, 2023 to obligate them. There are no extensions for fund obligation. OSEP’s memo clarified obligation with these examples:

For example, if the obligation is to acquire personal property, the obligation date is the date that the State makes a binding written commitment to acquire the property (i.e., the contract execution date). If the obligation is for personal services by a contractor who is not an employee of the State, the obligation date is the date that the State makes a binding written commitment to obtain the services. By contrast, if the obligation is for personal services by an employee of the State, the obligation date is the date that the services are performed. OSEP reminds States that the determination of what is a binding written commitment requires the State to follow its own procurement rules.

Fund Liquidation Including Late Liquidation1

The OSEP memo also clarified the timeline to liquidate the funds and provides information on late liquidation.

States must liquidate their funds during the 120-day liquidation period set forth in 2 C.F.R. § 200.344(b). The liquidation period for FFY 2021 IDEA ARP and FFY 2021 IDEA formula grant awards is from October 1, 2023 through January 28, 2024. After the initial 120-day liquidation period has ended, States may request a Phase 1 late liquidation request within 18 months of the obligation period (or not more than 14 months after the end of the normal liquidation period — i.e., after January 28, 2024). Thus, a State may submit its Phase 1 late liquidation request to the OSEP-MSIP Director by March 31, 2025. (emphasis added)

As The Center for IDEA Early Childhood Data Systems (DaSy), we encourage Part C programs that have not yet obligated all of their FFY 2021 funds to consider enhancing their existing data systems. The Part C Data Systems Functions document provides a comprehensive list of data system functions. While there is not adequate time to develop a significant data system request for proposal (RFP) and contractually obligate funds by September 30, 2023, it may be possible to collaborate and contract with an existing vendor on smaller data system enhancements. In some cases, states may be able to engage experienced vendors on self-standing data modules that vendors2 previously developed. Working with your state procurement experts, it may still be possible to obligate funds to an existing vendor, or potentially a new vendor, through sole-source contracts or other small dollar amount contracts. Data system enhancements or previously vendor-developed data modules can be obtained relatively cost-effectively and usually deployed quickly when compared to developing a new data system.


It is crucial for Part C coordinators to review the OSEP memo regarding the obligation and liquidation timelines for FFY 2021 funds. Ensure that your state is on track to obligate all these funds before the September 30, 2023 deadline. Consider enhancing your data systems to maximize the effectiveness of these funds. If you have any questions or need support, reach out to DaSy for guidance.

May 17, 2023 Memo from OSEP: Review of Obligation and Liquidation Timelines and Authority, and Process for Requesting Late Liquidations

Questions? Please contact us by finding your DaSy liaison or emailing us at


1Read the OSEP memo for details about the process for late liquidations.
2DaSy, of course, can not recommend particular vendors. However, DaSy can facilitate states talking to states about their vendors if that might be helpful.

Published August 2023