Perkins Frequently Asked Questions (FAQs)

December, 2017

State Board of Education

State of Iowa

Department of Education Grimes State Office Building

400 E. 14th Street Des Moines, IA 50319-0146

State Board of Education

Charles C. Edwards, Jr., President, Des Moines Michael L. Knedler, Vice President, Council Bluffs Brooke Axiotis, Des Moines Michael Bearden, Gladbrook Bettie Bolar, Marshalltown Diane Crookham-Johnson, Oskaloosa Angela English, Dyersville Mike May, Spirit Lake Mary Ellen Miller, Wayne County Robert Nishimwe, Student Member, Des Moines

Administration

Ryan M. Wise, Director and Executive Officer of the State Board of Education Jeremy Varner, Division Administrator Pradeep Kotamraju, Bureau Chief

Division of Community Colleges and Workforce Preparation

Bureau of Career and Technical Education

It is the policy of the Iowa Department of Education not to discriminate on the basis of race, creed, color, sexual orientation, gender identity, national origin, sex, disability, religion, age, political party affiliation, or actual or potential parental, family or marital status in its programs, activities, or employment practices as required by the Iowa Code sections 216.9 and 256.10(2), Titles VI and VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000d and 2000e), the Equal Pay Act of 1973 (29 U.S.C. § 206, et seq.), Title IX (Educational Amendments, 20 U.S.C.§§ 1681 – 1688), Section 504 (Rehabilitation Act of 1973, 29 U.S.C. § 794), and the Americans with Disabilities Act (42 U.S.C. § 12101, et seq.). If you have questions or complaints related to compliance with this policy by the Iowa Department of Education, please contact the legal counsel for the Iowa Department of Education, Grimes State Office Building, 400 E. 14th Street, Des Moines, IA 50319-0146, telephone number: 515-281-5295, or the Director of the Office for Civil Rights, U.S. Department of Education, Citigroup Center, 500 W. Madison Street, Suite 1475, Chicago, IL 60661-4544, telephone number: 312-730-1560, FAX number: 312-730-1576, TDD number: 877-521-2172, email: OCR.Chicago@ed.gov.

Contents Perkins General 4 Perkins IV Required and Permissive Activities 5 Financial 8 Expenditures/appropriate Uses of Funds 9 Equipment 17 Consortium & Consortia 20 Professional Development/Associations/Conferences/Conventions 21 Project Lead the Way (PLTW) 23 CTE Student Organizations (CTSOs) 24 Middle Schools 25 Program Evaluation 26 Program Improvement Plans 27 CTE Reporting 28 Appendices Appendix A (Ineligible Expenditures) 30 Appendix B (Memos regarding federal fund restriction) 32 Appendix C (Sample Claim) 34

Introduction – Perkins IV - General General Note: When a discrepancy exists, between the federal Carl D. Perkins Act of 2006 and any Iowa policies, the more restrictive law and/or regulation takes precedence. 2 CFR §200 (c) of the Uniform grant guidance (UGG) requires that for a cost to be allowable, it must be consistent with the policies of the state. Thus if the state has a more restrictive rule, the sub recipient must follow it. What is the purpose of Perkins IV (a.k.a. The Perkins Act of 2006)? a) To build on efforts of states and localities to develop challenging academic and technical

standards, and to assist students in meeting the standards, including preparation for high-skill, high-wage, or high-demand occupations in current or emerging professions.

b) To promote and develop services and activities that integrate rigorous and challenging

academic and career and technical instruction, and that link secondary and postsecondary education for participating CTE students at the secondary and community college levels.

(Carl D. Perkins Act, 2006; Iowa Perkins State Plan) What is OCTAE guidance? OCTAE guidance is broad technical assistance issued by the Office for Career Technical and Adult Education. What technical assistance resources are available to assist districts and community colleges? EDGAR (which stands for Education Department General Administrative Regulations) 2 CFR PART 200 (3rd Edition, September 2016), OMB Circulars, and OCTAE. Iowa Department of Education CTE Technical Assistance website. What are the special populations identified within the Perkins Act? Special populations include:

● Individuals with disabilities

● Individuals from economically disadvantaged families, including foster children

● Individuals preparing for non-traditional fields

● Single parents, including single pregnant women

● Displaced homemakers; and

● Individuals with limited English proficiency (Perkins Act of 2006, Sec. 3 (29)) What does “supplant” mean? “To replace, supersede, or take the place of.” Supplanting occurs when a Perkins recipient replaces items, currently purchased with the district fund (or other non-federal funds), and supplants/replaces the funding source with the Perkins appropriation. (Perkins Act of 2006, Sec. 311)

Perkins IV – Required and Permissive Activities What are the required (R1 through R9) uses of Perkins funds? Required uses of funds include:

● R1- Strengthen the academic and career and technical skills of students participating in CTE programs through the integration of academics with CTE programs. Public Law 109-270, Section 135(b)(1)

● R2 - Link CTE at the secondary level and the postsecondary level, including by offering the relevant elements of not less than one program of study described in Section 122(c)(1)(A). Local Plan, Public Law 109-270, Section 135(b)(2)

● R3 - Provide students with strong experience in and understanding of all aspects of an industry, which may include work-based learning experiences. Public Law 109-270, Section 135(b)(3)

● R4 - Develop, improve, or expand the use of technology in CTE, which may include training to use technology, providing students with the skills needed to enter technology fields, and encouraging schools to collaborate with technology industries to offer internships and mentoring programs. Public Law 109-270, Section 135(b)(4)

● R5 - Provide in-service and pre-service professional development programs to teachers, faculty, administrators, and career guidance and academic counselors who are involved in integrated CTE programs on topics including effective integration of academics and CTE, effective teaching skills based on research, effective practices to improve parental and community involvement, effective use of scientifically-based research and data to improve instruction. Professional development should also ensure that teachers and personnel stay current with all aspects of an industry, involve internship programs that provide relevant business experience and train teachers in the effective use and application of technology. Public Law 109-270, Section 135(b)(5)

● R6 - Develop and implement evaluations of the CTE programs carried out with Perkins funds, including an assessment of how the needs of special populations are being met. Public Law 109-270, Section 135(b)(6)

● R7 - Initiate, improve, expand, and modernize quality CTE programs, including relevant technology. Public Law 109-270, Section 135(b)(7)

● R8 - Provide services and activities that are of sufficient size, scope, and quality to be effective. Public Law 109-270, Section 135(b)(8)

● R9 - Provide activities to prepare special populations, including single parents and displaced homemakers who are enrolled in CTE programs, for high-wage, high-skill, or high-demand occupations that will lead to self-sufficiency. Public Law 109-270, Section 135(b)(9)

(Perkins Act of 2006 Title I, Section 135(b). Am I to allocate Perkins funds to all of the required activities? No. Sub-recipients are required to implement and fund each required activity; however, the source of funding (Perkins, local, or other) is a decision for the sub-recipient. Most school districts are already funding CTE-required activities with local funding without being aware of doing so. Contact Amy Vybiral for examples at amy.vybiral@iowa.gov. Example: All districts meet required activity one on the first contract day of the school year because the district is likely paying some or all CTE instructor salary with the district general fund. In this case, the required activity one is met and districts do not need to allocate additional Perkins funds. What are the permissible (P1 through P20) uses of Perkins funds? Permissible uses of Perkins IV funds include:

● P1 - Involving parents, businesses, and labor organizations in the design, implementation, and evaluation of CTE programs. Public Law 109-270, Section 135(c)(1)

● P2 - Providing career guidance and academic counseling, which may include information described in Section 118, for students participating in CTE programs, which improve graduation

rates and provides information on postsecondary and career options, and provide assistance for postsecondary students and adults. Public Law 109-270, Section 135(c)(2)

● P3 - Local education and business partnerships, including work-related experiences for students, adjunct faculty arrangements for qualified industry professionals, and industry experience for teachers and faculty. Public Law 109-270, Section 135(c)(3)

● P4 - Providing programs for special populations. Public Law 109-270, Section 135(c)(4) ● P5 - Assisting career and technical student organizations. Public Law 109-270, Section

135(c)(5) ● P6 - Mentoring and support services Public Law 109-270, Section 135(c)(6) ● P7 - Leasing, purchasing, upgrading, or adapting equipment, including instructional aids and

publications (including support for library resources), designed to strengthen and support academic and technical skill achievement. Public Law 109-270, Section 135(c)(7)

● P8 - Teacher preparation programs that address the integration of academic and CTE and that assist individuals who are interested in becoming CTE teachers and faculty, including individuals with experience in business and industry. Public Law 109-270, Section 135(c)(8)

● P9 - Developing and expanding postsecondary program offerings at times and in formats that are accessible for all students, including through the use of distance education. Public Law 109-270, Section 135(c)(9)

● P10 – Develop initiatives that facilitate the transition of sub-baccalaureate CTE students into baccalaureate degree programs, including articulation agreements between sub-baccalaureate programs and CTE postsecondary education institutions and baccalaureate degree-granting postsecondary institutions, and postsecondary dual and concurrent programs. Public Law 109-270, Section 135(c)(10)

● P11 - Providing activities to support entrepreneurship education and training. Public Law 109-270, Section 135(c)(11)

● P12 - Improving or developing new CTE courses, including the development of programs of study for consideration by the state and courses that prepare individuals academically and technically for high-skill, high-wage, or high-demand occupations and dual or concurrent enrollment opportunities. Public Law 109-270, Section 135(c)(12)

● P13 - Developing and supporting small, personalized career-themed learning communities Public Law 109-270, Section 135(c)(13)

● P14 - Providing support for family and consumer science programs. Public Law 109-270, Section 135(c)(14)

● P15 - Providing CTE programs for adults and school dropouts to complete secondary education or upgrade technical skills. Public Law 109-270, Section 135(c)(15)

● P16 - Providing assistance to individuals who have participated in services and activities under this Act in continuing their education or training or finding an appropriate job, such as through referral to the system amended under section 121 of PL 112-166. (29 U.S.C.2801 ET SEQ (2012) amended from PL105-220 (1998). Public Law 109-270, Section 135(c)(16)

● P17 - Supporting training and activities (such as mentoring and outreach) in non-traditional fields. Public Law 109-270, Section 135(c)(17)

● P18 - Providing support for training programs in automotive technologies. Public Law 109-270, Section 135(c)(18)

● P19 – Pool a portion of such funds available to not less than one other eligible recipient for innovative initiatives which may include A)improving the initial preparation and professional development of CTE teachers, faculty, administrators, and counselors; B) establishing, enhancing, or supporting systems for –

● Accountability data collection under this act; or ● Reporting data under this act; ● Implementing CTE programs of study described in section 122 (c) (1)(A); or ● Implementing technical assessments. Public Law 109-270, Section 135(c)(19)

●

● P20 – to support other CTE activities that are consistent with the purpose of this act. Public Law 109-270, Section 135(c)(20)

(Perkins Act of 2006, Title I, Section 135) When may I utilize Perkins funds for permissive activities? Recipients may utilize Perkins to fund permissive activities after all required activities (R1 through R9) have been addressed. May I use Perkins to fund the required career information system? Yes. Check with the regional planning partnership (RPP) prior to purchase. Some RPP’s have decided to collaborate with school districts and pay for the career information system to be used by all school districts within the RPP. When using Perkins to purchase career information systems, use permissive activity P2; “Providing career guidance and academic counseling, which may include information described in section 118, for students participating in CTE programs, which improve graduation rates and provides information on postsecondary and career options, and provides assistance for postsecondary students and adults. P.L.109-270, Section 135 (c)(2)

Perkins Financial How are Perkins funds allocated in the State of Iowa? The formula for the funds received through Perkins IV was based on input from a taskforce composed of administrators of secondary school districts and community colleges. Three factors were utilized to determine the distribution of funds to the two sectors. The factors gave consideration to the enrollments (contact hours) in CTE programs in each of the sectors, the costs incurred by each sector to operate the programs, and the factors (population data) utilized by the U.S. Department of Education to distribute CTE assistance to the states. These factors were selected because together they provided a means to give full consideration to the comprehensive nature of CTE programs and the needed investment of additional resources in both sectors to enable the achievement of the state's vision for its CTE system. Based on formula information found in the Iowa Perkins Plan, 50.6 percent of the funds received has been distributed to the secondary sector and 49.4 percent of the funds has been distributed to the postsecondary sector. Of the 50.6% that the community colleges receive, 5.4% must be used on secondary or shared programs. (Iowa Perkins State Plan) How are Perkins IV funds allocated per secondary school? Secondary Perkins allocations are calculated based upon demographics of student population (i.e., allocations are determined per student not per school). The federal allocation formula is geared toward potentially equalizing opportunities for students in all schools. Schools with shrinking student populations receive fewer dollars, whereas growing school districts may receive an increased allocation. Socio-economic status of a district’s populations is a factor. Thirty percent (30%) will be allocated to such local educational agencies in the proportion to the number of individuals aged five through seventeen (5-17), inclusive, who reside in the school district served by such local educational agency for the preceding fiscal year compared to the total number of such individuals who reside in the school districts determined on the basis of the most recent satisfactory data provided to the U.S. Secretary of Education by the Bureau of the Census for the purpose of determining eligibility under Title I of the Elementary and Secondary Education Act of 1965. Seventy percent (70%) of the funds will be allocated to each local educational agencies in proportion to the number of individuals aged five through seventeen (5-17), inclusive, who reside in the school district served by such local educational agency and are from families below the poverty level for the preceding fiscal year, as determined on the basis of the most recent satisfactory data used under section 1124(c)(1)(A) of the Elementary and Secondary Education Act of 1965, compared to the total number of such individuals who reside in school districts served by all of the local educational agencies in the state for such preceding fiscal year. (Federally approved Iowa Perkins State Plan). Does the State of Iowa have any financial technical assistance resources? Yes. The Department publishes Financing Public Elementary and Secondary Education in Iowa. What guidance exists for community college equipment accounting and reporting? The Iowa Department of Education CTE website offers: Accounting for Perkins Funds: Consortia Perkins Equipment Guidelines Perkins Equipment Disposition Forms Perkins-Funded Equipment Inventory Template

Perkins IV Eligible Expenditures/Appropriate Use of Funds When in doubt, contact Amy Vybiral (amy.vybiral@iowa.gov or 515-339-4520) or administrative consultant Pat Thieben (pat.thieben@iowa.gov) ensure eligibility status of purchases prior to purchase. What is the maximum amount allowed for administrative uses? Five percent (5%) is the maximum per consortium. (Carl D. Perkins Act of 2006, Section 135(d)) What activities constitute eligible administrative expenses at the LEA level?

● Development and review of the local plan ● Monitoring and evaluation of program effectiveness ● Assuring compliance with all state and federal laws ● Providing technical assistance

If several school districts organize into a consortium, may each district spend five percent (5%) for administration? No. The consortium fiscal agent is the eligible recipient. Only the assigned fiscal agent may claim the five percent (5%) administrative fee. School districts within the consortium are not eligible. Are Perkins funds allocated to individual districts or to consortia of individual districts? It depends. Perkins Act of 2006 Sec. 131(b). State Plan.

● If the recipient qualifies for an allocation in an amount that is ≥ $15,000, the allocation goes directly to the recipient.

● School districts with allocations of ≤ $14,999 must form a consortium to meet the $15,000 threshold.

o The allocation of all school districts combined is awarded to the fiscal agent.

o Districts send documentation to the fiscal agent for reimbursement.

o The claim is submitted by the fiscal agent to the IDOE for reimbursement on behalf of the entire consortium.

When should claims be submitted? ● As soon as the invoice/receipt are received ● Monthly ● Quarterly

Secondary claims will now be submitted as outlined below. Claims not submitted this way will be returned to the fiscal agent to remove unnecessary paperwork. The department will expect resubmission with only receipts, invoices (and in limited cases with prior approval, general ledgers.) Use the following steps so your claim is not returned to weed out unnecessary paperwork

1. One upload for all documentation (see screenshots below)

Looks like this

Not like this

Scan in the following order:

1. Claim Summary Page 2. Receipts and invoices in required and permissive activity sequence as listed on the Claim

Summary page.

Exclude purchase orders, requisitions, cancelled checks, general ledgers (limited circumstances-check prior to submission), email chains with your supervisor, conference registration forms, bill(s) of lading. See Appendix C for examples of what will and will not be accepted.

Unless the document clearly indicates that the purchase or service has been paid for AND/OR is in your possession, do not submit the documentation to claim reimbursement. Contact Amy Vybiral with any questions at 515-339-4520 (515-281-3169 is no longer available).

What is debarment?

Debarment refers to entities which have engaged in illegal conduct and are thereby not allowed to provide materials/equipment/services purchased with federal dollars. List of debarred entities (EDGAR 2 CFR, §200.213) Should claims be submitted as a broad category or as specific items? Specific items. Receipts and invoices must indicate each specific purchase and the corresponding Perkins required or permissive activity on the invoice to demonstrate eligibility for all items. What does “supplant” mean? “To replace, supersede, or take the place of.” Is supplanting allowed? No. Supplanting occurs when a Perkins recipient replaces items, currently purchased with the district fund (or other non-federal funds), and supplants/replaces the funding source with the Perkins appropriation. (Perkins Act of 2006, Sec. 311.) Supplanting is not allowed and occurs when the local recipient uses federal funds:

● For activities or programs that were previously funded with state or local dollars and, ● For activities or programs funded with state and local dollars for non-CTE programs ● See Appendix A for specific ineligible examples of expenditures that are considered

“supplanting.” ● Per the Iowa OCTAE federal contact (September 2017), “presumption of supplanting may be

rebutted if equipment and or materials purchased are upgraded versions of previous devices purchased by non-federal funds and the fact that Section 135 (b)(4) of the Perkins law states that Perkins funds may be used to “develop or expand the use of technology in CTE.”

● If purchases are upgraded versions of previous devices, indicate on invoice. (Perkins Act of 2006. Title III, Part A., Sec. 311 and Sec. 135(b) (4), EDGAR CFR Part 200, §200.33) What does “supplement” mean? “To complete, add to, or extend”

● Expenditures must be used to supplement CTE programs. Perkins Act of 2006. Title III, Part A., Sec. 311 and Sec. 135(b) (4)) What constitutes “necessary and reasonable” standards as applied to Perkins? Consideration must be given to whether the purchase is:

● In its nature and amount, the cost does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost (Title II, CFR Part §200.404.)

● consistent with the recipient’s policies, regulations and procedures

● consistent with guidelines for sound business practices in accordance with generally accepted accounting principles

● consistent with the intent, terms and conditions of the federal award, and provided at fair market prices for comparable goods and services

● demonstrating prudence by the individuals determining expenditure and cost allocation

● Complies with all federal, state, or local laws and regulations

● All equipment, materials, and supplies are documented and inventoried for audit

Expenditure Eligibility: If the purchase meets the standards listed below, the expenditure is allowable.

● Expands, improves, and modernizes a program of study. Public Law 109-270, Section 135(b)(1) ● The purchase(s) supplement[s] program instruction

● The purchase is not consumable (See Appendix A for ineligible consumable purchases)

Are computers an allowable Perkins IV expenditure? Maybe.

● Yes, if the purchase of computing devices is clearly an upgrade of previous equipment purchases or for a new course with new critical competencies, standards and benchmarks.

(Perkins Act of 2006. Title III, Part A., Sec. 311 and Sec.135(b) (4)) Is it appropriate for an Apple-based, 1:1 district to purchase PC-based computing devices for CTE programs?

a) Yes, as long as the purchase is a clear upgrade of previous equipment b) Yes, as long as the Perkins contribution to the reimbursement is “…consistent with the

proportional amount of time that the devices are used for CTE programs and services the cost is allocable to the grant, and the LEA can logically rebut the presumption of supplanting.” (Perkins Federal Contact memo, September 28, 2017.

May an Apple-based 1:1 district purchase iPads for CTE programs using Perkins IV funds? Yes May a district purchase Apple Care or PC-extended warranties for computers purchased with Perkins funds? Yes, but only if purchased at the same time as the computing devices. May I use my Perkins equipment to make items for a fundraiser? No. Costs of organized fundraising, including financial campaigns, endowment drives, solicitation of gifts and bequests, and other expenses incurred to raise capital or obtain contributions are unallowable. (EDGAR 2 CFR PART §200.442)

My district purchased an LCD projector with Perkins IV funds. The projector was stolen. The district’s insurance has a deductible which is greater than the cost of the projector. May the projector be replaced with Perkins IV funds? No. When the district purchased the insurance policy with a large deductible, it assumed the risk and responsibility for covering any losses to that amount with local funds. Therefore, the district must replace the stolen equipment for the program/activity – but not with Perkins IV funds. (Iowa School Finance Guidelines, Equipment Disposition Form, and Remove from Perkins Inventory May Perkins IV funds be used to repair or service equipment that was originally purchased with Perkins IV (or earlier) funds or donated to the CTE program? Yes. Costs incurred for necessary maintenance, repair, or upkeep of equipment and kept in an efficient operating condition, are allowable. EDGAR 2 CFR Part 200.452 May Perkins IV funds be used to upgrade infrastructure?

a) Yes. As long as the costs to upgrade are required in order to be, by law, and in compliance by law, in order to use the equipment (e.g., wiring to install commercial stoves for culinary program),

b) No. Costs incurred for improvements, which add to the permanent value of the buildings and equipment or appreciably prolong their intended life, must be treated as capital expenditures

(See §200.439).

EDGAR 2 CFR Part 200.452 May Perkins IV funds be used to purchase a maintenance contract for equipment that was originally purchased with Perkins funds or donated to the CTE program?

Yes. (EDGAR 2CFR Part 200.452)

May a district use Perkins IV funds to purchase supplies for equipment that was purchased with Perkins IV funds? No. Supplies specific to the CTE equipment are considered consumable and are not eligible for reimbursement. (e.g., saw blades, food, paper, toner, nails screws, wood, oxygen, seeds, etc.) (EDGAR 2 CFR Part 200 §200.403 (Factors Affecting Allowability of Costs) Consumable Restrictions - See Appendix A for ineligible purchases May a district purchase toner, welding rods, lumber, etc., beyond the initial purchase of equipment, which utilizes consumable items? No, districts assume the responsibility for maintaining supplies for equipment after the initial purchase, which excludes (EDGAR 2 CFR Part 200 §200.403). A district purchased its first LCD projector using Perkins IV (or earlier) funds. Now the district is purchasing additional projectors for other classrooms using local funds. May Perkins IV funds be used to maintain the original projectors? Yes, since the projector was originally purchased with Perkins IV (or earlier) funds. (Iowa Perkins State Plan) May a district mix local funds and Perkins IV funds to purchase a business computer lab where Perkins IV funds are used until exhausted and local funds are used to complete the purchase? No. Do not mix funding sources. The recipient may not use Perkins funding to maintain repair, or replace the equipment, this is eligible for reimbursement. Any division of funding sources, in which one of the sources is Perkins, is strongly discouraged.

● This practice automatically creates a supplanting issue and is ineligible for future upgrades or replacement utilizing Perkins as the funding source.

● This practice also demonstrates that local funds are available and increases the justification that the local funding is sufficient to purchase, without the Perkins funding source.

Upon encumbrance of the entire Perkins appropriation, may a district solicit donations to fund items needed for CTE? Yes. The district may also access other grant funds to pay remaining balances. Restrictions apply to the use of student activities funding. See Student Activity Funds. (EDGAR 2 CFR Part 200.422) May a district consider the purchase of replacement markers for a Smart Board “maintenance”? No. Markers are consumables and ineligible for reimbursement because markers are considered to be “stockroom supplies” made available to non-CTE classes and instructors. (EDGAR 2 CFR Part 200 §200.403) Perkins Act of 2006, Sec. 311 May Perkins IV funds be used to purchase student textbooks for a CTE course? Yes ● The textbook is for a brand new CTE Course

● The course has substantially changed in curriculum (a name change does not constitute a

substantial change) ● The textbook is supplemental to the normal textbook purchased by the district

May we purchase supplemental material for CTE courses as long as the materials are not the main texts or curriculum?

a) Yes. Perkins IV funds may be used to purchase resources/references for CTE program instructors to utilize. This would supplement the program.

b) Yes. Perkins IV funds may be used to purchase supplemental materials which are used periodically to enhance the learning experience beyond the primary textbook(s). This would supplement the program.

c) Yes. The purchase of textbooks for students is allowable if the books contain information that is required to implement a new technology. This would supplement the program.

d) Yes. If the course or courses are new. Materials may be purchased to expand or increase availability of CTE programs. This would supplement the program.

(Perkins Act of 2006, CFR Part 200 Sect 311) May textbooks be purchased using Perkins IV funds for a new CTE course that replaces a discontinued CTE class where the new class has identical critical competencies to the course it replaced, and there is no expansion of the CTE program? No. Renaming courses does not constitute a “new” course. The course must be substantially different including new critical competencies. (Perkins Act of 2006, Sect 311,) Because the Perkins IV Act addresses the improvement of academics, may Perkins IV funds be used to purchase textbooks/instructional materials for academic courses (e.g., math, science, English, etc.)? No. This is supplanting. Perkins IV expenditures must be targeted to meet the learning needs of CTE students. Improving achievement in academic courses is ultimately the responsibility of the district. Perkins IV funds may only be used to enhance and/or improve academic learning opportunities for CTE students in CTE courses. (Perkins Act of 2006, CFR Part 200 Sec. 311, May non-CTE students use equipment purchased by Perkins? Yes. Equipment, materials, and/or software purchased to enhance learning opportunities for CTE students may be used by non-CTE teachers and/or non-CTE students, beginning in grade seven. However, CTE students and CTE teachers have first priority to use these items. Example: A district purchased a cart of laptop computers with Perkins IV (or earlier) funds, and the

cart was maintained in the school’s media center. When CTE teachers attempted to schedule use of the laptops, they were informed that the English and history teachers had already scheduled use of the laptops every day first semester. This is not an allowable practice.

(EDGAR 2 CFR Part 200.313) May Perkins IV funds be used for classroom furnishings such as desks or tables? No. Supplanting. Classroom furnishings are considered standard equipment within a district, and are supplied for other courses by the district. Furniture specific to accommodating CTE requirements for specific programs of study (e.g., CAD desks) represent improvement and modernization. The invoice submitted must indicate the unique usage relevant to the program. (Perkins Act of 2006, Sect 311,) Are facility renovation, maintenance, operations, and repairs (e.g., including utilities, security, janitorial services, elevator services, and upkeep of grounds) allowable Perkins IV expenditures?

No. Perkins required and permissive activities do not include maintenance for bricks and mortar or building maintenance. (EDGAR 2 CFR PART 200.439) May Perkins IV funds be used to modify electrical upgrades in order to meet code compliance for the installation of new CTE equipment? Maybe.

a) Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $500 or more have the prior written approval of the pass-through entity (in this case, the Iowa Department of Education).

b) Capital expenditures for improvements to land, buildings, or equipment which materially increase their value or useful life are unallowable as a direct cost.

(EDGAR 2 CFR PART 200.439) May Perkins funds be used to pay for textbooks for concurrent enrollment courses? Only if the concurrent enrollment course is a CTE course. (USDE – OCTAE Guidance, May 2009) May Perkins funds be used to pay for the accreditation of a CTE program (i.e. nursing, dental assisting, etc.)? Although there is no one item that specifically addresses the use of funds for licensing and accreditation, there are elements that contain the option for community colleges and/or local education agencies/school districts to use their funds to develop, improve, expand, support, and innovate their CTE programs. In an accreditation process, community college and school district CTE programs are required to be re-accredited, thus the community college or school district is expected to expand, innovate, and update its programs in accordance to the new industry standards, which qualifies as an activity that pertains to size, scope, and quality.” (OCTAE Guidance, December 2016) May Perkins funds be used to pay for student certifications (CPR certification, OSHA Certification)? Yes/Conditional.

● If the certification is a requirement of the CTE course or if used as an assessment for the course for all students, then Perkins money may be utilized.

● Perkins funds may not be used for optional certification exams. May Perkins IV funds be used to pay a student’s technical skill assessment that is aligned with industry-recognized standards and that is related to the student’s CTE coursework? Maybe - limited circumstances.

● The technical skill assessment is required within the course or program (CNA certification), is contained in the course description, and is in the course syllabus.

● If all students in the CTE course are taking the assessment and the district uses the technical assessment results to report performance data to the State, an eligible recipient may use funds awarded under Perkins IV to pay the fee for a student’s technical skill assessment that is aligned with industry-recognized standards.

(Perkins Act of 2006, Sec. 113 (B) (i); USDE OCTAE Guidance May 2015) May Perkins IV funds be used for local support of Career and Technical Student Organizations (CTSOs)? Maybe. At the local level, allowable expenses would include supplemental teaching materials for the classroom, school-owned CTSO uniforms, and travel for the instructor, and substitute teacher costs for the adviser

if professional development is included. CTSOs restrictions against the use of Perkins funds. The support of CTSOs may not include:

● purchase of supplies, jackets, and other effects for students’ personal ownership ● cost of non-instructional activities such as athletic, social, or recreational events ● printing and disseminating non-instructional newsletters ● purchase of awards for recognition or students, advisors, and other individuals ● payment of individual membership dues ● data collection

(EDGAR CFR Part 403 Subsection E, §403.71 EDGAR 2CFR §200.454 and §403.71) May a district use its Perkins IV funds to pay the district’s dues in a CTE organization? Yes, this is an allowable expenditure since the membership belongs to the district and does not benefit an individual. (EDGAR 2 CFR PART §200.454) May food and beverage expenses be paid with Perkins IV funds? No. There is a very high burden of proof to show that paying for food and beverages with federal funds is necessary to meet the goals and objectives of a federal grant. See Appendix B for additional guidance. Email Pat Thieben for approval in writing, prior to purchase at pat.thieben@iowa.gov. Follow Appendix B guidance and the statements below before claiming food and beverage

reimbursement with federal funding. ● Meeting agenda is structured so participants have time to purchase their own food, beverages,

and snacks ● Meeting location provides easy access for participants to purchase food and beverages.

○ Determinations will be made on a case-by-case basis. ○ Grantees will have to make a compelling case that the unique circumstances they have

identified would justify these costs as reasonable and necessary. EDGAR 2 CFR PART §200.404 May Perkins IV funds be used to purchase groceries for the district’s family and consumer sciences food lab? No. Food is a consumable expenditure and falls under the most restrictive clause and is therefore, not eligible

When a discrepancy exists, between the federal Carl D. Perkins Act of 2006 and any Iowa policies, the more restrictive law and/or regulation takes precedence. 2 CFR §200 (c) of the Uniform grant guidance (UGG) requires that for a cost to be allowable, it must be consistent with the policies of the state. Thus if the state has a more restrictive rule, the sub recipient must follow it.

(Perkins Act of 2006, Sect 311 May a district use Perkins IV funds for entertainment or alcohol? No. (EDGAR 2 CFR PART 200 §200.423)

Equipment Is there a definition of Perkins “equipment”? Yes. The definition for equipment:

● Tangible property ≥ $5,000.00 (federal) and ≥$500 (state) ● Information technology systems having a useful life of more than 1 year ● A per unit acquisition cost equal to or exceeding the state threshold of $500 ● “Easily pilfered” items should be treated like equipment (labeled and inventoried)

Follow the equipment inventory and disposition documentation. (EDGAR CFR §200.33) What is Iowa’s definition of equipment? The Iowa Department of Education uses a per unit cost threshold of $500 or more for K-12 Certified Annual Report (CAR) purposes and also includes items with a per unit cost under $500 which are considered attractive or easily pilfered. Computer equipment such as CPU, monitor, disk drive, keyboard, and cables purchased as a system are to be listed and priced as a system. Such purchases may not be listed by individual components to achieve costs of less than $500. (Iowa Department of Education Financing Public Education in Iowa) What options exist for equipment purchased with Perkins IV funds when the equipment is no longer needed? The equipment shall be used in connection with other federally-sponsored activities, in the following order of priority:

● Other Perkins activities. A computer is purchased for an agricultural business program. When no longer needed, the computer may be transferred to a family and consumer science or an industrial technology program. The master inventory list will be revised to reflect the location change. See Equipment Inventory Template.

● Perkins consortium member school districts. If there are other districts within the consortium that could use the equipment, the equipment may be transferred to that district. The master inventory list will be revised to reflect the location change. See Equipment Inventory Template.

● Activities sponsored by other federal funds-awarding agencies, e.g., a computer is purchased for an agricultural business program. When it is no longer needed, and no other Perkins-funded program has a use for the computer, other federal activities can be considered. Title I staff have a need for the used computer. The computer may be transferred to Title I. See Perkins Equipment Guidelines.

● Trade-in or sale. When acquiring replacement equipment, the replaced equipment may be used as trade-in or it may be sold and the proceeds used to offset the costs of the replacement equipment. Disposition of Perkins Equipment.

(EDGAR 2 CFR Part 200.307 200.313 (e) (2))

One of the schools districts in a consortium is dropping a CTE program. May the district sell the equipment of the program being dropped and reinvest the dollars in another CTE program in the district? Adhere to the answer above and then the consortium agreement (the agreement should be included in annual grant application).

● Equipment and materials purchased with Perkins funds, through a consortium agreement, belong to the federal government.

● Useful life of the equipment is granted to the consortium.

o Members of the consortium must be involved in determining how the equipment is redistributed within the consortium.

● Because used equipment often sells for pennies on the dollar, it may make most sense to redistribute equipment among the consortium members.

(EDGAR 2 CFR 200.307 and 200.313(3)). What is the definition for “useful life”? “Useful life” ends when the equipment is no longer meeting the needs of the program. Note that useful life is not defined by a depreciation schedule. (EDGAR 2 CFR PART 2 200.436) What do “easily pilfered” items include? “Easily pilfered” items include, but are not limited to, digital cameras, laptops, iPads and tablet computers, DVD or Blu-Ray players, and tools. If the item is easily removed from its intended location, the item must be inventoried. (EDGAR 2 CFR PART 200.302 (b)(4)) Are there inventory requirements for equipment purchased with Perkins IV funds? Yes. Sub-grantees must maintain an Equipment Inventory Record for all Perkins IV-funded equipment that includes the following:

● A description of the equipment

● A serial number, model number, and/or other identification numbers

● The funding source(s) and percentage of the item’s acquisition cost covered by the source

● The acquisition date and unit cost

● The present location, use condition, and date the information was reported

● Transfer, replacement, or disposition of the equipment including the date of disposal, sale price, return of sale to Perkins and disposition information sent to the IDOE claims consultant) See Equipment Guidelines (EDGAR 2 CFR PART 200.313(d)(1))

Are there additional guidelines for Perkins IV inventory? Yes. The following guidelines apply:

● The inventory must be updated as equipment items are purged or new purchases are made.

● Equipment items purchased with Perkins IV funds are to be identified and physically marked as such.

● Adequate safeguards must be in place related to the loss, damage, or theft of the equipment. Any loss, damage, or theft should be investigated and fully documented.

● Adequate maintenance procedures should be implemented to keep the equipment in good condition.

A physical inventory of equipment items must be taken and the results reconciled with the inventory records at least once every two years. This process should be fully documented, including the person(s) responsible and date of completion. See Equipment Guidelines, EDGAR CFR Part §200.333.

In a consortium, is the ownership and responsibility for equipment purchased with Perkins IV funds retained by the consortium fiscal agent or may it be transferred to the local school in which the equipment is placed? The consortium retains a vested interest in the equipment for its useful life cycle (currently five years for computer equipment; seven years for all other equipment); however, the equipment may be assigned to and inventoried by an individual member district. (Perkins Act of 2006 (Part C, Sect. 131 (f)(2))

Consortium and Recipient Guidance May a consortium refuse to fund a program improvement activity requested by an individual member district? Yes. Funding decisions within a consortium remain a decision within that consortium. Funds allocated to a consortium shall be used only for purposes and programs that are defined in the local grant application and be mutually beneficial to all members of the consortium. (Perkins Act of 2006) May a district choose not to join a consortium if their formula-determined Perkins IV allocation is less than the minimum of $15,000 necessary? No. A district must join a consortium if its formula-determined Perkins IV dollars are less than the $15,000 threshold. The state can waive the minimum allocation rule if the LEA is located in a rural, sparsely populated area or is a public charter school that operates a secondary CTE program and demonstrates that it is unable to enter into a consortium. (Perkins Act of 2006)

Professional Development, Associations, Conferences, and Conventions How do we handle the registration fees which are due prior to the end of one fiscal year (June 30) and the professional development is delivered in the next fiscal year? The registration fee must be paid with the current fiscal year’s funds since this is when the actual expense occurs. Registration is essentially a contract with the organization and can be paid in advance. Actual travel expenses such as airfare, ground transportation, hotel, and food must be paid by Perkins in the fiscal year it is taken. (EDGAR 2 CFR PART 200, 200.472 and 200.474) May professional development for administrators be paid for with Perkins IV funds? Perkins IV funds are intended to improve CTE programs and the CTE skills of the students enrolled in CTE courses. The conference must be a CTE-related program that benefits CTE students, as well as impacts whole school reform and improvement for all students. Additionally, Perkins IV funds are targeted federal funds. The district must show the relevance to the CTE programs. All expenditures from Perkins IV must be “allocable” to the federal grant. (EDGAR 2 CFR PARTs 200.403, 200.404 200.472, and 200.474) May Perkins IV funds be used to pay for CTE instructors to attend a CTE educators’ association? Yes. Travel to CTE-related conferences is professional development and is eligible for reimbursement. (Perkins Act of 2006, Title III, Part B, SEC. 2(5) CFR 200.474). NOTE: Student travel is ineligible for reimbursement. Describe situations in which memberships, subscriptions, and professional activity costs are eligible for reimbursement with Perkins funds.

● Costs of a school district, non-federal entity’s membership in business, technical, and professional organizations

● Costs of the school district, non-federal entity’s subscriptions to business, professional, and technical periodicals

● Costs of a membership in any civic or community organization with prior approval by the Bureau of Career and Technical Education

● *Costs of individual memberships and subscriptions in business, technical, and professional organization are ineligible for reimbursement

(Perkins Act of 2006 EDGAR CFR Part and 200.454)

May Perkins IV funds be used to pay a CTE instructor’s stipend to attend a professional development activity occurring on non-contract days? Maybe. All travel and registration must be supported by the general fund

a) No. Stipends are ineligible for reimbursement when the district has a history of paying CTE instructor stipends from the general fund for non-contract days (supplanting).

b) No. Stipends are ineligible for reimbursement when the district sends CTE and non-CTE instructors to the same conference.

c) Yes. Standard and past operating procedure is to pay all non-contract day, professional

development activities using Perkins IV. (EDGAR C.F.R Part 200 §200.472)

d) No. If the district sends CTE and non-CTE instructors to the same professional development opportunity, Perkins IV funding may not be used to pay any of the instructors. Stipend pay must be taken from a funding source that is not Perkins IV.

May Perkins funds be used to pay for a keynote speaker at a CTE event? Yes, if the speaker is providing a professional development experience for CTE teachers. (EDGAR C.F.R Part 200 §200.34 (c)(4)(ii)) May teacher(s) be reimbursed using Perkins IV funds to attend a CTSO leadership development conference? Yes, the cost of training and education provided for employee development is allowable (200.472) if the teacher(s) is (are) presenting or actively involved in professional development during the conference. (Perkins Act of 2006. Sect. 311; EDGAR 2 CFR PARTs 200.472 and 200.474) May Perkins funds be used to support student transportation, lodging, and meals at technical skill competitions as part of national career and technical student organization (CTSO) conferences or conventions? No. The support of CTSOs may not include lodging, feeding, conveying, or furnishing transportation to conventions or other forms of social assemblage. (USDE OCTAE Guidance May, 2009; 34 CFR 403.71)

Project Lead the Way (PLTW) May a district use Perkins IV dollars to maintain or replace equipment which was originally purchased with a Project Lead the Way (PLTW) grant? Yes, if: ● Equipment is for an identified CTE program

● The equipment is used in a course taught by a licensed teacher with a PLTW endorsement

● The PLTW course is part of the district’s course offerings (Project Lead the Way Guidance)

May Perkins IV funds support PLTW programs? Perkins IV funds may be used to support PLTW courses if they are part of a CTE sequential program, and the instructor(s) is (are) properly endorsed. (Project Lead the Way Guidance) May a district use Perkins IV dollars to maintain or replace equipment which was originally purchased with a Project Lead the Way (PLTW) grant? Yes, if: ● Equipment is for an identified CTE program

● The equipment is used in a course taught by a licensed teacher with a PLTW endorsement; and,

● The PLTW course is part of the district’s course offerings. (Project Lead the Way Guidance)

Career and Technical Student Organizations (CTSOs) What benefit do CTSOs provide for school districts? CTSOs provide a unique program of career and leadership development, motivation, and recognition for youth and adult students in secondary and postsecondary education that are (or were) enrolled in CTE programs. CTSOs provide instructional strategies for students to develop, improve, and expand occupational competencies related to a particular career interest. Other integration activities include serving as an extension of the classroom and laboratory instructional program which enriches and enhances classroom and laboratory learning. These organizations present specific activities for students to gain personal and leadership skills, making students more employable and preparing them to become productive employers, employees, citizens and family members. CTSOs can be utilized as a recruitment tool to target underrepresented students, exposing them to non-traditional career options. Association for Career and Technical Education (34 CFR 403.71) Are CTSOs “clubs”? No. CTSOs are not “clubs” to which only a few CTE students are members. A CTSO is an instructional tool which works best when it is integrated into the CTE curriculum and classroom by instructors who are committed to the development of all students. CTSOs are referred to as “curricular” or “co-curricular,” but they are not “extracurricular.” (34 CFR 403.71) May teacher(s) be reimbursed using IV Perkins funds to attend a CTSO leadership development conference?

Yes, if the teacher(s) is (are) presenting or actively involved in professional development during the conference. However, if the sole purpose of the teacher is to supervise students, then Perkins funds cannot be used. Perkins funds may not be used for supervision of students. (Supplanting - supervision is generally provided by the district for students during other school-related travel.

(EDGAR 2 CFR §200.472, 34 CFR 403.71) May Perkins funds be used to support student transportation to, and lodging and meals at technical skill competitions as part of national career and technical student organization (CTSO) conferences or conventions? No. The USDE’s long-standing interpretation regarding the types of CTSO costs that may be paid from federal grant funds is that Perkins funds, used for the support of CTSOs, may not be used for lodging, feeding, conveying, or furnishing transportation to conventions or other forms of social assemblage. (Limited circumstances i.e., for special population students). (USDE OCTAE Guidance May, 2009) (34 CFR 403.71)

Middle Schools May Perkins IV funds be used for middle school? No. Perkins IV funds may not be used to provide CTE programs to students prior to the seventh grade.

‘No funds received under this Act may be used to provide career and technical education programs to students prior to the seventh grade, except that equipment and facilities purchased with funds under this Act may be used by such students.

(Perkins Act of 2006,)

Program Evaluation Are districts required to evaluate CTE programs? Yes.

Beginning in the 1992-1993, each recipient of Perkins IV financial assistance shall annually evaluate the effectiveness of its career and technical programs. The evaluation shall identify and adopt strategies to overcome barriers that are resulting in lower rates of access to, or success in, CTE programs for members of special populations and evaluate the progress of individuals who are members of special populations. Districts shall also evaluate its progress in providing CTE education students with strong experience in and understanding of all aspects of the industries its students are preparing to enter.

(Perkins Act of 2006) With the passing of Iowa HF2392 in 2016, all programs now need to be State-approved. During the approval process with the Regional Planning Partnership, all programs will undergo a complete program review which will meet the Perkins requirements.

Perkins Improvement Plans Are Perkins IV recipients required to write an improvement plan? Maybe.

● Improvement plans are required, only when the consortium or LEA does not meet the negotiated targets within 90% of their negotiated levels for Perkins performance indicators.

● Consortium and LEAs do not need to write a plan if their target is higher than the state target and the consortium and LEA meets the state target.

(Perkins IV Section 123(a)(1)(B.33)) What should the improvement plan address? An improvement plan must, at a minimum, include the following items:

● The core indicator(s) of performance for which the district, consortium, and/or community college failed to meet the 90% threshold

● Beginning in the current program year, the action steps which will be implemented to improve the performance on the core indicator(s)

● The staff member(s) who is (are) responsible for each step

● The timeline for completing each step (Perkins Act of 2006, Sec. 123)

CTE Reporting Should a student be reported as a concentrator if he/she completes a full year of CTE courses in District A, move into District B, and takes an additional full year in District B? The district will make the determination locally depending on its program. The reporting system will only pull credits the student has earned in your district. It does not pull what they have earned in previous districts.

Example: (Agriculture): Your district has a program designated as Ag Business. Your district has identified the course work which comprises the Agri-Business program. A student moves in from another district who has taken a year of Horticulture in the previous district. If Horticulture coursework corresponds to your program and is part of your district’s Agri-Business program, the district may locally decide to adjust the total units in the Secondary CTE Reporting Application.

For assessment purposes, how should districts count classes for students moving into the district that were taken in a previous district or districts? This is a local decision since course names are not identical from district to district.

How should districts report a student when the student is enrolled in the district, the student is not considered a dropout, and the student is not attending?

Report students fitting this category as ‘not assessed’. What assessment should be used to report technical skill proficiency for students in a program of study (POS)? Districts should use the assessment(s) identified and approved during their POS development process. When we select the assessments for our POS, what is the proficiency level for which we are aiming? The assessment and the proficiency level must be approved by a third party, which includes the district and/or regional advisory committee and the community college to which the program is aligned. If the assessment is an industry certification, a level of proficiency is pre-determined. What is the definition of a “participant” at the secondary level? For the secondary level, a CTE (CTE) participant is defined as a student who has completed one-half (0.5) or more units in any CTE program area. What is the definition of a “participant” at the postsecondary level? For the postsecondary level, a CTE participant is a student who has earned one or more credits in a CTE program area. What is the definition of a “concentrator” at the secondary level? For the secondary level, a CTE concentrator is defined as a student who has earned one and a half

(1.5) or more units in a single CTE program area. What is the definition of a “concentrator” at the postsecondary level? For the postsecondary level, a CTE concentrator is defined as a student who:

1) Completes at least 12 academic or technical credits within a single CTE program sequence that is comprised of 12 or more academic or technical credits that terminates in the award of an industry-recognized credential, certificate, diploma, or degree; or

2) Completes a short-term CTE program sequence of less than 12 credits that terminates with an

award of an industry-recognized credential or a certificate. What are the requirements for a completed, approved Program of Study (POS) For a completed, approved POS:

● Content standards and benchmarks must be established.

● Critical competencies must be identified and approved by the advisory committee / council and postsecondary institution

● A plan for sharing POS course sequence with stakeholders must be in place

● A technical skill assessment has been approved by the advisory committee / council and postsecondary institution

● A plan for annual review and continuous improvement of the POS is in place and is being implemented

● A POS course sequence, i.e., “drawing board” with linkage to at least one postsecondary program has been established. The drawing board includes:

o Academic and technical content

o Incorporation of the Iowa Core (including 21st Century Skills)

o State of Iowa and local high school graduation requirements

o Non-duplicative progression of courses consisting of a minimum of three units of CTE coursework

o Linkage to at least one postsecondary program

(DE Guidance document) More information on the 10 steps required for a Program of Study can be found on the Advance CTE Webpage:

Appendix A

Unallowable / Ineligible Costs

Alcoholic beverages (EDGAR 2 CFR Section §200.423 )

Alumni/ae activities (EDGAR 2 CFR Section §200.424)

Bad debts (losses from uncollectible accounts)(EDGAR 2 CFR Section §200.426)

Buildings and land

Capital expenditures (EDGAR 2 CFR Section §200.13)

Commencement and convocation costs (EDGAR 2 CFR Section §200.429)

Construction, renovation, and/or remodeling of facilities (limited circumstances i.e., labor required to rewire for code compliance) (EDGAR 2 CFR §200.439)

Consumables: Food, paper, pencils, notebooks (Districts assume responsibility to maintain a minimal service level for CTE (the same minimum service level as for all other grant and general education expenditures.) EDGAR 2 CFR §200.403

Contingency provisions (EDGAR 2 CFR §200.433)

Contributions and donations (cash, property, services) (EDGAR 2 CFR §200.434)

CTSO student travel costs (lodging, feeding, conveying, or furnishing transportation to conventions or other forms of social assemblage. (Title 34, volume 3, EDGAR §403.71)

CTSO effects for students’ personal ownership (jackets, supplies, thumb drives), recreation, membership dues, data collection (Title 34, volume 3, EDGAR 403.71).

Entertainment (amusement and social activities, i.e., sports tickets) (EDGAR 2 CFR §200.438)

Expenditures that supplant (paid with general fund for other programs); stipends for non-contract days, paper, printers, markers, keyboards, mice, basic computers, desks, dust pans, brooms, shovels, food, binders, folders, individual uniforms, individual membership dues) §200.22

Fines and penalties (EDGAR 2 CFR §200.441)

Fundraising See Student Activity Funds for more information (EDGAR 2 CFR §200.442)

Goods or services for personal use (EDGAR 2 CFR §200.445)

Instructional materials and supplies (pens, paper, poster-board, markers, dry erase boards, paint, nails, varnish, etc.) Districts assume responsibility to maintain a minimal service level for CTE (the same minimum service level as for all other grant and general education expenditures. ) §200.22

Unallowable / Ineligible Costs

Items retained by student (supplies, clothing/uniform, tools, calculators) (EDGAR 2 CFR §200.445)

Insurance. The federal grant funds cannot be used to purchase insurance; “Districts must, at a minimum, provide the equivalent insurance coverage for real property provided to property owned by the non-Federal entity (EDGAR 2 C.F.R., Part §200.310, Subpart D).

Lobbying (EDGAR 2CFR §200.450)

Memberships (Individual membership dues are ineligible; district memberships are eligible) (EDGAR 2 CFR §200.454)

Non-instructional furniture (EDGAR 2 CFR §200.439)

PLTW expenditures if taught by math and science instructors who have not taken the PLTW training and without a CTE endorsement (Project Lead the Way Guidance)

Political activities (contributions, fundraising, lobbying) (EDGAR 2 CFR §200.442)

Pre-award costs (prior to July 1) (EDGAR 2 CFR §200.458)

Professional development for personal benefit (tuition costs, exam fees) (EDGAR 2 CFR §200.454)

Promotional selling and marketing materials (T-shirts, pens, cups, key chains) (EDGAR 2 CFR §200.467)

Scholarships (EDGAR 2 CFR §200.466)

Stipends for CTE instructors attending professional development activities on non-contract days. If district has a history of paying stipends out of the general fund, the stipends are not allowable (supplanting) (EDGAR 2 CFR §200.75)

Student expenses/direct assistance to students (tuition, fees, insurance, transportation, lodging, registration fees, and other expenses) (EDGAR 2 CFR §200.466) Supplanting

Textbooks for normal classroom delivery and not for a new course

Vehicles for auto body/collision repair (request pre-approval prior to purchase) Permissive Category

The Iowa Perkins State Plan may have more restrictive policies than the federal regulation.

● e.g., EDGAR requires sub-recipients to inventory items <$4,999.00. The Iowa Perkins State Plan and Perkins Grant Guidelines required sub-recipients to inventory items that are <$499.00. EDGAR requires all sub-recipients to implement the most restrictive rule. 200.403

Contact claims team with questions, amy.vybiral@iowa.gov, 515-339-4520 or pat.thieben@iowa.gov, 515-281-4707.

Appendix B Frequently Asked Questions

To Appropriately Use Federal Funds for Conferences and Meetings

Basic Federal Regulations

● The use of federal funds for travel, transportation and/or subsistence expenses are allowable only in limited circumstances.

● An appropriate justification must be available anytime the use of federal funds is provided for travel, transportation, or subsistence expenses.

● Justifying the allowability of these expenses is the responsibility of the grantee. ● As a general rule, with limited exceptions, federal funds may not be used for personal expenses (i.e.,

food). “Food” includes, but is not limited to, coffee, snacks, light refreshments, hors d'oeuvres, breakfast, lunch, dinner, etc. Using Federal Grant (Discretionary and Formula) Funds to Host a Meeting or Conference 1. May a grantee receiving funds from the U.S. Department of Education (Department) use its Federal grant funds to host a meeting or conference? Yes. Federal grant funds may be used to host a meeting or conference if doing so is:

· Consistent with its approved application or plan; · For purposes that are directly relevant to the program and the operation of the grant, such as for conveying technical information related to the objectives of the grant;

A grantee hosting a meeting or conference may not use grant funds to pay for food for conference attendees unless doing so is necessary to accomplish legitimate meeting or conference business.

· A working lunch is an example of a cost for food that might be allowable under a Federal grant if attendance at the lunch is needed to ensure the full participation by conference attendees in essential discussions and speeches concerning the purpose of the conference and to achieve the goals and objectives of the project.

Example Situation: ·Our Department holds community forums to garner input which we use when creating State Plans. These typically occur over dinner, and we are afraid that without providing dinner, the community won’t attend, which will diminish our ability to write an effective plan. To avoid this we provide full buffet style dinners to all who attend. ·What are the relevant facts? ·Is this allowable? If yes, why? If no, why not and what could be done differently to make it allowable? Relevant Facts:

• This appears to be a legally constituted group pursuing a mandated function. • Having some- not all – community meetings at night is reasonable. • This appears to be the evening equivalent of a working lunch.

Is this Allowable?

No. Although all the aspects listed above would indicate this as an allowable activity, the “full buffet style dinner” appears to be an unreasonable method to complete the activity. Dramatically scaling back the food could make this activity allowable.

Grantees must follow all applicable statutory and regulatory requirements in determining whether costs are reasonable and necessary, especially the Cost Principles for Federal grants set out at 2 CFR Part 200 Subpart E of the, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” Items that are Never Allowable:

• Alcoholic beverages • Entertainment, including the costs of amusement, diversion, and social activities • Expenses that are already covered by per diem • The grantee cannot document how the expense is necessary and reasonable

2. What are examples of “technical information” that may be conveyed at a meeting or conference?

Examples of technical information include, but are not limited to, the following, each of which must be related to implementing the program or project funded by the grant:

• Specific programmatic, administrative, or fiscal accountability requirements; • Best practices in a particular field; • Theoretical, empirical, or methodological advances in a particular field; • Effective methods of training or professional development; and • Effective grant management and accountability.

3. What factors should a grantee consider when deciding whether to host a meeting or conference? Grantees should consider whether a face-to-face meeting or conference is the most effective or efficient way to achieve the desired result and whether there are alternatives, such as webinars or video conferences, that would be equally or similarly effective and more efficient in terms of time and costs than a face-to-face meeting. In addition, grantees should consider how the meeting or conference will be perceived by the public; for example, will the meeting or conference be perceived as a good use of taxpayer dollars? 4. When a grantee is hosting a meeting, may the grantee use Federal grant funds to pay for food, beverages, or snacks? Generally, there is a very high burden of proof to show that paying for food and beverages with Federal funds is necessary to meet the goals and objectives of a Federal grant. In developing the agenda for a meeting/conference, every effort should be made to set the agenda in a manner that allows attendees sufficient time to procure snacks and meals at their own expense. In addition, when planning a meeting, grantees may want to consider a location in which participants have easy access to food and beverages. While these determinations will be made on a case-by-case basis, and there may be some circumstances where the cost would be permissible, it is likely that those circumstances will be rare. Grantees, therefore, will have to make a compelling case that the unique circumstances they have identified would justify these costs as reasonable and necessary. The key factor in the decision making process on whether or not to expend Federal funds for food at conferences and meetings, is the food necessary for the performance of the Federal award? Example situation: Our Commission provides coffee in the morning and cookies in the afternoon. We have done so for 15 years and our members have come to expect this. Can we continue?

·What are the relevant facts?

·Is this allowable? If yes, why? ·If no, why not and what could be done differently to make it allowable?

·Relevant Facts: ·This appears to be a legally constituted group pursuing a mandated function. Coffee and cookies have been provided for 15 years and members have come to expect this

Is this Allowable? No. No facts were presented to indicate that providing these amenities for members is necessary to achieve the mandate functions. Furthermore, these amenities may be covered in per diem costs, which are already paid to the member. We recommend assuring agendas or other plans are structured to allow members time to acquire food/drinks on their own.

5. May Federal grant funds be used to pay for food and beverages during a reception or a “networking” session? In virtually all cases, using grant funds to pay for food and beverages for receptions and “networking” sessions is not justified because participation in such activities is rarely necessary to achieve the purpose of the meeting or conference. 6. May grantees provide meeting participants with the option of paying for food and beverages (e.g., could a grantee have boxed lunches provided at cost for participants)? Yes. Grantees may offer meeting participants the option of paying for food (such as lunch, breakfast, or snacks) and beverages, and arrange for these items to be available at the meeting. 7. What should a grantee consider when planning to use Federal grant funds for attending a meeting or conference?

Grant funds may be used to pay for the costs of attending a conference. Specifically, Federal grant funds may be used to pay for conference fees and travel expenses (transportation, per diem, and lodging) of grantee employees, consultants, or experts to attend a conference or meeting if those expenses are reasonable and necessary to achieve the purposes of the grant. When planning to use grant funds for attending a meeting or conference, grantees should consider how many people should attend the meeting or conference on their behalf. The number of attendees should be reasonable and necessary to accomplish the goals and objectives of the grant.

8. What are the consequences of using Federal grant funds on unallowable expenses? Grantees are responsible for the proper use of their grant awards and may have to repay funds to the Department if they violate the rules on the use of grant funds, including the rules for meeting- and conference-related expenses. The Department may seek to recover any Federal grant funds identified, in an audit or through program monitoring, as having been used for unallowable costs, including unallowable conference expenses.

9. Whom should grantees call if they have specific questions about the allowable use of Federal grant funds? Grantees are strongly encouraged to contact their project officer with any questions or concerns about whether using grant funds for a meeting or conference is allowable prior to committing grant funds for such purposes.

Appendix C Claim Example

What do I EXCLUDE?

Any document that is NOT an invoice or receipt

What do I exclude or remove when claim is returned to me?

Why?

Purchase order Does not show receipt of item

Does not show payment for item

Requisition Does not show payment of item

Does not show receipt of item

Cancelled Check Does not show item description

Does not show receipt of item

Eligibility cannot be determined

Warrant Does not show item description

Does not show receipt of item

Eligibility cannot be determined

Credit Card Statement Does not show item description

Eligibility cannot be determined

Registration forms Does not confirm payment of registration fees

What do I exclude or remove when claim is returned to me?

Why?

Emails or letters from or to supervisors, principals, Perkins contact.

Does not confirm payment or receipt of items

What do I exclude or remove when claim is returned to me?

Why?

General ledgers Only when all like costs are totaled together e.g.,

R5 - Indicate total for all subs by quarter when submitting for reimbursement. Include Base + FICA+ IPERS and TOTAL. Indicate R5 next to each total.

Do Not Use General Ledgers for any other activity (R1 through P20 - Use only receipts and invoices).

Call for prior approval to use GL if you have examples not on this list 515-339-4520 or email amy.vybiral@iowa.gov

Claims Summary Page

Hotel fees for instructors (R5) (eligible) Remove student expenditures - Ineligible.

Do NOT submit documentation in duplicate or triplicate - one invoice per purchase.

Checks are insufficient documentation, impossible to determine item eligibility or if purchased in the period of performance.

No letters. It’s duplicative and slows the process. One original invoice or receipt per item.

No letters. It’s duplicative and slows the process. One original invoice or receipt per item.

No warrants or voucher. Invoice only. No duplication