Answer: The short answer is yes, both McKinney-Vento funds, and the Title I Part A homeless setaside funds, may be used for this purpose.
The U.S. Department of Education guidance states that Title I Part A setaside funds may be used for homeless students if the services are “reasonable and necessary to assist homeless students to take advantage of educational opportunities.”
Credit recovery certainly fits that description.
Also, two authorized activities in the McKinney-Vento Act speak to this issue:
- The provision of tutoring, supplemental instruction, and enriched educational services that are linked to the achievement of the same challenging State academic standards as the State establishes for other children and youths. 42 U.S.C. 11433(d)(1).
- 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. 42 U.S.C. 11433(d)(7).
Lastly, ESSA put new emphasis on credit recovery by requiring States to have “procedures to identify and remove barriers that prevent students from receiving appropriate credit for full or partial coursework satisfactorily completed while attending a prior school, in accordance with State, local, and school policies.” 11432(g)(1)(F)(ii). School district liaisons are required to implement these procedures. 11432(g)(6)(A)(x).
Although this provision does not speak directly to the situation raised in your question—because the ESSA provision deals with credits for courses fully or partially completed—it reflects a strong Congressional policy in support of assistance with credit recovery.