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

To expend their allocated basic and reserve funds, each consortium develops and submits a biennial application 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. The following discussion is meant to give guidance to consortia in decision-making.

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 that are mutually beneficial to all members of the consortium. This presupposes joint planning by the consortium members resulting in programs that are of sufficient size, scope, and quality to be effective. 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.

When utilizing Perkins funding expenditures (see Section 135) in the local plan, these expectations must be met:

1. The funding is for the purpose of development, implementation, refinement or support of an approved CTE program or program of study.
2. Funding is allocable according to the Perkins V Act.
3. There is no You cannot use federal funds to pay for services, staff, programs or materials that would otherwise be paid for with state or local funds. In other words, the expenditure was not previously funded with local funding.

4. The expenditure is reasonable and necessary for the plan’s execution.

Supplement versus supplant is a frequent question. 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.

Funds available to consortia under Section 135 of Perkins V 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

Refer to Perkins V Section 135 for a complete description of requirements for uses of funds at the local level.

Algorithm for Making Local Funding Decisions

When determining whether or not the use of federal Perkins V Grant funds is appropriate, local consortium leadership should consider the following questions:

• Does this use of funds constitute “supplanting” of other funding sources? For example, if an individual’s salary was funded through state funds previously, federal Perkins V funding cannot be used to fund the salary now or in the future unless the job duties have changed and have been documented in a revised position. The position description must specify which duties are funded with Perkins Grant funds and what percentage of the overall duties are funded by federal Perkins Grant funds.
• Is the expense reasonable? Does it meet the intent of size, scope, and quality as specified in the Perkins V law and in the Minnesota 4-Year State Plan?
• Is the expense necessary? For example, what are the consequences if Perkins funds are not used?
• Is the expense allocable? For example, does the expenditure comply with the uses of funds specified in Section 135(b) of Perkins V and with the Education Department General Administrative Regulations (EDGAR)? Be prepared to identify and describe the following specific considerations as they apply to the expenditure:
  • Which Perkins V use of funds under Section 135(b) is being addressed?
  • How does the expenditure support the consortium’s programs of study?
  • How does the expenditure support the recruitment, retention, and training of CTE professionals?
  • How does the expenditure support special populations as identified in Perkins V?
• 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?

Refer to Appendix E, "General Guidance for Perkins V Local Use of Funds." for additional guidance.

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 ....” The Perkins V Act does not define size, scope and quality, but instead 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
• 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

Specific Fund Usage Guidelines

Support Services (Nontraditional by Gender)
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.

OCTAE has provided the following guidelines:

• 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
• Child care and transportation may be provided, but not by direct payments to CTE 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)

• Perkins funds may not be used for car parts and/or maintenance

Personnel
Colleges may not use Perkins V resources to fund instruction within non-credit or customized training courses. Personnel may be funded via the college’s 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 college’s 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 are funded via the Perkins Grant

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 for which they were compensated through federal grant funds. These are often 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 to the position description for the individual. Time and effort reports must be a single, certified document that reflect 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)

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 will need to ensure that any third year of funding for positions still aligns directly to the priorities identified. Documentation must be retained to support personnel-related costs. Timesheets are considered a best practice for time and effort reporting, also known as personnel activity reports. If electronic time sheets do not allow 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)

Postsecondary Perkins 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, or an 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.

Field Trips and Student Transport Activities
Field trips and student transportation activities that are in direct support of 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. This funding may not be used for support of individual classes at the middle-school level.

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

Career and Technical Student Organization (CTSO) Activities

• Individual student lodging and meals do not qualify as a permissible Perkins expenditure
• Advisor travel, lodging and meals must include staff- development activities for licensed CTE staff (Perkins funds are not allowable for chaperones only)
• All Perkins funding recipients must be licensed CTE teachers/administrators or counselors
• Perkins funding can be used for the purchase of branded organizational materials as long as those materials remain the property of the program and are not distributed to individual students upon program completion
• 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)
  
  

Career Development License and Activities
Specific 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.

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 for the proper and efficient performance of the eligible fiscal and data collection responsibilities under the Perkins V Act.

WorkForce (CareerForce) Center Collaboration Expenditures
Postsecondary CTE programs, assisted under the Perkins V Act, are mandatory partners in the one-stop career center delivery system established by the CareerForce Centers and continued in the current WIOA legislation. Colleges are encouraged to collaborate with their one-stop partners. However, as specified in the local application, colleges must report all direct and indirect resources that were used in collaborative efforts with CareerForce Centers each fiscal year.

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. 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.

Capital Assets (Equipment)

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 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 number.
   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

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.