Section 9 Requirements for Local Uses of Funds

Local Uses of Funds

Requirements for Local Uses of Funds

Each consortium develops and submits an annual local application including a 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; 34 CFR Parts 75, 76, 77, and 81; and 2 CFR 200 establish the requirements for the use of funds within consortia. These guidelines may be further defined by the State and will be highlighted in the following sections.

At a minimum, consortium funds must be used only for purposes and programs mutually beneficial to all consortium members. Joint planning by the consortium members is required to develop effective programs of sufficient size, scope, and quality. Furthermore, a consortium is prohibited 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, not on a preset percentage of funds basis.

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; A Hyslop; Association for Career and Technical Education).

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 established size, scope, and quality definitions for consortia to determine which Programs of Study to prioritize funding.

Size

Parameters and/or resources that affect whether the Program of Study can adequately address student learning outcomes; this includes:

  • Number of students within a Program of Study
  • Number of instructors/staff involved with the Program of Study
  • Number of courses within a Program of Study
  • Available resources for the Program of Study (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 of Study connect with secondary CTE via articulation agreements and/or dual credit, etc.
  • Programs of Study develop not only specific work-based skills, but also broadly applicable employability skills

Quality

  • A Program of Study 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 of Study 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

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 allowed.

Direct Individual Benefit

2 CFR 200.403 states that all costs must be necessary, reasonable, and allocable. A cost that primarily benefits an individual typically fails the allocability and reasonableness tests. An expenditure is typically considered unallocable and therefore, unallowable under Uniform Guidance if it is:

  • Limited to one person;
  • Not required for program participation, or
  • Not available to similarly situation participants

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. To be allowable, 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.

Districts and colleges should carefully evaluate whether a proposed cost creates equitable access and program-wide impact. If an expense appears to benefit individuals, the applicant must demonstrate that the benefit is incidental to a larger program purpose and available to all similarly situated participants. When this cannot be clearly justified, the cost should not be included in the Perkins budget. Seek state guidance prior to approval to ensure compliance with federal Uniform Guidance requirements.

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. Perkins V requires that all local uses of funds are clearly aligned to the Comprehensive Local Needs Assessment (CLNA), the approved local application, and current industry standards. 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 Career and Technical Education (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 considered weak and may not meet federal allowability requirements.

Local recipients are responsible for ensuring that all expenditures support the size, scope, and quality of CTE programs as outlined in their approved local plan. Funded items should be used regularly and meaningfully within the program and accessible to students enrolled in the pathway, rather than serving a limited or unclear purpose. Costs that lack alignment to identified needs, are not supported by the CLNA, or do not advance program priorities may be unallowable. Strong justification must demonstrate how the investment improves program quality, expands access, or enhances student outcomes in alignment with local and regional workforce needs.

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 Funding Programs of Study (programs of study in development). 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). All proposed costs must also meet federal Uniform Guidance (2 CFR 200.403) requirements, including being necessary, reasonable, allocable, and properly documented.

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

  • CLNA Alignment is Required: Every expenditure must clearly align to identified needs in the CLNA and priorities in the approved local plan; if it is not documented, it should not be funded. This ensures funds are driven by data 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 directly strengthen the size, scope, and quality of Programs of Study and align to consortium-defined priorities. This keeps funding 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 maintains compliance with federal requirements and preserves the intent of Perkins as an enhancement 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 Drive Decisions: 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