Can Perkins funds pay for a Food Dehydrator?
Possibly.
Several criteria must be met before the approval of a food dehydrator.
Describe which program of study the food dehydrator will be used and provide justification.
Explain in writing what CTE standards the food dehydrator will be used to meet.
Provide the size and whether the dehydrator is commercial (allowable), small home grade (nonallowable), or other (allowability TBD)
See Vehicles in the Perkins Management Guide.
Justification for approval indicating how the cost is necessary and reasonable and allocable to the grant will be required. Decisions will be made on a case-by-case basis. Specific information necessary for consideration includes:
A detailed description of how the vehicle purchase is “reasonable and necessary” and will only be used for Perkins-related activities.
The purchase must be justified for instructional purposes only (transportation of faculty or students is not permitted)
Documentation and certification of any miles driven and justified as instructional only (student instruction)
In 2 CFR part 200 (Federal guidelines) it states that recipients should assess whether it is a better deal to buy or lease the vehicle. Is there possibility of getting the vehicle donated, developing partnerships for a future donation, if/how costs may be shared (not just a grant funded purchase), etc.?
What will the replacement plan entail? Has this been run past the risk management department?
What is the policy for use of the vehicle at a reasonable and justified rate? See CFR 200.313 (c)(2)
If the vehicle is later sold, that amount will need to be returned to the NDE and NDE will then need to send the funds back to the Federal granting agency.
Approval would be on a case-by-case basis.
No. A washer and dryer for the use of laundering foods lab laundry is the responsibility of the LEA. Many commercial businesses contract with laundry services. Nor is a washer/dryer tied to students developing skills and knowledge that are needed for a career in the fashion/clothing industry.
From the standpoint of Fashion Construction & Fashion Design, there are not any standards in those courses that point towards students learning how to properly care for clothes. There are standards that read: “analyze the effects of textile characteristics on design, construction, care, use, and maintenance of products.” But that does not signal that students must learn how to do laundry or treat stains. To effectively teach those classes, a washer and dryer are not needed and there are no student skills and knowledge connected to those pieces of equipment.
With prior approval, an exception may be made in order to teach student skills and knowledge for an adaptive Special Ed/Life Skills course co-taught with the FCS teacher.
No. Perkins does not allow for carryover.
In the Grant Award Notification (GAN) it is stated: 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 the ending date of the Grant.
Finally, LEAs need to follow their own internal policies and business practices. It’s most unlikely an LEA would pay for items not yet received.
Potentially. In most cases, Perkins funds can support the LEA’s CTE courses that have the intent to eventually establish an approved CTE program of study. Equipment must also be justified by the curriculum aligned with state model programs of study. Check with your NDE Perkins Monitor for allowability before purchasing.
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:
Equipment purchased with Perkins grant funds can only being used for approved CTE programs and services.
Equipment purchased by a consortium remains the property of the consortium and is to be made available to all consortia members. It is strongly recommended that these equipment purchases be made by the consortium.
Property Records must be maintained that include a description of the property, a serial number or other ID number, the source of funding (including the FAIN (Federal Award Identification Number), who holds the title (Consortium), acquisition date, cost of the property, Percentage of Federal participation in the project costs for the Federal award under and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Inventory Records need to be obtainable at both entities: the consortium and the district fiscal offices.
A physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years.
A control system must be developed to ensure adequate safeguards to prevent loss, damage or theft of the property. Any loss, damage or theft must be investigated.
Adequate maintenance procedures must be developed to keep the property in good condition.
If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible level of return.
No. From the Perkins grant perspective, the main concern is that the capital asset is being used for CTE programs and services, that the cost is reasonable and necessary, and that it is allocable to the grant.
Used equipment may be procured with Perkins funds, however this is approvable only if it is industry/commercial grade and has a long time-span for use as in multiple years.
No.
Yes. (Note: Car repairs are not an allowable expenditure.) CFR 200.452
Repair and/or maintenance of instructional equipment and capital assets performed by persons other than the LEA’s employees is an eligible expenditure. However, Maintenance contracts or agreements are not allowable.
No. Because the grant is for one year only, funds cannot be expended beyond that grant year, even with the rationalization of a discounted cost. Protection Plans are the responsibility of the LEA. Purchasing these would be supplanting.
This is non-allowable unless the installation meets the following criteria:
Equipment that requires professional, one-time factory installation and training to ensure warranty validity is allowable.
2 CFR 200.468 Specialized service facilities costs are allowable.
Yes, CTE School-based business expenditures for commercial grade equipment is allowable when following the allowable Perkins purchases.
Yes- Middle grades CTE (grades 5-8) purchases would be allowable if they are to modernize, improve or expand CTE offerings and align them to current industry standards and expectations. They must also be used for a course or courses that enhance instruction for students to gain knowledge and skills that meet industry standards and certifications in high-wage, high-skills, and high-demand occupations.
The key is career skills development (not family, personal development, or teen parenting courses) aligned to business/industry standards and focus on H3 careers. (See additional information in the next question below.)
Perkins funds can be used for grades down to the 5th grade, so a middle-schools building with 5-8 would still be permissible.
Regarding the middle school program, purchases would be allowable ONLY if they are to modernize, improve, or expand the career and technical education offerings; they are aligned with current industry standards and expectations as determined through the outcomes of the reVISION process; and are written in the Local Application. They must also be used for a course or courses that enhances instruction for students to gain knowledge and skills that meet industry standards and certifications in high wage, high skill and high demand occupations and used in approved CTE programs.
Instructional materials, software, or equipment that is used in hobby, craft, leisure-arts, or other non-occupational, exploration, or preparation courses are not approvable for reimbursement.
If the items are for career exploration for a middle school class that specifically addresses health sciences or human services careers (and not personal life skills, communication, teamwork, problem solving, etc.), then they would be approvable.
Always review items with the middle school teacher(s) with the above criteria in mind. The key is career skills development (not family or personal development) that is aligned to business/industry standards and focuses on H3 careers and approved CTE programs.
Following are the guidelines for curriculum tool purchases:
1. A provision within the current ESU/District Perkins V Plan, or an amendment is needed.
For example: Plan includes improving safety lessons.
2. Curriculum tools are for instructional necessity to teach content (e.g. Excel, Fusion 360, Solid works, etc.)
3. Purchase does not supplant district funds previously allocated to purchase said curriculum.
4. Doesn’t provide direct assistance to students by paying for student certifications or certification exams.
Purchased tools or tool kits would need to be:
labeled as district property
labeled as purchased with Perkins funds
only loaned to students for the duration of the course and
returned to the district
Potentially. If culinary aprons, gloves, coats and hats, welding aprons, and welding gloves are considered the property of the department - not the student (as that would be a direct benefit) - they would be allowable. Items may be issued to a student to be used during a class to ensure proper safety and sanitation. Disposable materials would not be allowable as they would be considered consumable. Replacement clothing would be the responsibility of the district.
First-time materials to start or update a course would be considered allowable.
See section: Career and Technical Student Organizations for more information about direct benefits to students.
Can Perkins funds be used to purchase a Personal Finance Curriculum?
No.
Perkins funds may be used to purchase instructional materials when new approved CTE programs are being implemented or curriculum is being aligned to new program of study standards. However, in some cases, high-quality, no-cost options are available. This is especially true with Financial Literacy. Therefore, expending funds on an expenditure wiht a cost may not be considered reasonable. (See § 200.404, definition below.)
Given the regulations below, high-quality, no-cost alternatives are always reviewed relative to Perkins expenditures. For instance, The Nebraska Department of Education procures various statewide licenses at reduced rates to provide services to programs and schools across Nebraska. It would not be prudent nor reasonable, then, for an LEA to use the Federal Perkins funds to purchase a comparable product.
Under CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, it includes a section related to the factors that affect allowability of costs. These include, among other things, that the cost be necessary and reasonable, allocable to the grant, and that the LEA can rebut the presumption of supplanting.
In § 200.404, a cost is defined as “reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.” Further, “in determining reasonableness of a given cost, consideration must be given to:
Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the non-Federal entity or the proper and efficient performance of the Federal award.
The restraints or requirements imposed by such factors as: sound business practices; arm’s-length bargaining; Federal, state and other laws and regulations; and terms and conditions of the Federal award.
Market prices for comparable goods or services for the geographic area.
Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the non-Federal entity, its employees, where applicable its students or membership, the public at large, and the Federal government.
Whether the non-Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award’s cost.
Yes, this is an approvable item to spend Perkins funds as the harness is mandatory for roof repairs and is industry grade.
Specific only to CTE programs and when implementing new CTE programs or updating Programs of Study: the flammable storage cabinet is allowable even though it is considered furniture.
It is a specialty piece of furniture with a specific purpose for CTE safety in the workshop. It would have to be industry grade and required by OSHA. The Eyewear Sanitation cabinet--for safety and sanitation, would be allowable and have to be Industry grade. No replacement items are allowable.
Is an enclosed trailer, for storing construction class materials, an allowable expense for Perkins Grant funding?
Trailer for storage: NO
Purchases are to be focused on helping to learn career skills. Additional storage does not equal a learning experience.
A trailer for transporting equipment for use in a consortium's districts may be allowable as it would be necessary in order to provide all CTE students with the use of the equipment. Prior Approval required.
Yes, they are allowable. However, they should be a part of an approved CTE program and not consumable.
Most likely. Like all expenditures, the purchase must be allowable and allocable to the grant - meaning, it must align with the local Perkins application and be used to support approved CTE programming/curriculum. Whole-school or non-CTE uses would not be permissible (school events, athletic games, etc.). If the software is being used by CTE students during these events to refine their skills and demonstrate skill acquisition and that is tied back to the CTE curriculum, this would most likely be permissible.
They are allowable with the following stipulation for each school to use them: They are not allowable for a teen parents program. The use of the requested materials must directly relate to the current standards and Programs of Study. If the requested items were going to be used as part of FCS Program of Study course (e.g. Child Development course in Early Childhood Education and Services) then they would be allowable. The teacher(s) that would be using the materials must attend the $150 (approximately) training offered by the manufacturer to teach using best practices for the materials.