Budgets

On the Capital Assets Request for Approval form there is a question asking if a bid or contract has been obtained. Will a Quote serve as a bid?

Multiple quotes can be accepted as bids. Also acceptable is a statement that says they will obtain bids.


What are the Receipt and Disbursement Codes for the Perkins and reVISION grants? 

The Perkins Basic Grant and the reVISION Action Grant use the same coding.
Receipts: 4525, and Disbursements: 6700.

Keeping Perkins expenditures coded to the 6700's could benefit the district for other State calculations (when coded prior to the end of the district's fiscal year).

What are Function Codes for the Perkins Budget? 

Each code represents a function that describes the activity for which a service or material object is acquired. This coding structure distinguishes and identifies the functions and objects of expenditures.

 
  Examples are below:


03 - Expand Use of Technology (e.g., adding computers and software in Information Technology)

20 - Upgrade Equipment (not replacing, but upgrading to Industry standards)

07 - Modernize Programs (May include professional development in addition to  modernizing  equipment)

08 - CTE Course Development (expenses towards any new CTE course. May include Professional Development training.) 

Can an LEA make a payment for an item from a soon-to-expire grant, and then make the final payment from a successive grant?

No, this is not allowable. It is considered a prepayment and outside of the grant period.

Can a 3-year subscription be paid using the funds for the current grant year and have the remaining 2 years pre-paid

No. This would be obligating funds outside the grant period. 

When does the obligation period begin? 

There is a difference between Obligated and Expended. Funds must be obligated within the 12-month period.
Perkins Grant Award Notifications (GANs) have a 12-month grant period starting July 1 and ending June 30.
    The obligation period of the Grant is identified in Grant Award Period.  Obligations cannot be made prior to or after this Grant Period.  All obligations should be liquidated within 45 days after ending date of Grant. 

What are the Federal guidelines for when Perkins funds are considered obligated? 

Expenditure Type When Obligated
Equipment and Supplies Date of Purchase Order
Work of employees When the work occurred
Contracted Services Date of written agreement
Travel expenses When the travel is taken

If a Purchase Order was signed and dated prior to June 30th, the end of the grant period, can it be paid for after July 1st with those prior year’s funds? 

Yes, however the item should be received and the payment should be made in a very timely manner so that the grant does not need to be left open for an extended period of time. Perkins Grant Awards (GANs) state the following Terms and Conditions:
"The obligation period of the Grant is identified in Grant Award Period.  Obligations cannot be made prior to or after this Grant Period.  All obligations should be liquidated within 45 days after ending date of Grant.  At the completion of the grant period, a final request for funds accompanied by the final report of expenditures must be submitted to the Department with proper documentation not later than 45 days after the last day of the grant period."

Can I start expending funds once we submit our annual Perkins budget? 

No. An annual budget and application for Perkins funds must be approved by NDE before any funds can be obligated from it.

What are administrative costs and can we claim them? 

Administrative costs must be associated with the direct administration of the local application. Costs are limited to no more than 5% of total allocation. Approved indirect costs are considered administrative costs and must be included in the 5% limitation. Documentation of actual expenses must be maintained to claim the 5% administrative cost. Budget and reporting of the direct administrative expenditures should appear in the appropriate object code. 

The allowable rate should be the LEA’s or Consortium’s Approved Rate when it is LESS than the 5% maximum. (Up to 5% is the rate allowable by Perkins law.)

Examples:  If the 5% is claimed for staff time, it should be in Category 100-Salary and Category 200-Employee Benefits. You do need to record and submit time certification for reimbursement. The records must show positive time kept under the 5% cap. 

If the 5% administrative cost is directly associated with advisory committee meals or other related expenditures, it would be coded to Category 300- Professional & Technical Services or Category 400/500-Other Purchased Services depending on the type of purchases involved. 

If it is to pay mileage for the ESU staff
  travel expense reimbursement, code to
  Category 400.

What type of documentation are  needed when claiming administrative costs? 

The documentation needed depends on the expense. This documentation could be payroll records along with Time and Effort, paid invoices and receipts, contracts, etc. This is would be the same documentation you would need to support any expense where there is no additional documentation for administrative expenses.

If you are charging Indirect Costs to grants you would want to have the documentation showing how the Indirect Cost is being calculated and charged.

Can some purchases be made up front by a third-party during the grant award's timeline to be later reimbursed from the Perkins Grant funds?

No. The reimbursement requests should clearly indicate that the district or community college made those expenditures as this is to whom the grant award was issued.

It is also important that all equipment and supplies purchased with the grant funds be tagged and/or inventoried as property of the school district or community college. 

What are Direct Costs? 

Direct costs generally include:

What are Indirect Costs? 

Indirect costs represent the expenses of doing business that are not readily identified with a particular grant, contract, project or activity, but are necessary for the general operation and the conduct of activities it performs. In theory, costs like heat, light, accounting and personnel might be charged directly if little meters could record minutes in a cross-cutting manner. Practical difficulties preclude such an approach. Therefore, cost allocation plans or indirect cost rates are used to distribute those costs to benefiting revenue sources.

Documentation at the LEA should have:

Direct costs can be identified specifically with particular cost objectives such as a grant, contract, project, function or activity.


If indirect costs were claimed on any other Federal Grant in the grant year, they must also be claimed for the Perkins Grant in that same year.  

 

Perkins grant indirect costs are capped at 5%. Additionally, administration fees must be included within the 5%. Combined, this amount cannot exceed the 5% cap.  

 

The amount of capital outlay (equipment) is excluded from the total direct costs when the indirect cost rate is applied to determine the dollar amount of indirect cost to be allowed by the project. 


Our negotiated indirect cost rate changed on July 1.  Our old rate was effective through June 30th.  What is the NDE’s policy on sub-awards/contracts and a new rate?  Do I go ahead and continue to use the old rate as it was the rate in effect when the contract was awarded?  I know per the uniform guidance, indirect cost rates in effect at the time of the award are typically used through the life of the award. 

NDE views indirect cost rates to be applied to the rate in effect at the time of the direct cost.  The approved IC rate for August of the allowable direct costs for August could be charged to the grant.

It is June 15 and our Accountant already processed June payroll. Should a special payroll check be issued or can this stipend be paid in July’s payroll? What about Time and Effort reporting? 

If it is June’s time worked on a June Timesheet, you can allow it as an obligation for a payment being made in July. Time and Effort reporting would follow the same dates

What do we do with rebates, credits, or trade-in funds on equipment bought with Perkins funds? 

EDGAR §200.406   Applicable credits.  Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the Federal award as direct or indirect (F&A) costs. Examples of such transactions are: purchase discounts, rebates or allowances, recoveries or indemnities on losses, insurance refunds, and adjustments of overpayments or erroneous charges. To the extent that such credits accruing to or received by the non-Federal entity relate to allowable costs, they must be credited to the Federal award either as a cost reduction or cash refund, as appropriate. E.g., deduct the amount of the rebate from the request for reimbursement before submitting to the NDE. 

If a subrecipient wanted to purchase a capital asset, are they permitted to split that cost across different funding sources one of which is Perkins?  In other words, can they use $50,000 in Perkins funds for a piece of equipment that costs $75,000, and other funds to make up the difference? 

Yes, with proper documentation. Review 2 CFR 200.313 (Equipment) of the Uniform Guidance. When it is time for this item to be sold or disposed of, it will be important there are records of the proportional amount of Perkins funds that were used in the acquisition of the equipment. Additionally, the equipment must be used for CTE programs and services, the cost must be reasonable, necessary, and allocable to the grant. 

What is considered a Capital Asset?

Equipment costing $5000 or more per item = 700 category Capital Assets. Equipment costing $4,999 or less per item = 600 category Supplies.

* It is not permissible to purchase residential grade equipment and seek Perkins reimbursement.

How does Perkins handle depreciation of Capital Assets?

Items purchased with Perkins funds can be disposed of following the school’s own “Accounting Depreciation Procedure for Disposing of School Inventory.” The NDE does not determine the depreciation cycle for equipment, rather, it is left up to the ESU’s and district’s policies.  In most cases it means keeping track of the item in their accounting records for 5-7 years. (5 years for a Perkins federal audit.) *The key is the actual value of the equipment now, not the depreciated value.

Equipment that is no longer functional and can’t be upgraded or updated essentially has a value of “0”. Keep documentation on file that indicates the item, inventory number and explanation that it has no value and was disposed of on such and such date.

Equipment with a depreciated value of “0” can be sold, however documentation must be on file and the proceeds have to be refunded into the CTE program.

Does a “kit” that costs over $5000 need to be categorized as Capitalized Assets? 

In most cases, yes, however if an item is made of several different parts that are not dependent on each other and can be used independently on their own, then categorizing the kit can be made under 600-Supplies. 

If none of the individual items are over $5000 each, but they are all dependent on being ordered together to run the equipment that totals over $5000- then they need to be categorized as 700s-Equipment. 

Can a Perkins Consortia use Perkins funds for a portion of the cost of a piece of equipment costing over $5,000 (capital asset) and a participating District pays the other portion? 

Probably - with proper documentation and prior approval.

Equipment purchased with Perkins funds in part by a district and in part by the Consortium should follow OCTAE guidance:  Review 2 CFR 200.313 (Equipment) of the Uniform Guidance. When it is time for this item to be sold or disposed of, it will be important there are records of the proportional amount of Perkins funds that were used in the acquisition of the equipment. 

Management requirements, at a minimum, must meet the following requirements: 


Under Category 300, Professional & Technical Services, what exactly can the grant reimburse? 

This category is used for payment of Professional Development Registration and/or fees to consultants or for professional and technical services.
ESU's also use this code for payment from consortiums to schools for stipends to teachers and Substitute Teacher reimbursement as requested in the local application.

Does a Claim for Reimbursement need to be returned if an item is coded to the wrong category? 

Yes.

Does Perkins funds allow for carrying over funds from one fiscal year to the next? 

No. Perkins does not allow carry over funds for their annual grants. Obligations cannot be made prior to or after the grant period (July 1st through June 30th).

Can Districts or Postsecondary's be reimbursed sales tax on purchases? 

No. Per 2 CFR Part 200, 200.470 local governments that are tax exempt cannot be reimbursed for tax that was inadvertently paid.

Can a percentage of the consortium’s allocation be used to pay for each of its districts’ membership fees with a vendor?

Yes, however, just like any other expenditure the fee must align with the overarching CTE application and four-year plan for the consortium and is considered an allowable expense. A vendor must provide a description of exactly what the fees are for, detailed information on any personnel services charged to the grant and the item’s purpose and will these activities provided by the vendor reasonably contribute to the identified results of the comprehensive local needs assessment.