Meeting Spending Requirements
Overview – Meeting Federal Spending Requirements
The reauthorization of the Carl D. Perkins Career & Technical Act of 2006 (Perkins V) updates and strengthens the accountability for the expenditure of these federal funds. This guide specifies how Region 2A’s Career and Technical Education division will be accountable for these federal funds, administered through the Oregon State Plan.
First, all funds must be expended strategically in pursuit of one or more of the following Five Oregon Perkins Goals: (defined in the following pages)
- 1 – Standards & Content
- 2 – Alignment & Articulation
- 3 – Accountability & Evaluation
- 4 – Student Support Services
- 5 – Professional Development
Second, Perkins V details the Required Activities for Use of Funds detailing how the fund must be used to support High School through Community College Programs of Study.
Improve and Enhance CTE
Federal grant funds must improve and enhance CTE Programs of Study and not supplant state or local funds. Federal funds may not result in a decrease in state or local funding that would have been available to conduct the activity had federal funds not been received. In other words, federal funds may not free up state or local dollars for other purposes, but should create or augment CTE programs to an extent not possible without federal dollars. The Consortium must be able to demonstrate that federal funds are added to the amount of state and local funds that would be made available for uses specified in your plan.
Determining Supplanting vs Supplementing
The critical question in determining whether there has been a supplanting violation is whether federal funds were used instead of funds from non-federal sources. It will have to be shown that the federally funded activity would not have been funded by state or non-federal sources. When auditors review compliance with non-supplant rules, they often use the following test: What would the recipient have done in the absence of federal funds? If the project could have been completed without non-federal funds, there will be the presumption of supplanting. During the audit appeal process evidence would be required to disprove that presumption.
On the other hand, if the auditor were to find evidence that in the absence of those federal funds, the specific activity or program could not have been carried out, there would be no presumption of supplanting.
Think of it this way – The law is designed to ensure that federal funds pay for something extra! NOT pay for ‘day to day’ operational costs including basic teacher and student supplies.
The Test! You can presume Supplanting if: 1. Perkins funds are used to provide services the recipient is required to make available under other federal, state or local laws. 2. Perkins funds were used to provide services the recipient provided with State or Local funding the prior year.
Using Perkins Funds to Purchase
Guidelines for Purchasing
Step 1 – Planning and Thought: Identify the need
With the issue of Improvement/Expansion your Program of Study vs the Supplanting funds the following questions can be used as a guide as you begin to review your needs for each school year.
Can you answer “YES” to the following questions?
- Will the funds be used to purchase consumable products with a life of less than 1 year?
- In the past, the supplies have not been purchased using general funds or other grant funds?
- Will the supplies be used in a manner that supports the increase in student performance in a CTE Program of Study this year?
- Will the purchase be used exclusively to help improve technical and/or academic performance of students enrolled in courses associated with CTE Programs of Study?
- Was the expenditure appropriately identified in the Basic Perkins Grant and budget?
- Will the purchase meet the “allocable” requirements – All purchasing completed by December 1st and used within classroom for that school year?
When considering the purchase of Materials and Supplies:
- Equipment (of any amount) purchased using Perkins funds, solely for teacher use is not allowed. All equipment purchased with Perkins funds must be for student use or utilized in instructing students in the classroom.
- Use of Perkins funds to pay for any expense that was previously paid by the local school district is considered supplanting. This may include: salaries, textbooks, stipends etc.
- Consumable supplies such as toner cartridges, paper, baking supplies etc. are the responsibility of the local school district.
- Perkins funds cannot be used to purchase items such as mugs, T-shirts, pencils etc. to promote CTE programs.
- Textbooks can be ordered with Perkins funds for new courses only but would have to have very good rationale for this to be a Perkins expense for your program of study. Textbooks for existing CTE courses are the responsibility of the local board of education. (NOTE: textbooks are a very hard sell to the Oregon Department of Education. Please think about class sets of references or resource books.)
- When considering the purchase of Equipment: (Federal regulations define “Equipment” as $5,000.00 or more.)
- Is the equipment necessary to accomplish what is stated in Program of Study plans and not currently available in the school?
- Is the equipment purchase necessary for effective instruction in the program area?
- The Questions and Goals, and Strategies sections of the application must show how the equipment will be integrated into the curriculum.
- Equipment purchased, in whole or in part, with Perkins funds must not result in any direct financial benefit to any School building, School District, Portland Community College or its employees.
Your purchase may not be made …
- If funds will be used to upgrade, replace or repair existing equipment.
- If funds will be used to enhance infrastructure such as wiring, plumbing or construction to a facility.
- If equipment will be considered a permanent part of the instructional facility such as air conditioners, smoke or exhaust removal systems and other similar fixtures.
(State of Oregon Requirement: A specific, detailed, line-item request for equipment more than $4,999 must be in the annual budget approved by the Oregon Department of Education as a line item equipment purchase prior to the year in which the purchase will be made.)
Step 2 – Purchasing Procedures: Identify the need.
- Confirm that the purchase(s) you or your teachers would like to make for the current school year qualifies as an allowable expense and meets the goals of your Programs of Study. When in doubt ask Beth Molenkamp, CTE Regional Coordinator, for assistance.
- Have the requesting teacher contact Jenn Noble to have a Requisition Request and Non-Supplanting forms sent to you via email.
- Have the requesting teacher follow the instructions on the Requisition Request form when completing it
- Have the principal sign the forms if necessary
- Scan and email to firstname.lastname@example.org or FAX all documents to Jenn Noble at 971-722-7734
For Equipment purchases– (defined as $5,000 or more) Complete the steps above and…
- Include shipping costs and copies of any internet or catalog research you conducted for your purchase.
- Three bids must be submitted with the Requisition Request.
Timing – All major purchases must be made by December 1st annually.
This is a state requirement. Perkins grant purchases are intended to impact student performance during the year the money is awarded, therefore it is expected that Perkins purchases will be made early in the designated school year and that students will have benefit from the purchases during that year.
Some expenditures, such as field trips and professional development are ongoing; for such expenses submit as soon as possible.