Section 9 - Uses of Perkins Funds

This section describes the allowable uses of Perkins funds by consortia. Perkins is dedicated to increasing learner access to high-quality CTE programs of study. With a focus on systems alignment and program improvement, this funding is critical to ensuring that programs are prepared to meet the ever-changing needs of learners and employers.

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:

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.

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).

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."

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.

Size, Scope, and Quality

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

Consumables

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.

Direct Individual Benefit

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.

Capital Improvement

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.

Weak or Absent Connections

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.

Overarching Considerations and Key Questions

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?

Specific Fund Usage Guidelines

Disclaimer: This information is intended to assist consortia leaders when making funding decisions. Other uses of funds not listed here may be determined to be unallowable upon further research of federal documentation or consultation with state leadership. In some instances, state leadership must confer with our federal consultants at the Office of Career, Technical, and Adult Education (OCTAE).

Source Documents: Strengthening Career and Technical Education for the 21^st Century Act of 2018 and The Administrator's Handbook on EDGAR, 4^th Edition.

UNALLOWABLE USES OF FUNDS

• Alcoholic beverages

• Alumni/ae activities
• Career and Technical Education instruction in approved postsecondary programs, shops, labs, and internships.
• Capital assets (non-instructional equipment, building, land, and expenditures to make improvements to capital assets)
• Child Care
• Commencement and convocation costs
• Construction, renovation, and/or remodeling of facilities
• Contributions and donations (cash, property, services)
• Entertainment, amusement, and social activities (food may be viewed as entertainment)
• Expenditures for career education/exploration prior to the fifth grade
• Expenditures for non-approved CTE programs (may require consultation with state staff)
• Expenditures that supplant
• Fines and penalties
• Food (There is a high burden of proof to show that food is "necessary." Follow federal, MDE and/or Minnesota State guidelines.)

• Fundraising
• Gifts
• Goods or services for personal/individual use
• Insurance
• Interest
• Items retained by students (supplies, clothing, calculators, etc.)
• Monetary awards
• Non-instructional furniture
• Political activities such as contributions, fundraising, or lobbying
• Postsecondary customized training courses and programs
• Promotional materials (T-shirts, pens, cups, keychains, book bags, etc.)
• Remedial/developmental courses - both secondary and postsecondary
• Scholarships
• Student expenses/direct assistance to students (tuition, tools, fees, car mileage, etc.)
• Student stipends
• Vehicles, unless used directly for CTE instruction (Purchasing vehicles requires consultation with state staff)

Uses of Funds Examples

The table below provides explanations and examples for requests that have been the subject of inquiry in recent years. Please keep in mind that Perkins funding is not designed to fully support the local CTE program(s), but rather a complement and supplement to local resources. Some items labeled as unallowable may be supported through other funding sources, such as the CTE levy, general education funding, leveraged equipment funds, or disability services. Purchases intended for program use will be ordered in a timely manner to be used during the grant/academic learning year (i.e., items for use in fall courses should be ordered and received in a timely manner for fall; items for use in spring courses should be ordered and received in a timely manner for spring).

Item: Career and Technical Education Organizations (CTSO) and Clubs

Description/Explanation: Career and Technical Student Organizations means an organization for individuals enrolled in a career and technical education program that engages in career and technical education activities as an integral part of the instructional program. The CTSO's in Minnesota are: Business Professionals of America (BPA), DECA, Family, Career and Community Leaders of America (FCCLA), FFA, Health Occupations Students of America (HOSA), and SkillsUSA.

There are limited allowable expenses for clubs (e.g., Vex, Robotics, Supermileage) that provide intra-curricular leadership experiences to CTE students similar to state-recognized CTSO's.

Unallowable Expenses:

• Individual Student membership in CTSO chapters or clubs
• Program affiliation fees for local CTSO chapters (may be possible, but requires consultation with state staff)
• If non-CTE students also participate in the club outside of a CTE course, Perkins funding may not be used to support the club
• Individual student lodging and meals do not qualify as a permissible Perkins expenditure

Allowable Expenses:

• All members of the student organization or class/ program must have an opportunity to participate in the funded activity (This opportunity may reflect qualifying competitive performance or participation)
• Transportation for events/ excursions tied directly to CTE coursework and CTSO or club advisor travel costs if professional development opportunities are available
• All Perkins funding recipients must be licensed CTE teachers/administrators or counselors
• Advisor travel, lodging, and meals must include staff-development activities for licensed CTE staff (Perkins funds are not allowable for chaperones only)
• Perkins funding can be used for the purchase of branded organizational materials as long as those materials remain the property of the program and not distributed to individual students upon program completion

Item: Field Trips and Student Transport Activities

Description/Explanation: Additional pre-approval is not required if the field trips/activities are listed, budgeted, and approved as part of the annual Perkins consortium grant application. Field trips and student transportation activities not listed in the original approved application must be pre-approved if the cost of the activity exceeds the $1,000 threshold.

Unallowable Expenses: Funding may not be used to support individual classes at the middle-school level.

Allowable Expenses: Field trips and student transportation activities directly supporting CTE students and programs are allowable under the Perkins Grant funding. This can include middle school career-awareness activities that support CTE program enrollment at the high school level.

Item: Computers, tablets, and mobile devices

Description/Explanation: Computers, tablets, and mobile devices seldom relate to specific industry skills. These devices may have previously been considered innovative; however, given the standard nature of this equipment across many content areas, the hardware itself is no longer considered innovative. The district or college should typically purchase these hardware items. Using Perkins funds could be considered supplanting.

Unallowable Expenses: 

• Standard-issue computers or mobile devices
• Hardware primarily used for teacher and student instructional tasks (i.e., laptops, projectors, SmartBoards) and not tied to industry-standard competencies to be learned by CTE students
• See Supplanting section
• See Weak or Absent Connections section

Allowable Expenses:

• Industry-grade computers with increased processing speeds or processing that is not the standard equipment typically purchased by the district or college.
• New applications or software used on iPads

Item: Concurrent Enrollment Fees

Description/Explanation: Costs associated with the delivery/participation in concurrent enrollment postsecondary opportunities

Unallowable Expenses:

• Payment of individual Tuition/Course Credit
• See Supplanting section
• See Direct Individual Benefit section

Allowable Expenses:

• Start-up costs for new concurrent enrollment instructional materials (ongoing costs are not allowable)
• Professional development intended to build the capacity of teachers offering concurrent enrollment
• In certain situations, fees for individuals of special populations (requires consultation with state staff)

Item: Electronic Instructional Materials

Description/Explanation: Curricula that supplements instruction and allows students to gain knowledge and skills that meet industry standards and expectations in high-wage, high-skill, or in-demand occupations.

Unallowable Expenses: 

• Licensure agreements that provide curriculum access to students not enrolled in CTE programs
• Online subscriptions with a per-person user agreement
• Curriculum only loosely aligned to career exploration or preparation
• See Weak or Absent Connections section

Allowable Expenses: 

• Online CTE simulations
• Purchased curricular components that are supplemental to the full program offering
• Online curricula available via a site or lab license or limited access date rather than per person user agreement

Item: Career Development Software License and Activities - Secondary

Description/Explanation: Specific software licenses for career development activities (i.e., Minnesota Career Information System, Naviance, etc.) do not require additional permission if they are currently reflected in the local Perkins application budget approved by MDE.

Pre-approval is not required for these expenditures; however, if they require a budget modification or change, this must be approved through the budget maintenance system.

Item: Equipment that is used in a program to generate profit

Description/Explanation: Perkins funds cannot be used to acquire equipment in which the acquisition results in a direct financial benefit. If the equipment is purchased with federal funds and then used to sell products or services, the generated revenue must be returned directly to the program. Generally accepted accounting practices and documentation must be in place to show the funds were invested in the program. There is a robust burden of proof documenting the reinvestment of any profit.

Unallowable Expenses: 

• Equipment used to fundraise for Career and Technical Student Organization activities or programs
• Equipment has a weak connection to the skills taught within the course
• See Weak or Absent Connections section

Allowable Expenses: 

• Equipment is connected directly to the skills taught within the course
• All generated revenue is re-invested into the program; no students or school district personnel receive a direct financial benefit

Item: Food: Meals/ Working Lunches

Description/Explanation: The federal grant has marked meals as allowable with a high threshold or burden of proof to show that food is necessary and requires a working meeting. Perkins funds may not be spent on food except in very limited circumstances and must be pre-approved.

Unallowable Expenses: 

• Banquets, award ceremonies, goodwill gestures, etc.
• Payments for student meals during a regular school day is the responsibility of the school district

Allowable Expenses:

Food and meal expenses are allowed in limited situations and must be pre-approved. To be approved, expenses must meet the following criteria:

• The event is undertaken to further the goals of the Perkins grant
• All food costs are documented in the consortia budget in a manner that makes it easy for a third party to determine how the costs benefited the project
• Food is an integral part of the event and necessary to sustain the flow of the meeting
• The portion of the agenda to held during lunch moves beyond networking and includes substantive and integral content connected to the overall purpose of the conference or meeting
• Meeting is more than four hours (not including the meal period)
• Breaking for lunch would extend the meeting time and cause most participants to incur additional travel and hotel expenses
• A formal agenda and meeting roster is documented and available upon request

Item: Furniture and Storage

Description/Explanation: Tangible supplies purchased by the district or college, such as desks, chairs, tables, mobile carts, storage bin cabinets, toolboxes, shelving, and external USB storage, are generally supported with local funds for non-CTE purposes and, therefore, considered supplanting.

Unallowable Expenses:

• Storage bins, cabinets, shelving, mobile carts
• USB storage, removable storage
• Furniture such as desks, chairs, and tables

Allowable Expenses

• If items are specific to a CTE area, i.e., stainless steel prep tables for culinary classes, drafting tables for architecture and construction, cosmetology chair, or diagnostic cart for Health Science program, and not able to be used in general classes, they may be funded by Perkins.
• In specific situations, a cart may be allowable if it is used for the purpose of moving a specific tool from one workstation to another and matches industry usage.

Item: Industry-grade equipment and tools [Note: Must have a per-item value of $100 or more]

Description/Explanation: Perkins funding supports instruction which equips students with career skills in preparation for high skill, high wage, or in-demand careers. Items that are not the industry standard in the workplace are not allowable.

The minimum cost is to ensure innovation and improvement rather than maintenance cost.

Unallowable Expenses: 

• Basic, residential grade, educational version, and/or hobby grade tools and equipment
• Multiple purchases of an identical item in order to circumvent the $1,000 or $5,000 threshold for equipment requests

Allowable Expenses:

• Secondary equipment purchases greater than $1,000 must also go through Minnesota Department of Education (MDE) approval process
• Postsecondary equipment purchases greater than $5,000 must go through Minnesota State approval process

Item: Memberships

Description/Explanation: Memberships to professional organizations that provide a benefit to the consortium membership and provide a direct individual benefit to staff and students. Additionally, many membership organizations actively lobby elected officials on behalf of CTE. 
Unallowable Expenses: 

• Dues and memberships to professional organizations for individuals, even when included in registration fees.
• Entrance fees, food, or individual student costs may not be funded for any student travel or activity.
• May not be used for memberships in civic or community organizations (i.e., chamber of commerce, Lions club, etc).
• See Direct Individual Benefit section

Allowable Expenses: Organizational membership granted to the agency, district, or college that provides a benefit to the consortium rather than a specific entity.

Item: Middle School Career Exploration

Description/Explanation: Section 135 of the Act states local uses of funds shall be used to "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 career and technical education program, in making informed plans and decisions about future education and career opportunities…"

Unallowable Expenses:

• Activities or equipment for students below grade five
• Activities or equipment focused on a single career field
• Activities or equipment intended for the development of life skills
• See Weak or Absent Connections section

Allowable Expenses:

• Activities or equipment intended for broad career exploration across all career fields
• Professional development related to career exploration and CTE for school counselors serving middle school students
• Activities or equipment intended for development of career-related skills 

Item: Removing barriers to access for a member of a special population

Description/Explanation: Supports that reduce or eliminate barriers to participation in CTE programs and activities. This may include areas such as transportation, targeted programs for preparation or retention, mobility, child care, or cost of associated fees.

Unallowable Expenses: Direct assistance to a student not identified as a member of a special population or gender nontraditional is not permissible.

Allowable Expenses:

• Assistance may only be provided to an individual to the extent needed to address barriers to the individual's successful participation in CTE programs.
• Consultation with state staff is needed.

Item: Technical Skill Attainment (TSA) Exams or Industry Recognized Credentials

Description/Explanation: TSA exams and industry-recognized credentials allow students to demonstrate mastery of knowledge and skills within a specific course and provide data for curriculum improvements for a program or program of study. 

Unallowable Expenses: Exam or credential only completed by select students within an approved program or course.

Allowable Expenses: Exam or credential is required for all students enrolled in a CTE course within an approved program. Instructors should utilize results for data-driven decision-making and continuous program improvement.

Item: Textbooks (printed or digital)

Description/Explanation: School districts regularly purchase textbooks for other content areas in the district. As such, using Perkins funding to purchase textbooks for CTE courses would be an example of supplanting local funds. Additionally, textbooks can become out-of-date shortly after they are printed, particularly in quickly changing fields, and are thus not an innovative classroom tool. 

Unallowable Expenses: 

• Classroom sets of textbooks (including digital) intended to update or replace current textbooks
• See Supplanting section

Allowable Expenses:

• New program or course offered for early college credit and aligned to an in-demand occupation identified in an approved application or statewide Perkins priority.
• In specific situations, a limited number of textbooks may be purchased for individuals of special populations (requires consultation with state staff)

Item: Unmanned aerial vehicle or unscrewed aerial vehicle, commonly known as a drone

Description/Explanation: Use of drone technology is standard for the industry for which the requesting program prepares students.

Aerial vehicles/drones must be registered with the FAA, and the instructor must hold the appropriate FAA license. If the instructor under whose name the drone is registered leaves the district or consortium, then the district or consortium is responsible for ensuring that registration is transferred to an individual providing instruction in the CTE classroom and licensed.

Unallowable Expenses: If aerial vehicles/drones are purchased for non-CTE classroom instruction or other uses using district funds, Perkins may not support similar drones in the CTE classroom.

Allowable Expenses: Used solely for CTE instructional purposes and aligned with curriculum

Item: Support Services (Nontraditional by Gender)

Description/Explanation: If a college or school district determines a need to fund support services for nontraditional (by gender) students, they must develop local guidelines within state and federal laws to provide assistance with dependent care, transportation services, special services, supplies, books, and materials for nontraditional students in CTE-approved programs and/or services.

Unallowable Expenses: 

• Perkins funds cannot be provided to individual students for the purchase of tools, uniforms, equipment, or materials
• Perkins funds cannot be used for student stipends or tuition
• Perkins funds may not be used for car parts and/or maintenance

Allowable Expenses:

• Child care and transportation may be provided, but not by direct payments to CTE students. Colleges shall establish procedures for payments to vendors for child care and transportation costs
• Costs for public transportation or rates consistent with the cost of public transportation may be allowed only to provide transportation for students to attend a CTE-approved education activity. In areas where public transportation is not appropriate/available, colleges shall develop equitable options for students by providing vouchers or purchase orders.
  
  

Personnel Compensation

Personnel may be funded via the Perkins Grant in the following cases:

• Personnel are providing services to special populations (as defined by the Perkins V Act), and/or
• Personnel are assigned to other functions and/or projects designed to improve CTE as specified in the currently approved Perkins local application.

In all cases, the following conditions must be met:

• Job descriptions are written and kept on file at the time of employment for each individual
• Time and effort reports are completed and filed for each employee
• Perkins funds are not supplanting state funds or other federal grants
• Only that portion of a person's time assigned to Perkins-related functions and/or activities is funded via the Perkins Grant
• Colleges may not use Perkins V resources to fund instruction within non-credit or customized training courses.

As with any expense, personnel-related costs must directly link to the needs assessment process and the overall priorities outlined in the local application. Personnel paid with Perkins Grant funds should not, except in unique circumstances, be funded by the grant for more than three fiscal years, whether funded in whole or in part. Because the needs assessment must be updated every two years, local recipients must ensure that any third year of funding for positions still aligns directly with the priorities identified. Documentation must be retained to support personnel-related costs. Timesheets are considered a best practice for time and effort reporting. If electronic time sheets do not allow a narrative of duties, other documentation is needed. Perkins coordinator positions are subject to the time and effort reporting requirement if the position is paid in full, in part, or is part of the administrative match for the grant. Coordinator positions are not subject to the three-year review. (2 CFR Subpart E §200.430)

Personnel Activity Reports (PAR)

Personnel who are compensated in whole or in part with federal grant dollars are required to report on their duties/activities funded under the grant. This time and effort reporting reflects how teachers, faculty, and/or staff spent the time compensated by federal grant funds. These documents are referred to as Personnel Activity Reports (PAR).

The purpose of federally mandated time and effort reporting is to provide documentation to substantiate payroll charges. For example, if 25 percent of an individual's time was charged to a federal grant, time and effort reports must substantiate that the individual spent at least 25 percent of their time working on activities to support the goals of that federal grant. This should also align with the position description for the individual. Time and effort reports must be a single, certified document that reflects 100 percent of an employee's time worked in a given period for:

• Each specific federal grant program
• Cost sharing, matching funds, or leveraged funds required for the federal grants
• All other activities not funded by a grant for which the individual is compensated (both grant and non-grant time is documented)

Perkins Eligible Programs as Funding POS or POS in Development

Perkins V funding can only be utilized for funding POS identified as part of the application. POS underdevelopment can use funding for content/curriculum development, not to purchase equipment, classroom resources (textbooks), etc.

Postsecondary Approved Programs

Postsecondary, credit-based programs: Perkins V resources may only be used by colleges for program expenditures relating to students pursuing an approved program as identified in the Minnesota State System Office program inventory database.

The student must be pursuing a program that is identified by a CIP code in one of the 16 career clusters designated as "Perkins eligible." To be eligible, the program must, among other requirements, terminate in a certificate, diploma, associate of applied science (AAS), or associate of science (AS) degree.

Postsecondary Customized Training Courses and Programs: Perkins V resources may not be used by colleges for program expenditures related to students pursuing non-credit courses and programs within customized training or employer-sponsored training programs. For example: Perkins funds may not be used for costs related to providing customized training for ABC Corporation.

Secondary Approved Programs

Perkins V resources may only be used by districts for program expenditures relating to students participating in an MDE CTE-approved program, as identified on Table C.

Administrative Cost Allowances

Perkins V allows eligible consortia to use up to, but not more than, five percent of their Perkins allocation for administrative costs. The five percent administrative allowance must be accounted for separately within the consortium's basic and reserve funds. For example, when developing the consortium budget, a maximum of 5% of basic funds and 5% of reserve funds must be indicated as separate line items in the budget. Administration is defined as activities necessary to properly and efficiently perform the eligible fiscal and data collection responsibilities under the Perkins V Act.

Fiscal Year Expenditure Timelines

Local consortia are responsible for prudent cash management. Greater than 50 percent of the funds should be spent by the 3rd quarter of the fiscal year. A review of cash management should be an agenda item at every consortium leadership meeting.

Perkins V does not allow colleges or school districts to carry over unexpended funds from one fiscal year to the next. All expenditure orders must be encumbered and items received by June 30th. Attempts should be made to pay all invoices by June 30th. Late payments must be coordinated with the Minnesota State System Office grants accountant or MDE fiscal personnel.

Equipment (Capital Assets)

This section describes purchases, inventory controls, and proper disposal of secondary and postsecondary equipment acquired with federal funds.

Equipment purchases must be permissible according to Perkins V, Section 135(b). Consortia must also follow policies set forth by Minnesota State Board policy 7.3.6 for postsecondary and MDE UFARS policy Chapter 5, section 500 for secondary. Allowable use, disposition, and record-keeping requirements as defined by the Education Department General Administrative Regulations (EDGAR) must be followed.

In accordance with § 34 CFR 74.34, the recipient's (consortium's) property management standards for equipment acquired with federal funds and federally-owned equipment shall include all of the following:

1. Equipment records shall be maintained accurately and shall include the following information:

1. A description of the equipment.
2. Manufacturer's serial number, model number, federal stock number, national stock number, or other identification numbers
3. Source of the equipment, including the award number.
4. Whether title vests in the recipient or the Federal Government.
5. Acquisition date (or date received, if the equipment was furnished by the Federal Government) and cost.
6. Information from which one can calculate the percentage of federal participation in the cost of the equipment (not applicable to equipment furnished by the Federal Government).
7. Location and condition of the equipment and the date the information was reported.
8. Unit acquisition cost.
9. Ultimate disposition data, including date of disposal and sales price or the method used to determine current fair market value where a recipient compensates ED for its share.

2. Equipment owned by the Federal Government must be identified to indicate federal ownership.

3. A physical inventory of equipment must be taken, and the results reconciled with the equipment records at least once every two years. Any differences between quantities determined by the physical inspection and those shown in the accounting records must be investigated to determine the causes of the difference. The recipient shall, in connection with the inventory, verify the existence, current utilization, and continued need for the equipment.

4. A control system must be in effect to ensure adequate safeguards to prevent loss, damage, or theft of the equipment. Any loss, damage, or theft of equipment shall be investigated and fully documented; if the equipment was owned by the Federal Government, the recipient shall promptly notify the Secretary.

5. Adequate maintenance procedures must be implemented to keep the equipment in good condition.

6. Where the recipient is authorized or required to sell the equipment, proper sales procedures must be established which provide for competition to the extent practicable and result in the highest possible return.

Combined Consortium Equipment Inventory and Asset Tags

The consortium maintains a combined inventory of equipment purchased with federal Perkins funds, validated/reconciled at least every two years. All equipment purchased with federal dollars must have specially marked asset tags.

• A single consolidated inventory of secondary and postsecondary equipment is on file.
  • Records for each item may include:
    • Date of purchase
    • School/teacher/program for which purchase was made
    • Item description
    • Cost
    • Current location

• A process is in place to inventory and label equipment as property of Perkins CTE. Asset labels should identify the Perkins Federal Grant as the source of funding. Add other relevant details deemed necessary. This asset tag example was provided by the Saint Paul Perkins Consortium:
  
  
• A process is in place to update inventory if equipment is reassigned or disposed of.
• Equipment purchases have been pre-approved per MDE and Minnesota State requirements. See the Postsecondary Equipment and Secondary Equipment sections below for more information.

Postsecondary Equipment

Documentation of equipment must comply with federal requirements, Minnesota State Colleges and Universities Board policy, and institutional policies.

• Minnesota State's policy requires purchases of $10,000 or more to be recorded as equipment; however, the federal government requires purchases for $5,000 or more to be recorded as equipment.
• Institutional policies determine sensitive equipment guidelines
• Equipment and capital assets are recorded and maintained in the equipment module within Minnesota State's ISRS program.
• Equipment of $10,000 or more is to be expensed with object code 4000 (equipment)
• Equipment purchased between $5,000.00 and $9,999.99 is to be expensed with object code 3006 (sensitive equipment)
• Equipment under $5,000, and determined to be classified as sensitive (e.g. computer equipment) is to be expensed with object code 3006
• Designate a unique department number in the equipment module to record equipment purchased with Perkins Grant funds
• All equipment purchased with federal dollars must have specially marked asset tags. See the Combined Consortium Inventory and Asset Tags section above for more information.
• Equipment purchased with federal funds requires a physical inventory at least every two years, with proof of the inventory process
• Record physical inventory date in the equipment module
• Perform equipment reconciliation at least annually, or more often, as determined by System Office recommendation and requirements
  • Run a report filtered by object codes 4000 and 3006 and FPK appropriation
  • Run equipment module report, filtered by the designated department number
  • Compare to ensure all equipment purchased with Perkins Grant funds are listed in the equipment module with the unique department code
  • Run fixed asset reconciliation equipment module report

Secondary Equipment and Curriculum

Information in this section is taken from MDE’s Perkins V Legislation webpage.

For UFARS reporting, equipment or technology qualifies as a capital expenditure if the item meets all of the following criteria:

1. It retains its original shape and appearance with use. It has a normal useful life extending beyond a single reporting period.
2. It is nonexpendable, that is, if the article is damaged or some of its parts are lost or worn out, it is usually more feasible to repair it rather than replace it with an entirely new unit.
3. It does not lose its identity through incorporation into a different or more complex unit or substance.

A more complete description may be found in Chapter 5 of the 2020 UFARS Manual.

The three components of the above definition of equipment must be followed by independent school districts throughout Minnesota. District policy may add additional components to the equipment definition, but all school district policies must support the three criteria listed above.

Criteria for Secondary Perkins Funded Purchases

• Classroom/lab equipment and curriculum/licensure funded through Perkins must be used to support courses within a state-approved CTE program
• The CTE course must be taught by a CTE-licensed teacher holding a current CTE license in that discipline (unless special permission has been granted)
• All Perkins-funding recipients must be licensed CTE teachers/administrators or counselors (unless special permission has been granted)
• All Perkins-funded purchases must support CTE students
• Perkins funding must not be used to supplant existing (non-federal) funding sources
• Equipment purchased through the Perkins Grant must have the priority of use dedicated to CTE students — however, incidental use by CTE-related students is allowable
• Funding for classroom/lab equipment and curriculum/ licensure may come from multiple sources (Perkins Grant used for any portion of this funding requires adherence to the above criteria)

Requirements for State Pre-Approval

Secondary equipment and curriculum purchases that equal $1,000 or more require pre-approval before the consortium authorizes the district to make the expenditure from Perkins Grant funds.

To obtain MDE pre-approval of these purchase requests, consortium leaders should complete and electronically submit the equipment request form found on MDE’s Perkins V Legislation webpage. 

MDE approval of the annual Perkins consortium application establishes a fiduciary relationship between the Perkins consortium and MDE. Because of this relationship, all secondary equipment approval requests must be submitted from and granted to the secondary Perkins consortium coordinator of record.

All equipment and curriculum items purchased with Perkins funding must be identified (tagged) and included in the building inventory of the school district where it is located. See the Combined Consortium Inventory and Asset Tags section above for more information.

Inventory Control Requirements

The responsibility for maintaining inventory control of secondary equipment and curriculum purchased with Perkins funding remains with the Perkins consortium. Consortia are requested to have a single consolidated inventory which is validated/reconciled at least every two years. All secondary equipment and curriculum purchased, inclusive of those under the $1,000 threshold, must be included in the Perkins consortium's equipment inventory list.

Inventory control records should include the following:

• Equipment/curriculum description (serial numbers, model numbers, physical description, etc. as applicable)
• Date of acquisition
• Original expenditure/percent of grant funding
• Source of equipment/curriculum
• Location and condition of equipment/curriculum (school building, room location, CTE-approved program(s)
• Space for inventory record; Perkins equipment/curriculum inventory is required every two years (Inventory procedures may follow school district policy)
• Corresponding physical tag number when applicable
• Space for final disposition of equipment
• When possible, a physical tag should be permanently fastened to, or stamped on, each item of equipment/ curriculum indicating Perkins funded expenditure. This tag must be identifiable to the inventory record

Perkins Funding for Curriculum Software/License

• Acquisition and disposal of curriculum software/licenses follow the same guidelines as stated above for equipment
• Perkins funding is not a sustainable long-term funding source for secondary initiatives (Consequently, license and curriculum program funding are restricted to one or two years of support)
• Inventory control must be maintained in the same manner that was recommended for equipment

Equipment Disposal

Equipment that has been purchased with federal funds as part of a consortium’s Perkins plan should be disposed of using the following Postsecondary and Secondary Disposal procedures.

Postsecondary Disposal

Follow the college’s equipment disposition procedure based on the Minnesota State policy 7.3.6, Part 9(3), stating, When equipment purchased with Federal funds with a current per unit fair market value in excess of $5,000, is no longer needed for a Federal program, it may be retained or sold with the Federal agency having a right to a proportionate amount of the current fair market value. Before selling the equipment, consider donating it to another CTE program at the secondary or postsecondary level.

Document equipment disposed of in the combined consortium inventory, including date and disposal method.

Secondary Disposal

Secondary equipment should be disposed of by using the following procedure:

1. All equipment/curricula purchased through the Perkins consortium must be disposed of through the original assigning consortium.
2. The original assigning consortium whose school districts are disposing of equipment with a current value of $5,000 or more must coordinate disposal with MDE and the United States Department of Education using general administrative regulations guidelines (34 C.F.R. 80.32(c)).
3. Disposal of equipment that has a current value of $1,000 or more, but less than $5,000 must be coordinated with MDE. The original assigning consortium must provide to MDE a list of said equipment to allow support for repurposing this equipment to another consortium.
4. Equipment that has a current value of less than $1,000 may be disposed of through the local Perkins consortium. (See note below.)
5. All disposition of equipment must be reported on the annual CAR. The respective consortium inventory must reflect the disposal.
6. Equipment disposal records including inventory documentation, disposal, salvage recovery funds and any transfer information need to be retained by the consortium for three years.

Note: Before equipment is disposed of, the consortium must make an effort to repurpose the equipment to support a CTE program in another member district. Technical support for these efforts will be available through MDE.