Grant Management

Can NDE reject my application based on my answers to the questions in GEPA  (General Education Provisions Act)

Yes. Applications may not be approved until the NDE's progam office is satisfied that no barriers to equitable access or participation exist. This determination is based on the written answers to each question. 

When can Perkins funds be used? 

After approval of the application, Perkins funds may be obligated and expended after the issuance of the Grant Award Notification. Even though a GAN is dated July 1, grant applicants cannot legally expend funds until the grants are approved. Competitive Grants over $50,000 (reVISION) are approved at the State Board meetings and in effect on the date the Board approves. Funds expended before the grant was approved would trigger an audit issue.

Prior to October 1st, only 25% of awarded funds are eligible for obligating or expending. After October 1st (beginning of Federal fiscal year), the full grant award is eligible for obligating or expending.

Allocability: Must the goods and services purchased be placed in use by June 30? 

In order for a cost to be allowable, it must be allocable. A cost is allocable if it benefits the cost objective. Although the benefit should be documented in the 12-month window, Perkins is a “continuous” program.

Examples:

• Installing equipment in a lab in June, although students might not benefit until September.

• Purchasing curricula/software/textbooks which benefit CTE students in future years, as well as the current year. 

If an item was ordered and grant funds were obligated within the grant year, but because of back-order issues, it was paid for after the grant year ended. Can NDE reimburse the district? 

As long as the item was obligated prior to the end of the grant period and then was paid before the end of the liquidation period (45 days). The expense is then allowable and can be reimbursed. In the Grant Award Notification (GAN) the Terms and Conditions of the Award state: Obligations cannot be made prior to or after this Grant Period.  All obligations should be liquidated within 45 days after the 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 NDE with proper documentation not later than 45 days after the last day of the grant period. 

May current year funds be used to pay Past obligations or Future obligations? 

No. Current year appropriations must be used for current obligations. See Question above.

If I have an invoice with a date of July 15th, is this considered a “Purchase Date” after July 1? 

Not necessarily. The Purchase Date is the obligated or Purchase Order date. 

How many years of financial records do schools need to keep? How many years of records do Consortia need to keep? 

For stand-alones, the local district’s depreciation schedule and disposal policies apply.

Federal Audits go back 5 years from the date of purchase (statute of limitations), however, NDE recommends five years from the end date of when the final expenditure report is received. For example, the July 1, 2019 to June 30, 2020 grant year’s final expenditure report should be received by October 1, 2020. The retention date would then be 5 years from that date or October 1, 2025.