Section 9 Requirements for Local Uses of Funds

Local Uses of Funds

Requirements for Local Uses of Funds

In Minnesota, eligible recipients of Perkins funds are the 23 designated Perkins consortia. To receive Perkins funding, a consortium must submit a local application for funding annually. The application describes how the consortium plans to use Perkins funds during the grant year. Only after the State CTE director notifies the consortium that the local application has been approved can the consortium begin to spend awarded funds.

Sections 131(f) and 132(a)(3) of Perkins V specify that consortium funds must be used only for purposes and programs that are mutually beneficial to all consortium members. Uses of funds are data-driven; in other words, funds must be distributed within the consortium to districts or programs based on priorities identified in the CLNA and not based on percentage, formula, or any other method. Section 135 of Perkins V and 2 CFR§200 (Subpart E) describe allowable, and in some cases, unallowable uses of federal funds. As the eligible agency for distribution of federal funds, Minnesota State reserves the right to make final decisions concerning eligible uses of funds.

Section 135: Local Uses of Funds

Section 135 of Perkins V includes the six broad categories listed below. More specific examples under each category are included in the legislation. Each local consortium receiving funds under Perkins V must use funds "to develop, coordinate, implement, or improve CTE programs to meet the needs identified in the comprehensive needs assessment." Funds must be used to support CTE programs that are of sufficient size, scope, and quality to be effective and that:

  1. 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.
  2. Provide professional development for teachers, faculty, school leaders, administrators, specialized instructional support personnel, career guidance and academic counselors, or paraprofessionals.
  3. Provide within CTE the skills necessary to pursue a career in high-skill, high-wage, or in-demand industry sectors or occupations.
  4. Support integration of academic skills into CTE programs and programs of study.
  5. 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.
  6. 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.

Supplement versus Supplant

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."

There are two presumptions of supplanting:

  • If Perkins funds are used to pay for an activity of service that is required to be provided under state or local law; or
  • If Perkins funds are used to pay for a cost that was paid for in the prior year with state or local funds.

Federal funds cannot be used to pay for services, staff, programs or materials that have previously been paid for with state or local funds within a 12-month (366-day) period or that are otherwise a local fiscal responsibility required by state or federal law. An exception to the 12-month period may only apply in rare cases where there is clear and compelling evidence that the activity would be eliminated without Perkins support. In these situations, the district or college must document that the cost continues to be necessary, is not otherwise sustainable, and would not continue without these funds. Consult state staff when determining whether this exception applies. Perkins funding is neither designed nor able to be the full support of local CTE program(s), but is rather a complement and supplement to local resources.

Examples of Supplanting:

  • A school district purchases CPR manikins with local funds and purchases additional mannikins later in the year with Perkins funds. This would be considered supplanting because the same items were purchased with local and Perkins funds during the same year.
  • A college moves salary for an existing position from local funding to Perkins funding without a change in duties performed. Unless this position is now responsible for Perkins-related duties with a subsequent reduction in other duties, this would be considered supplanting.
  • Purchase of common classroom technologies that may be used for any course delivery, not specifically for a CTE classroom, is supplanting.

Consumables

Minnesota prioritizes Perkins funding for innovation and improvement. Consumable supplies maintain a CTE program, while Perkins funds are intended to make transformational changes and improvements to the CTE program. Any purchase of supplies or consumables must be pre-approved by state staff.

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 allowable.

Direct Individual Benefit

2 CFR 200.403 states that to be allowable under a Federal award, costs must be necessary, reasonable, and allocable. A cost that primarily benefits an individual fails the allocability test. Perkins funds support CTE programs, not individuals.

Expenditures must provide a broad, program-level benefit that is accessible to all participants in a CTE program or pathway. Costs should strengthen the overall quality, scope, or accessibility of the program rather than provide a one-time or exclusive benefit to a single individual or small group. For example, purchasing shared classroom equipment, upgrading instructional materials, or supporting professional development that improves instruction across an entire program would generally meet the allocability standard because the benefit extends to all students served.

Examples:

  • Awards, scholarships, tuition, individual certification or membership costs directly benefit individuals and, therefore, are not allowed.
  • Purchasing uniforms, supplies, or resources that become the property of students is not allowed.

Capital Improvements

Use of Perkins funds for structural changes to facilities is unallowable in Minnesota.

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 to infrastructure such as electrical wiring or plumbing.
  • Widening a doorway to accommodate new equipment purchased for a CTE program would not be an acceptable use of Perkins funds. The college or district is responsible for facility changes or improvements.

Weak or Absent Connections

2 CFR 200.403 states that all costs must be necessary, reasonable, and allocable to the grant’s purpose. This means expenditures must directly support high-quality CTE programming that prepares students for in-demand careers. Equipment, materials, and services funded through Perkins should reflect current industry practices and be integrated into the approved curriculum to ensure students gain relevant technical skills. Requests that do not demonstrate a clear connection to program improvement, technical skill attainment, or industry alignment are unallowable.

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.
  • Purchase of less-expensive video cameras for an Audio/Video production program so that all students can use one in class, although they are not considered “industry-standard” equipment.
  • 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.

Overarching Considerations and Key Questions

Consortium expenditures must be based on the results of the comprehensive local needs assessment (CLNA) and be documented in the approved consortium Plan. All proposed costs must meet use-of-fund requirements under Section 135 of Perkins V, 2 CFR 200 (Subpart E), and this Operational Guide.

To ensure consistency as you consider the eligibility of a proposed expenditure using Perkins funds, utilize these 10 decision-making criteria (key questions):

  • CLNA Alignment is Required: Expenditures must clearly align to consortium-identified priorities in the approved local plan. This ensures funds are data-driven and targeted toward validated program gaps rather than individual preferences.
  • EDGAR Compliance is Non-Negotiable: All costs must be necessary, reasonable, allocable, and properly documented, with clear evidence supporting allowability. This protects the consortium from audit risk and ensures responsible stewardship of federal funds.
  • Program of Study Focus: Investments must support Programs of Study and align to consortium-defined priorities. This ensures funding is focused on comprehensive program improvement rather than isolated or disconnected activities.
  • Industry Relevance and Equipment Standards: Fund only those activities and resources that align to high-skill, high-wage, and in-demand industries identified in the CLNA. Equipment purchases must reflect current industry-grade tools, technology, and standards used by professionals, be integrated into the curriculum, and provide students with authentic, real-world learning experiences. This ensures students are trained on relevant equipment that prepares them for actual workforce expectations.
  • Supplement, Not Supplant: Perkins funds must add value—not replace local or state funding. This preserves the intent of Perkins as a complement to, not a replacement for, existing funding.
  • Program-Wide Impact: Expenditures must benefit the overall programs, not provide direct or exclusive benefit to individuals. This ensures equitable access and maximizes the return on investment across the entire consortium.
  • Student Outcomes: Priority should be given to investments that measurably improve technical skill attainment, credential attainment, and postsecondary or employment transitions. This keeps the focus on results that matter for students’ long-term success.
  • Equity and Access: All expenditures must intentionally expand access, participation, and success for special populations. This aligns with Perkins V’s core purpose of reducing barriers and improving outcomes for underserved learners.
  • Sustainability and Capacity Building: Fund activities that build long-term program capacity, are scalable, and extend beyond one-time or short-term impact. This ensures investments continue to benefit programs after the grant period ends.
  • Governance and Accountability: All expenditures must be vetted and approved through the consortium’s governance process, include clear justification, demonstrate system alignment, and have a plan to measure effectiveness and ensure proper oversight. This creates consistency, transparency, and shared responsibility in funding decisions across the consortium.

Policy & Procedure History
Date of Implementation: 07/01/2026
Date of Last Review: 0/0/0