Perkins Administration

Use of Perkins V money for personnel services and salaries is an approvable expense if it helps to accomplish the activities identified in the local application.

Administrative expenditures are limited to 5% of the total budget and can be spent for meeting general requirements of administering the grant (records retention, financial management). The system will provide the indirect cost rate for each district or ESU on the budget pages if selected as an option. The applicant must decide, for each program, whether to use indirect costs or not. If chosen, the system will figure the amount of indirect costs.

Note: if the budget includes equipment (capital outlay), this amount will be subtracted from the amount allowable for indirect costs as required by law.

Documentation of individual staff time must be kept at the local level, and detailed on the itemized printout submitted to NDE when claiming for reimbursement. Semi-annual time certification records are acceptable.

Grant funds can be used to pay staff for grant-related activities if the time spent is documented and justification is made for determining the rate of compensation. Under no circumstance is supplanting allowable.

Regular Salary/Benefits. When it is permissible to use funds for staff, expenditures must be limited to only that amount that is necessary to carry out the activity. Funds cannot be used to maintain staff; however, if funds are used to establish a new program, then funds could be used to provide instructional staff for a period of not more than three years.

Employee benefits are considered part of the personnel cost. These may include social security, retirement, health insurance, worker’s compensation, tax-sheltered annuities, and life insurance. Personnel who are chargeable to more than one program must be time certified, and time certification records should be kept on the local level. See the project sample in “Approved Application of Accounting Procedures” at the end of this chapter. Include all personnel that will be associated with the project. This may include the project contact person, instructors, aides, tutors and secretaries. The local application should include:

• Name of person or position
• How the salary and benefits were calculated
• Total salary for the project

EXAMPLE
Pat Jones, a CTE teacher, is involved in an approved career education project to revise one course that is a part of the total career education program in the school. The plan included 1/8 of Pat’s time during the school year to field test the revised course.

Stipends/Extended Contract Time. Stipends may be paid to teachers or participants (other than students/clients) participating in inservice training or workshops if one of the following conditions is met:

• There is a genuine need to pay stipends. Example: The inservice training or workshop is conducted after school hours, weekends or during the summer. Actual expenses may also be reimbursed in addition to the stipend.

Or

• The stipend is paid in lieu of paying expenses (travel, registration, etc.) If stipends are paid, it will be necessary to check the IRS guidelines because under some circumstances stipends may be subject to Social Security and Income Tax withholding. Stipends and substitutes are paid at the local district’s established rate.

Substitute Teacher Salaries. Substitute teachers are an eligible expense if it allows for NCE teachers to participate in professional development activities.

This category is used for payment of fees to consultants or for professional and technical services.

Purchased services are allowable expenses, within reason, used to meet the intent of the program, and documented at the local level. Examples may include:

Professional & Technical Services. Services needed to carry out the activities as defined in the local application. This may include work of a subcontractor.

Subcontractors. The funded agency may enter into written agreements for part of the services to be provided under the local application. Such agreement will describe the services of the subcontractor and will contain provisions assuring that the funded agency will retain supervision and administrative control over the services. Services of the subcontractor agreement must be specified in the local application. If subcontractors are used, indicate their qualifications and specific responsibilities to the local agency.

Consultants. Consultant fees must be justified in the local application. Consulting fees plus travel, lodging and per diem shall conform to the funded agency’s written policy. Consultant travel, lodging and per diem must be itemized in the expenditure printout.

EXAMPLE
The ESU is sponsoring a one-day, multi-session, CTE Collaboration Day. This is a professional development event. Estimation is based upon 20 CTE teachers attending including mileage and substitute reimbursement for those on contract time. (Code 300: Mileage of $1000 + Substitute Reimbursement of $2200 = $3200). Anticipated CTE workshops throughout the year to enhance the engagement, instructional, and technological strategies for student success. (Code 300: Possible Mileage + Substitute reimbursement (contract time) OR Stipends (non-contract time).

Training.
The cost of training provided for teacher development is allowable. This may include the cost of meals and breaks subject to the Federal guidelines in OMB Circular A87, Attachment B.

Working Lunches
USDE, the Office of Vocational and Adult Education, references the OMB CircularsA-87 (Cost Principles for State, Local, and Indian Tribal Governments), CFR225, Attachment B (Selected Items of Cost), #27 (Meetings and Conferences) states:

Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information is allowable. This includes the costs of meals, rental of facilities, and other items incidental to such meetings or conferences. The costs should be considered necessary and reasonable, and allocable and only when secondary to meetings, workshops or events, (e.g., the meal is not the purpose of the meeting).

• NOTE: Expenses for advisers/sponsors attending student organization conferences and/or activities are a local responsibility and are not allowed as an eligible expenditure. This would be an example of supplanting local fiscal responsibility.

Services purchased to operate, repair, maintain, and rent property owned or used by the school district. These services are performed by persons other than school district employees. Although a product may or may not result from the transaction, the primary reason for the purchase is the service provided. Repair and/or maintenance of instructional equipment meeting these criteria is an eligible expenditure. General maintenance agreements for equipment not purchased under these criteria are not an eligible expenditure.

Expenses budgeted and reported here include travel, conference expenses and other activities that support the requirements of the legislation. Instate travel is allowable. Out-of-state travel is allowable if the grantee is unable to receive comparable information (a comparable service or conference) within the state. If the budget includes expenses for out of state travel, include justification under performance measures/planned activities. Examples of allowable expenses may include:

• Personnel Travel
• Board and lodging
• Mileage (paid at the local district’s established rate)
• Airfare (if appropriate)

Travel expenses are limited to mileage, airfare, meals and lodging.  Travel must be justified in terms of value of the travel to the successful completion of the local application.

Costs associated with participation in both in-state and out-of-state conferences are approvable as requested on the local application. The potential benefit to NCE programs should be identified on the local application for justification of conference participation.

Instructional Materials and Equipment (Instructional Equipment items <$5,000) Appropriate non-consumable instructional and curriculum materials include reference books, audio-visual materials, instructional software, curriculum and necessary duplication of materials. State the instructional materials/equipment to be purchased and the activities to be addressed. Supplies and materials are allowable expenditures, within reason, used to meet the intent of the program. Simply stating intent to purchase (for example, applied academics curriculum for consortium schools) is not adequate. Any instructional materials, software and equipment (both <$5,000 and >$5,000 per item) must be justified according to their ability to modernize, improve or expand the career and technical education offerings and align them with current industry standards and expectations. It is not permissible to buy residential grade equipment and seek Perkins reimbursement. Any equipment purchased (both <$5,000 and >$5,000 per item) must be industry grade and quality to be eligible for reimbursement.  Office supplies used specifically for Perkins purposes may include:

Instructional Software.  Instructional software is defined as software that is needed to improve the academic or technical skill development of students; is used for professional development of teachers; or to update technological resources available in the programs. Instructional materials, software and/or equipment must enhance instruction for students to gain knowledge and skills that meet industry standards and expectations in high wage, high skill and high demand occupations. Instructional materials, software or equipment used in hobby, craft or leisure arts courses are not approvable for reimbursement.

Instructional Materials.  Instructional materials must be non-consumable (student workbooks are not an approvable expense). Textbooks are considered a part of the regular school’s obligation and therefore are not approvable because of the federal guidelines on supplanting state and local resources except when the books or curriculum are purchased for developing new curriculum not previously offered. Supplanting occurs when the school is replacing textbooks of an existing program. Online working documents that are purchased as a per student fee are not eligible for reimbursement.

Instructional Equipment (Items <$5,000) Instructional equipment for this section costs less than $5,000 per individual unit and is described as a movable or portable item, an implement, a devise or a machine designed for a specific instructional purpose that meets the following conditions:

• Retains its original shape and appearance with use and is non-consumable. (Consumable supplies that are not eligible include such things as plants, potting soil, welding rods/wire, welding gas, food, printer cartridges, paper, office supplies, lumber, etc.)
• Equipment purchased using lease/purchase is approvable.
• It is generally repairable.
• Retains its identity.
• It is a necessary adaptation to upgrade an existing item of equipment in order to be consistent with technology found in business and industry.

Capital Assets defined as equipment that costs more than $5,000 per individual item. It is not permissible to buy residential grade equipment and seek Perkins reimbursement. Any equipment purchased (both <$5,000 and >$5,000 per item) must be industry grade and quality to be eligible for reimbursement. Equipment is described as a movable or portable item, an implement, a device or a machine designed for a specific instructional purpose that meets the following conditions:

• Retains its original shape and appearance with use and is non-consumable. (Consumable supplies that are not eligible include such things as plants, potting soil, welding rods/wire, welding gas, food, printer cartridges, paper, office supplies, lumber, etc.)
• Equipment purchased using lease/purchase is approvable.
• It is generally repairable.
• Retains its identity.
• It is a necessary adaptation to upgrade an existing item of equipment in order to be consistent with current technology found in business and industry.
• Repair and/or maintenance of instructional equipment meeting these criteria is an eligible expenditure. General maintenance agreements for equipment not purchased under these criteria are not an eligible expenditure.
• All equipment must be housed within career education programs, not in general use computer or learning labs. Equipment purchased with federal funds must be used for career education instruction purposes. For example, computers purchased using federal funds may not be used for general school clerical/office work.
• Equipment purchased by a consortium must be maintained and inventoried by the consortium.
• All equipment purchases must be shown on an itemized printout that is submitted with the final claim for reimbursement.
• All equipment must be housed within career education programs, not in general use computer or learning labs. Equipment purchased with federal funds must be used for career education instruction purposes. For example, computers purchased using federal funds may not be used for general school clerical/office work or library computer labs.
• All equipment must be tagged designating the source of funding as Perkins.
• Equipment purchased by a stand-alone/consortium must be maintained and inventoried by the stand-alone/consortium using the local inventory process.
• Periodic review or request of inventory list may occur through monitoring.
• All equipment purchases must be detailed and shown on an itemized printout that is submitted with the final claim for reimbursement. An inventory must be maintained, which includes the make, model number, serial number, school/consortium inventory number and depreciation schedule, until the item is depreciated. The depreciation schedule used should be the same as the school depreciation schedule. In the absence of a local depreciation schedule, NDE defaults to IRS guidelines. Inventory is maintained at the consortium level.

In the case of food and food science labs, residential grade equipment may be purchased with Perkins funds to modernize or expand career and technical education offerings. However, any equipment (free standing or counter top) purchased must demonstrate or showcase the most recent technology within the equipment category.  For example: a low end, coil burner, electric range does not demonstrate or showcase the most recent technology in electric ranges.  Residential grade washers/dryers, salt and pepper shakers, flatware, spatulas, private label products sold through home parties outlets, used/damaged or discounted because of damage, light grade plastic products (bowl toppers), etc., are not approvable and are the responsibility of the local school.

Items of equipment with an original purchase unit price of $5,000 or more must be identified in the Capital Assets category on the local application consolidated budget and final claim form. An inventory must be maintained that includes the make, model number, serial number, school/consortium inventory number and depreciation schedule, until the value of the item is less than $5,000. See sample inventory tag in the section Use of Perkins Funds for Instructional Materials, Software and/or Equipment Examples of this manual.

The depreciation schedule used should be the same as the school depreciation schedule. In the absence of a local depreciation schedule, NDE defaults to IRS guidelines.

Equipment items with a current unit value of $5,000 or more cannot be disposed of without approval from the Nebraska Department of Education. Disposal of items is defined as sale, trade-in, transfer, exchange or loan. If disposal is approved, the federal share of the equipment must be used for approved career and technical education purposes or returned to NDE for reallocation.

If an item of equipment is stolen, copies of letters should be submitted to the Nebraska Department of Education to document the notification and action of law enforcement officers.

Career Technical Student Organizations

Awards

Awards for recognition of students, advisors or other individuals are not approvable including:

• • Cash Awards
  • Medals/Pins
  • Plaques
  • Ribbons
  • Advisor/Student registration fees to events, conferences, activities
  • Dues (student or advisor)
  • Food for students
  • Jackets/uniform apparel
  • Lodging for students
  • Printing and disseminating of non-instructional materials
  • Supplies
  • Start-up kits
  • Student/Advisor expenses at CTSO conferences
  • Transportation of students to CTSO conferences

Non-CTE Courses or Activities

Expenditures for students not enrolled in CTE are not approvable.

Consumable supplies or equipment

Standard classroom consumable and not allowable supplies including but not limited to:

• CO2 cartridges
• Drill bits
• Food
• Ink
• Lumber
• Office supplies (e.g., markers, glue, shears, thank-you notes)
• Paper
• Plants
• Potting soil
• Printer cartridges
• Replacement batteries
• Safety glasses/goggles
• Toner cartridges including extra cartridges purchased with a new printer
• Welding rods/wire
• Welding gloves/jackets
• Whiteboards individualized for students
• Workbooks

Consumable Instructional Materials

Any instructional materials that are consumable (one-use only) or that are retained by the student are not approvable.

Workbooks or “consumable” items are not approvable

Entertainment

Meals, Entertainment or Social Activities

(There is a high burden of proof to justify the expenditure of Perkins funds for a meal. Please refer to the Nebraska Grants Management Manual for more details)

Non-allowable expenditures for entertainment or social activities include:

• Beverages
• Lodging
• Meals Non-working Lunches
• Transportation
• Gratuities
• Gifts, giveaways, promotional materials

Banquets and meals are considered entertainment expenses are not approvable. Working lunches (such as for an advisory committee) and that are essential to the meeting and the agenda reflects that work is taking place are permissible.

Alcoholic Beverages are not allowable (see EDGAR 2CFR, Section 200.423)

Promotional materials are not approvable

Examples:

• Banners
• Cups/glasses
• Advertising
• Folders or bags Gratuitous items
• Key chains
• Public Relations Costs
• T-shirts

— Gifts (of any kind)

• Notepads
• Pens/Pencils

The OMB Circulars A-87 regulation basically states that the costs of meetings and conferences of which the primary purpose is the dissemination of technical information allows for working lunches only, transportation, rental of facilities, speaker fees and some incidental items. The costs should also be considered necessary and reasonable and written in the grant as part of a CTE activity. The approved CTE activity should have an agenda that reflects the work that is taking place and considered necessary to the primary purpose of disseminating technical information.

Refreshment breaks or breakfasts are not approvable.

Please always consider if this is the best use of limited funds; necessary and reasonable.

Construction

Construction or renovation costs

Construction costs and materials for a permanent structure (e.g., greenhouse) or anything that becomes a part of a permanent structure are not allowable expenditures

Installation

Expenses for installing equipment or materials including wiring are not approvable. Perkins funds may be used for professional development for the use or set-up of

Equipment

Expenditures for equipment that are not specifically used for approved career technical education courses/programs of study and are housed in appropriate CTE classrooms/labs/workshops are not allowable.

Equipment must be inventoried and clearly labeled as purchased with Perkins funds.

Equipment that is used for general administrative or personal use is not allowed.

Equipment that is mounted or becomes a part of a building or structure is not allowed.

Equipment warranties and service contracts beyond the current grant year are not allowed.

This includes any warranties on computers or other electronic items that are considered supplies.

Equipment and supplies needed for building maintenance are not allowed.

Equipment—repair, or replacement of lost, stolen or broken

The cost of replacing or repairing federally funded equipment that is lost, stolen or broken is the responsibility of the grant recipient

Equipment that is hobby, craft or non-occupational is not approvable.

Equipment for CTE school-based enterprises are allowable if industry grade.

Maintenance contracts or agreements

These contracts or agreements are not approvable. This includes repair plans that may be purchased when purchasing a piece of equipment

Repair expenditures

Repairs (e.g., car repairs) are not allowable

Storage

Storage files or cabinets are not approvable

Equipment—uncommon

• Animal Cages/Containment Units
• Approvable only if industry/commercial grade that have a long time-span for use as in multiple years.
• Airplanes (Nebraska does not currently have a program of study)
• Food dehydrator
  Exception would be the written rationale for the item and whether or not it is a part of the Food Science courses.
• Automobiles
• Chicken Tractor

Computers

Computers must be of industry standard that are found in the business world. Chromebooks are not approvable for purchase with Perkins Funds.

Culinary/Kitchen Tools

Basic kitchen and culinary tools are not approvable. This includes flatware, dishes, food containers, spatulas, whisks, etc. Any tools or equipment for culinary must be industry grade and commonly found in professional culinary kitchens.

Residential type kitchen tools are not allowable (e.g., salt and pepper shakers, flatware, dishes, spatulas, private label products sold through home party outlets, light-grade plastic products)

Equipment MUST be industry grade and quality and demonstrate or showcase the most recent technology within the category. Examples of residential grade equipment that would not be allowable include:

• Electric ranges (Low end, coil burner)
• Washers/dryers
• Dishwashers
• Pressure canners
• Food dehydrators (unless they are industry-grade)
• Quilting machines
• Embroidery machines (unless industry grade and tied directly to a school-based enterprise)

Tools

Basic Tools

Basic hand tools or tools that would not be considered innovative are not allowable e.g.

Ergonomic and/or state-of-the-art tools and tool kits that are part of an innovative program that combines rigorous academic instruction with career education are allowable.

Furniture

Furniture is not approvable. Furniture required to make reasonable accommodation for a student with disabilities may be approvable

Furniture that is designed to collapse and add flexible workspace is nonessential, would be considered classroom furniture so would not be allowable.

Exception: if the furniture is unique to a tool or piece of equipment and is required for that tool or equipment to operate safely and properly, furniture may be approvable.

Fiscal Expenses

Audits

The cost of a general school/institution audit is not permissible BUT the portion directly attributable to auditing the Perkins grant may be charged against the 5% administration category

Capital Expenditures

Building modifications, attachments, accessories, construction (including plumbing, wiring, HVAC, etc.) or land purchases are not approvable

Computers

Computers must be of industry standard that are found in the business world. Chromebooks are not approvable for purchase with Perkins Funds.

Contributions and donations to contingency or “petty cash” funds

These contributions and funds are not approvable

CTE Teacher and Staff Salaries

Perkins funds may support a teacher and/or staff member’s salary, however the State has a “three-year rule” on salaries using Perkins funding. A CTE related position will be funded for three years only. It is the responsibility of the local board of education to sustain this position after the first three years.

Dues

Dues to professional or other organizations are not approvable.

Fines and penalties

Fines and penalties of any type are not approvable

Fund-raising

Perkins funds are not allowed to be used for fundraising

Insurance

Building, equipment or personal/institutional insurance is not allowable

Interest and other financial costs

Any interest paid or other financial costs such as audits are not approvable

Legal Fees

Legal Fees and expenses are allowable only as necessary for the administration of the grant program
Retainer fees are not allowable costs
Legal expenses for claims against the federal or state government are not allowable

Memberships

Memberships in civic or community organizations are not allowed

Instructional Materials

Career Information System Subscriptions

Because Nebraska provides a statewide career information system (Nebraska Career Connections) that is partially funded with Perkins funds, subscriptions to other career information systems are not approvable with Perkins funds.

Certifications or Certification Exams

Perkins funds may not be used to pay for an individual certification or certification exams or tests as this is considered a benefit to individual students. Perkins funds may not be used for industry recognized certifications. (This applies to students and teachers. I.e., Microsoft Office Specialist Certification licensing, OSHA Construction Safety Certification)

* MOS Certification Practice Tests (GMetrix) licensing may be allowable.

*Professional development is approvable as long as it is not credit bearing.

College Preparatory Courses or Materials and On-line college prep tests

These would be considered a direct benefit to the student and are not approvable.

Consumable Instructional Materials

Any instructional materials that are consumable (one-use only) or that are retained by the student are not approvable.

Distance Learning Fees

Fees associated with operation of distance learning are not approvable as it provides a direct benefit to students.

Electronic Instructional Materials*

*Subscription-based fees that supplement CTE classroom instruction CAN be purchased

Instructional aides/materials to be retained by or that become the property of the student are not approvable.

Software for Use Outside the CTE Classroom/Lab

Instructional materials, software or equipment that is used in hobby, craft or leisure arts courses are not approvable for reimbursement. Software is only approvable if it is for use in career-technical skill enhancement directly tied to the CTE program of study and directly to instruction in the classroom/laboratory/workshop. Perkins funds cannot be used to purchase software or upgrades for additional alternative uses (e.g., software such as Striv, Wirecast Pro or other software used for videography or editing for athletic or other school activities such as plays, performances, etc.)

Subscriptions

Subscriptions to magazines or journals are not approvable.

Textbooks

Textbooks are not approvable expenditures

Exception: Textbooks and instructional materials for new programs or new courses that are part of a new program of study not previously provided by the school provided the curriculum is tied to current industry standards. (Workbooks or “consumable” items are not approvable)

Journalism courses or materials

Journalism is not a part of a CTE program of study.

Printing Costs

Printing costs are allowable when they are reasonable and necessary. Any multi-color printing must be reasonable in cost and must be necessary to carry out the objectives of the grant program. Promotional Items, Memorabilia, and Souvenirs Promotional items, memorabilia, and souvenirs are not allowable costs.

Other

Maintenance contracts or agreements

These contracts or agreements are not approvable. This includes repair plans that may be purchased when purchasing a piece of equipment.

Printing Costs

Printing costs are allowable when they are reasonable and necessary. Any multi-color printing must be reasonable in cost and must be necessary to carry out the objectives of the grant program. Promotional Items, Memorabilia, and Souvenirs Promotional items, memorabilia, and souvenirs are not allowable costs.

Repair expenditures

Repairs (e.g., car repairs) are not allowable

Storage

Storage files or cabinets are not approvable

Vehicles

Purchase or leasing of automobiles, trucks, buses, airplanes, boats, golf carts, motorcycles, tractors, trailers

Supplanting

Using Perkins funds to provide services the recipient is required to make available under other federal, state or local laws
Or
using Perkins funds to provide services the recipient provided with state or local funds in the prior or previous years.

Middle School

Middle school (5-8 ) expenditures for hobby, craft, leisure arts, or other non-occupational, exploration or preparation courses

Middle school (5-8) purchases would be allowable ONLY if they are to modernize, improve or expand CTE offerings AND align them to current industry standards and expectations. 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 demand occupations. The key is career skills development (not family or personal development) aligned to business/industry standards and focus on H3 careers.

Pre-5^th grade

No funds can be used to provide career education programs to students prior to the 5^th grade (pre-5^th grade students CAN use equipment in NCE classes that was purchased for 5-12 students).

Non-CTE Courses or Activities

Expenditures for students not enrolled in CTE are not approvable.

Dues/Membership Fees

Memberships for students, faculty, or administration for career and technical student organizations, professional organizations or societies.

Postsecondary fees

Any fees for students or teachers related to postsecondary education are not approvable.

Travel

Student Related Travel

Travel related to CTSO or student activities is not approvable. However, Travel costs (transportation only) for CTE students to attend field trips and laboratory experiences directly related to preapproved career education activities are permissible.

Travel outside of the US

Any travel outside the United States is not approvable with Perkins Funds

Professional Development

Memberships for students, faculty, or administration for career and technical student organizations, professional organizations or societies.

Postsecondary fees

Any fees for students or teachers related to postsecondary education are not approvable.

Conferences (CTE Conferences only are permissible)

Conference registration fees for teachers to attend a CTE-focused professional development workshop, seminar or conference are permissible.

Non CTE-focused Conference Expenses

Perkins can only pay for the expenses of CTE teachers, School Counselors or Perkins Administrators attending conferences that are directly related to CTE instruction.