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Using Title IV, Part A Funds
Using Title IV, Part A Funds
An LEA must outline clear objectives and measurable outcomes for its Title IV, Part A program in the program description. To ensure accountability, the LEA must demonstrate that all program expenditures are justified, address specific student needs, and positively impact student achievement.
Each LEA must be able to respond appropriately to and maintain documentation of the following:
Each LEA must be able to respond appropriately to and maintain documentation of the following:
How is the expenditure reasonable and necessary* to carry out the intent and purpose of the program and content area(s) of Title IV, Part A?
What specific need identified in the comprehensive needs assessment does the expenditure address?
How will the expenditure be evaluated to measure a positive impact on student achievement?
How are the expenditures supplemental to other non-federal programs?
* Costs that are reasonable are defined as those costs that are consistent with prudent business practice and comparable to current market value. Costs that are necessary are those costs that are essential to accomplish the objectives of the grant project.
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Title IV, Part A Content Areas
Title IV, Part A Content Areas
The Title IV, Part A, Subpart 1 statute specifically authorizes activities in each of the three program content areas.
Important Note: LEAs must remember that although an activity may fall in one of the 3 content areas, it may not be allowable because of Traditional Supplement, Not Supplant (SNS) rules. An auditor will always presume a supplant; therefore, districts must be sure to document that the expense is supplemental before it is incurred.
Mental Health, School Facilities, EOP + State Requirements
Traditional SNS Rules
Traditional SNS Rules
Purpose
Purpose
SNS aims to ensure that federal grant funds are used for their intended purpose and don't replace state or local funding. This helps guarantee that the program benefits the targeted population as intended by the federal government.
Funds must supplement existing programs and services, meaning they should add to, enhance, or expand what is already funded by state and local resources. LEAs will need to know the base state requirements in the 3 T4PA content areas of Well-Rounded Education, Safe and Healthy Schools, and Effective Use of Technology to determine what can be added to, enhanced, or expanded.
LEAs cannot supplant state and local funds, meaning they cannot replace or take the place of state and local funds that were used in the previous year.
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Questions to Ask Before Spending Funds
Questions to Ask Before Spending Funds
Is the program or activity required by state or local law?
Using the cupcake analogy, the cake base is state and local requirements for the Title IV, Part A content areas of Well-Rounded Education, Safe and Healthy Schools, and Effective Use of Technology. The content areas heavily overlap with state mandates and could easily create a supplanting issue if T4PA funds were used to meet a state requirement. Although federal T4PA grant guidance may say an activity is allowable for the intent and purpose of the T4PA grant, it is not allowable to use federal funds to meet a state/local requirement. Texas has many legal statutes that require activities that align with T4PA content areas.
Did the LEA provide this activity/service in the prior year using state or local funds? If the answer is yes, LEAs must wait one year before using federal funds to fund the same activity.
Is the activity/service provided to some recipients with federal funds and state or local funds to other recipients? If yes, the expense is not allowable.
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Other State Requirements That Could Create a Supplant
Other State Requirements That Could Create a Supplant
Required Trainings
Required Trainings
Educator Training/Professional Development Requirements
Educator Training/Professional Development Requirements
TEA SBEC Continuing Education and Training Clearinghouse Website
Districts must review this clearinghouse chart annually and adopt how they apply its guidance to their DMA Legal/Local board policy— Professional Development: Required Staff Development Policy.
TEA Best Practice and Programs Registry to Meet State Requirements
TEA Texas School Mental Health
TEA Texas Database for School Mental Health (ESC identified)
TASB Required Training Chart 2023-2025
Members of TASB can Log In to access this list of required training.
Other Guidance
Trainings/Professional Development in Statute as of July 2023
Charter Schools
Charter Schools
Charter School Requirements
Charter School Requirements
Charter schools must provide many of the public schools' safety and mental health requirements.
TEC 12 - Charters - TEC 12.013, TEC 12.016, TEC 12.104 and other sections
Title 19 of the Texas Administrative Code (TAC) §100.1033 (b)(14)(C)
Unallowable Use of Funds Guidance
Unallowable Use of Funds Guidance
TEA has the final say on the allowability of funds. The following resources can help LEAs determine the allowability of a purchase.
T4PA programs, activities, and services, which are also mandated by state law, rule, and regulation, State Board of Education (SBOE) rule, or local board policy cannot be funded with T4PA grant funds. LEAs should be aware of the mismatch between what is federally allowable with the grant and the overlap of state mandates to avoid supplanting.
No federal funds may be used to provide a dangerous weapon or training in the use of a dangerous weapon. ESSA Section 8526.
Medical services or drug treatment or rehabilitation are unallowable, except for integrated student supports, specialized instructional support services, or referral to treatment for impacted students, which may include students who are victims of, or witnesses to, crime or who illegally use drugs.
T4PA funds cannot be used for the construction, renovation, or repair of any school facility. ESSA section 8526(1) USDE Response 12/20.
These funds may be used for minor remodeling and repair. Minor remodeling refers to minor alterations in a previously completed building. The term also includes extending utility lines, such as water or electricity, from points beyond the confines of the space where the minor remodeling is undertaken but within the confines of the previously completed building. The term does not include building construction, structural alteration to buildings, building maintenance, or repairs.
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