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 21st Century Act of 2018 and The Administrator's Handbook on EDGAR, 4th Edition.
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 V funding can only be utilized for funding POS identified as part of the application. POS under development can use funding for content/curriculum development, not to purchase equipment, classroom resources (textbooks), etc.
Postsecondary Approved Programs
- 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.
- 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.
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.
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.
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).
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
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.
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
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)
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
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.
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
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
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.
[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
- 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
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.
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
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.
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.
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)
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
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.
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)