Local Uses of Funds
Requirements for Local Uses of Funds
Each consortium develops and submits a biennial application and yearly budget to expend their allocated basic and reserve funds, addressing the requirements identified in Section 134 of the Perkins V Act. At this sub-recipient (consortium) level, expenditures are based on the approved local application.
Sections 131(f) and 132(a)(3) of Perkins V establish the requirements for the use of funds within consortia.
At a minimum, consortium funds must be used only for purposes and programs mutually beneficial to all consortium members. This presupposes joint planning by the consortium members, resulting in effective programs of sufficient size, scope, and quality. Moreover, a consortium is precluded from allocating resources to members in amounts equal to their original allocations or for purposes and programs that are not mutually beneficial. In other words, funds are distributed according to the consortium's approved application.
Section 135: Local Uses of Funds
Each local consortium receiving funds under Perkins V must use the majority of the funds "to develop, coordinate, implement, or improve CTE programs to meet the needs identified in the comprehensive needs assessment." Not more than five percent of the award may be used for administrative purposes. There must be a clear linkage between the needs assessment and how funds are spent. In addition to being justified by the needs assessment, funds must be used to support CTE programs that are of sufficient size, scope, and quality to be effective and that:
- Provide career exploration and career development activities through an organized, systematic framework designed to aid students, including in the middle grades, before enrolling and while participating in a CTE program, in making informed plans and decisions about future education and career opportunities.
- Provide professional development for teachers, faculty, school leaders, administrators, specialized instructional support personnel, career guidance and academic counselors, or paraprofessionals.
- Provide within CTE the skills necessary to pursue a career in high-skill, high-wage, or in-demand industry sectors or occupations.
- Support integration of academic skills into CTE programs and programs of study.
- Plan and carry out elements that support the implementation of CTE programs and programs of study and that result in increasing student achievement on performance indicators.
- Develop and implement evaluations of the activities carried out with funds under this part, including evaluations necessary to complete the local needs assessment and the local report.
A consortium can pool resources with other consortia to support program of study implementation through the professional development activities listed above. Refer to Section 135 of the Act for more detailed elements that require your attention (pages 202-205 of Perkins V: The Official Guide to the Strengthening Career and Technical Education for the 21st Century Act (PDF); A Hyslop; Association for Career and Technical Education).
Section 211(a) of Perkins V clearly states:
"SUPPLEMENT NOT SUPPLANT—Funds made available under this Act for career and technical education activities shall supplement, and shall not supplant, non-federal funds expended to carry out career and technical education activities."
Perkins funds shall supplement, not supplant (replace), non-federal funds expended for CTE. If an activity is, or has been, supported by non-federal funds, Perkins funds may not be used to support that activity unless there is overwhelming evidence that the activity would be terminated where it is not supported by Perkins funds.
Seek state advice before proceeding under this exception. If the district or college would normally pay for an item, service, or activity, then Perkins dollars should not be used.
Examples:
- The district provides all teachers standard classroom technologies (i.e., laptop, projector, SmartBoard, etc.) but wants to use Perkins funds to provide these assets specifically for career and technical education (CTE) classrooms. This is supplanting.
- The college has previously paid for administrative personnel from the general operating budget, but the current request is to move part of that salary to Perkins. This is supplanting without evidence of changes in duties, including a reduction in general duties to accommodate the new Perkins work.
Section 135 of Perkins V states, "Funds made available to eligible recipients … shall be used to support CTE programs that are of sufficient size, scope, and quality to be effective and that -"
- Provide career exploration and career development activities
- Provide professional development for CTE professionals
- Provide within CTE the skills necessary to pursue careers in high-skill, high-wage, or in-demand industry sectors or occupations
- Support integration of academic skills into CTE programs and programs of study
- Plan and carry out elements that support the implementation of CTE programs and programs of study and that result in increasing student achievement of the local levels of performance established under section 113
- Develop and implement evaluations of the activities carried out with funds under Section 135
The Perkins V Act does not define size, scope, and quality, but leaves it to individual states to interpret what that means. Minnesota has defined size, scope, and quality as the following:
Size
Parameters and/or resources that affect whether the program can adequately address student learning outcomes; this includes:
- Number of students within a program
- Number of instructors/staff involved with the program
- Number of courses within a program
- Available resources for the program (space, equipment, supplies)
Scope
- Programs of study are part of or working toward inclusion within a clearly defined career pathway with multiple entry and exit points
- Programs of study are aligned with local workforce needs and skills
- Postsecondary programs connect with secondary CTE via articulation agreements and/or dual credit, etc.
- Programs develop not only specific work-based skills, but also broadly applicable employability skills
Quality
- A program must meet two of the following three criteria to meet Minnesota's standard of quality: the program develops (1) high-skilled individuals, (2) individuals who are competitive for high-wage jobs, and (3) individuals who are trained for in-demand occupations
- High-skilled: individuals completing programs resulting in industry-recognized certificates, credentials, or degrees
- High-wage: Above the median wage for all occupations, based on recent data from DEED
- In-demand: Occupations identified in the Occupation in Demand index and/or through local needs assessment
Consumable supplies maintain a CTE program instead of providing improvement and innovation. Perkins funds are intended to make transformational changes and improvements to the CTE program.
Examples:
- Supplies that are consumed/used up, such as ink, toner, printer cartridges, paper, food, health science first aid kit supplies/gloves, lumber, welding wire, etc. (Note: secondary may want to consider including these items as part of their reported CTE Revenue/Levy).
- Items given to a student and do not stay with the program as a resource for other students (e.g., workbooks). This is not allowed.
Perkins funding supports CTE programs and services, not select individuals. If the budget request supports only select individuals, this is not allowable. This applies to instructional staff as well as students.
Examples:
- Awards, recognitions, scholarships, tuition, certification, exams, memberships, etc., directly benefit only certain individuals and, therefore, are not allowed.
- Purchasing uniforms, equipment, or resources that become the property of students is not allowed.
It is not allowable to spend Perkins funds on structural changes, constructing buildings, or capital improvements. Remember that nothing purchased with Perkins funds belongs to the local school district or college. If a district or college closes a program(s), all Perkins purchases must be transferred to other approved CTE programs. Obviously, it would not be possible to transfer upgraded wiring or a wall that has been moved.
Examples:
- A district wants to upgrade to a commercial-grade kitchen, and the new equipment will require increased electrical access and load capacities. Perkins funds cannot pay for the improvement of infrastructure such as electrical, moving of walls, installing plumbing, etc.
- Changes such as rewiring a lab or widening a doorway to accommodate new equipment purchases for a CTE program would not be acceptable uses of funds. These are capital improvements a college would make to support the CTE program upgrades.
CTE is about career preparation through industry-driven programming and learning opportunities. Your request for local uses of funds should connect to your CLNA, approved local Perkins plan, and the industry standards. The goal is to have the same equipment and tools that industry professionals use to provide learning opportunities for students. Does the equipment request align with the technical skill requirements of the identified content/program area? Is the equipment purchased in alignment with the curriculum? What percentage of time will the equipment be utilized? What has your consortium written in the local plan to address size, scope, and quality, and does the request for local uses of funds fit the consortium's priorities?
Examples:
- Requesting to attend professional development that is remotely connected to CTE or an industry, but not directly aligned to the state or local Perkins plan.
- Audio/Video production program wants to buy video cameras and proposes buying less expensive cameras so that all students can use one in class. Industry professionals are not using similar equipment. They are using professional-quality DSLR camera/video cameras with professional-grade accessories.
- Request to make a high-dollar equipment purchase that only serves a small student population. Consider the cost per student in your request (Consultation with state staff may be needed).
Refer to Perkins V Section 135 for a complete description of requirements for uses of funds at the local level.
Consortium expenditures may be used for State-Recognized Programs of Study and intentional, specifically-identified and prioritized Programs of Study. Expenditures should be based on the results of the comprehensive local needs assessment (CLNA), included in the Consortia Plan application, and assure Perkins Uses of Funds criteria are met (found here and under Section 135 on Perkins V).
Essential questions to ask as you consider the eligibility of a proposed expenditure using Perkins funds include:
- How is the proposed expenditure intentionally supporting your identified State-Recognized Programs of Study and your local priorities identified in your application/plan? Elements and priorities must be led by the CLNA.
- Is the proposed expenditure necessary, reasonable, and allocable?
- Does the proposed expenditure support new and innovative changes?
- What industries does your CLNA identify as high-skill, high-wage, or in-demand in your region?
- What has your consortium written in the plan to address size, scope, and quality? (See definitions in CLNA, and Sections 131 and 132.)
- How is the proposed expenditure ensuring support for access and participation of special population groups?
- Does your comprehensive local needs assessment support the expenditure?
- Has the expenditure been vetted with your consortium's governance team?
- Is the focus of the expenditure on systems alignment and program improvement?