Perkins Management Guide
The Perkins V Management Guide has been developed to be the main and trusted source of information for CTE administrators when administering CTE programs in Nebraska. All grant recipients (schools, consortia, and community colleges) are expected to adhere to the policies and procedures discussed in this guide for audit compliance and program quality purposes.
The Management Guide’s sections are outlined below and serve as a comprehensive reference guide for CTE administrators on a variety of topics including:
- Nebraska’s CTE Framework
- Program Administration
- Program Implementation
- Data Reporting and Accountability
- Grant Management
This guidance will be updated as needed. Changes will be indicated and described in the Change Summary.
Under Perkins V, eligible recipients include local educational agencies, area career and technical education schools, educational service agencies, Indian Tribes, Tribal organizations, Tribal educational agencies, or a consortium eligible to receive assistance under section 131 of the Act, or, an eligible institution or consortium of eligible institutions eligible to receive assistance under section 132 of the Act.
Eligibility is contingent upon recipients’ completion of the NDE’s reVISION process, submission and approval of the Local Perkins Application and annual budgets, and the annual confirmation that CTE Essential Components are in place, which indicate CTE programs of are of sufficient size, scope, and quality to be effective and meet the needs of all learners.
A secondary school district must qualify for a minimum allocation of $15,000 or join/form a consortium with other eligible recipients. A postsecondary institution must qualify for an allocation of $50,000 or join/form a consortium with other eligible recipients. See below for more information about Perkins consortia.
Each year Nebraska public secondary schools and community colleges – referred to as the local education agency (LEA) in the Act – will be asked to indicate their intent with regards to participating in the Perkins grant program administered through the NDE.
The LEA allocation will be made on a single fiscal year basis. The allocation to each LEA is calculated using a formula established in the Federal legislation and published in the Nebraska Perkins V State Plan. LEAs will be notified of their annual allocation. Perkins funds should be used to improve or expand CTE programs, not maintain them.
The NDE will use the Perkins V Intent to Participate Tool through the NDE portal for local secondary school districts to declare their intent to participate in Perkins V for the fiscal year. Completing the requested information will accomplish the following:
- Affirm the LEA meets the essential components requirement for participation
- Identify the active Career and Technical Education Student Organizations (CTSO) offered and available for student participation in the local district
- Declare the district’s intent to participate by identifying their participation option. LEAs can choose one of three participation options:
- If the LEAs allocation is greater than $15,000, the LEA can either accept the federal funds and operate its own program or choose to participate in a consortium;
- If the allocation is less than $15,000, the LEA must enter into a consortium managed by an educational service unit (ESU) or other eligible recipient(s) in order to meet the $15,000 minimum allocation requirement; or
- The LEA can decline the allocation.
Waivers and Exemptions:
Per section 131(c)(2) of Perkins V, requests for an exemption from consortia membership will be limited. The requirement will be waived only in instances where the requesting district is able to demonstrate, through detailed documentation, it is:
- Located in a rural, sparsely populated area; and
- Unable to enter into a consortium for purposes of providing activities under Perkins.
Postsecondary institutions will declare their intent to participate by responding to the written request for information annually.
LEAs on the postsecondary level can choose one of three participation options:
- If the LEAs allocation is greater than $50,000, the LEA can either accept the federal funds and operate its own program or choose to participate in a consortium;
- If the LEAs allocation is less than $50,000, the LEA must form a consortium with other eligible recipients in order to meet the $50,000 minimum allocation to participate; or
- The LEA can decline the allocation.
Waivers and Exemptions:
Per section 132(c)(1) of Perkins V, there are no waivers or exemptions for the minimum allocation for postsecondary institutions or postsecondary consortiums.
Since 2012, the NDE’s reVISION process has been instrumental in improving and strengthening CTE in Nebraska. This process provides Nebraska schools with the opportunity to analyze and transform their current CTE systems in order to improve their ability to educate a qualified workforce that meets industry needs within an ever-changing economy.
To satisfy the Perkins V requirement for the development and implementation of a comprehensive local needs assessment, reVISION, given its success and reach, was updated and expanded to meet the required elements of the Act.
As Nebraska CTE transitioned from Perkins IV to Perkins V, reVISION was used as the foundation for local CTE implementation – it was the foundation for developing the local application (for stand-alone districts, consortia, and community colleges) and future spending decisions. It was a chance for all schools and community colleges to take an in-depth look at their entire local and regional CTE system and identify areas where targeted improvements could lead to increased opportunities for student success. reVISION, if implemented thoughtfully, will be a powerful opportunity for local educators to engage stakeholders in a common understanding and vision for the future of CTE in their community.
Each district and community college in Nebraska desiring to operate as an approved CTE program and receive Perkins funds is required to complete the reVISION process. Additional information about the reVISION process can be found at: https://www.education.ne.gov/nce/ revision/.
After the reVISION process has been completed, LEAs may elect to form or join a Perkins consortia. LEAs who do not meet the minimum allocation threshold as described above in the Intent to Participate section are required to participate as a member of a consortia or request a waiver (for secondary recipients). For Perkins V funding purposes, funds allocated to a consortium (formed to meet the requirements of Section 135) will be based on the amount that would otherwise be distributed each LEA.
Because a consortium submits one four-year local application on behalf of all member schools or entities, it is strongly recommended that LEAs remain in their consortia for the same time period. If a member school or entity decides to leave a consortium or terminate a cooperative agreement, they must appeal to the NDE.
Allocation of Funds Within a Consortium
Members of the consortium will jointly determine the method for identifying consortium activities and funding priorities based on each participating member’s reVISION process, recommendations from any local or regional advisory committee, and funds available. The consortium must determine a fiscal agent, such as an ESU or a district/community college that is a member of the consortium. Members of the consortium must reach consensus upon the mutually-beneficial programs and purposes that Perkins funds will support. Members will describe the purposes and programs, aligned with the outcomes of the reVISION process, in the local Perkins application.
Funds may not be reallocated to individual members of the consortium for purposes or programs benefiting only one member of the consortium. Similarly, funds may not be “granted back” to an individual LEA. In other words, if a school generates $5,600 through the formula allocation and participates as part of a consortium, they are not guaranteed $5,600 to be spent on their CTE programs. The consortia must review the CTE needs of all schools and allocate funds on the consortia level based on reVISION outcomes and the local four-year application. For example, if the consortium decides to prioritize business education programs, all business education programs in the consortium must have the opportunity to benefit and participate in related programming or expenditures.
Any equipment or instructional materials purchased remain the property of the consortium and must be clearly identified as such. If an LEA chooses to leave a consortium, any equipment purchased by the consortium that has undepreciated value should be returned to the consortium.
For competitive awards under Perkins, any eligible recipient who completed the reVISION process and is interested in applying may do so, regardless of their participation within a consortium.
The federal Strengthening Career and Technical Education for the 21st Century Act (Perkins V) provides resources to support educators in developing the academic, technical, and employability knowledge and skills of secondary and postsecondary education students enrolling in CTE programming.
The Local Perkins Application must be completed by all secondary and postsecondary (stand-alone and consortia) CTE providers seeking federal funding through Perkins V. Staff from the Office of Career, Technical, and Adult Education at the Nebraska Department of Education (NDE) created several resources to help LEAs in developing a strong application for Perkins V funding, one based on information that surfaced as part of the reVISION process. Only those needs identified as a result of the reVISION process and articulated through the local application will be considered for Perkins funding.
The Local Perkins Application asks LEAs to describe how they will use federal funds in strengthening CTE programming and expand student access to CTE programs. Under Perkins V, each state is required to submit a four-year plan to the U.S. Department of Education, Office of Career, Technical, and Adult Education (OCTAE) covering the 2020-2024 academic years. Local CTE providers (districts, consortia, and community colleges) receiving a Perkins V grant allocation are also required to submit plans with the same timeline committed. Submission of this Local Perkins Application will fulfill that eligibility requirement.
This is the template for the Local Perkins Application under Perkins V. Once complete, this application will then be uploaded into the NDE’s Grants Management System where the remaining application components and requirements will be completed.
Click one of the following links to download an editable version of the Local Perkins Application covering program years 2020-2024:
Efforts that advance educational equity help to ensure that all students have the resources they need to graduate prepared for success in postsecondary, career, and civic life. Both the ESSA and Perkins Act give greater responsibility to states and districts to advance equity at the local level.
Special populations include:
- Individuals with disabilities
- Individuals from economically disadvantaged families, including low-income youth and adults
- Individuals preparing for nontraditional fields (students who are in programs or employment in occupations in which their gender comprises less than 25% of total employment)
- Single parents, including single pregnant women
- Out-of-workforce individuals
- English learners
- Homeless individuals
- Youth who are in, or have aged out of, the foster care system
- Youth with a parent who is a member of the armed forces and is on active duty
Nebraska Career Education must be available and provide services to all students, including those from special populations. Special emphasis must be given to the success of special populations in CTE courses.
Through Nebraska’s reVISION process, local recipients are required to work collaboratively to assess performance data for all students across all special populations, identify performance gaps, positive or negative trends, and identify strategies for addressing any disparities in performance. These findings must be carried through to each recipient’s local Perkins application and annual application for Perkins funds. Within the application, a description of how students from special populations are provided with programs that enable them to meet or exceed State determined levels of performance, and prepare them for further learning in high-skill, high-wage, and high-demand occupations is required.
Several resources have been created to assist local recipients in supporting students from special populations .These resources will help recipients develop plans to address the equity gaps for special populations that were discovered during the Perkins V reVISION process. Your Perkins V Indicator Report provides you with performance data disaggregated by gender, race, and each of the nine special population groups.
Specific strategies targeting each of the nine special populations can be found here: www.education.ne.gov/nce/nontraditional-special-populations/
Use this resource with your team to identify potential strategies to address the root causes of your identified gaps in participation and performance. Utilize the recommended state and national organizations to support your efforts and to locate similar local organizations that serve students in your community. Target your strategies to address the needs of each of the special population groups to increase the potential for success. With the right support, your students who are members of a special population can achieve amazing results and discover a new world of opportunities.
Pursuant to section 135(b) of the Act, Perkins funds may only be available to programs meeting the following minimum criteria to ensure local recipients’ CTE systems are of sufficient size, scope, and quality to meet the needs of all students served.
The following definitions are intentionally framed around Nebraska CTE’s Guiding Principles to provide coherence to the Nebraska CTE system. The Essential Components of Size, Scope, and Quality listed below apply to secondary CTE programs.
Size refers to the quantifiable evidence, physical parameters, and limitations of each approved program that relate to the ability of the program to address all student learning outcomes. Generally, size will be defined by items such as the required number of programs, and availability of facilities and equipment to ensure quality, equity, and access.
Scope provides curricular expectations of each program and/or program of study to cover the full breadth of its subject. Generally, scope involves appropriate sequencing of courses, career development, early postsecondary and work-based learning opportunities, the role of advisory committees, and the role of Career and Technical Student Organizations (CTSOs).
Quality refers to the strength of the overall system components, including the extent to which these components positively impact student outcomes.
Perkins V requires a continued federal, state, and local commitment to performance measurement and accountability. Perkins V builds on past efforts to evaluate and improve CTE. This law gives States, school districts, and postsecondary institutions greater flexibility to design services and activities that meet the needs of their students and communities. In return for that flexibility, Perkins V establishes a rigorous State performance accountability system “to assess the effectiveness of the state in achieving statewide progress in career and technical education and to optimize the return of investment of Federal funds in Career and Technical education activities” (sec. 113(a)).
Nebraska CTE will assist educators in making a more formal shift from collecting data to using data to ensure local CTE programs create success for students and employers and reduce performance gaps for CTE concentrators, including those who are members of special populations. The quality and effectiveness of Nebraska CTE is dependent on the ability to constantly evaluate and improve. Through Nebraska’s reVISION process, all local recipients are required to analyze disaggregated student performance data to identify performance disparities across student groups, detect root causes, and direct resources towards addressing both. These findings will be carried through to each recipient’s annual application for Perkins funds. Within the application, a description of how concentrators from special populations are provided with programs that enable them to meet or exceed State determined levels of performance, and prepare them for further learning in high-skill, high-wage, and high-demand occupations will be included.
If a local recipient fails to meet State determined levels of performance or has made no meaningful progress, a Performance Improvement Plan must be submitted to articulate the steps that will be taken to address the performance deficiencies. This plan will need to include specific detail about how the recipient plans to address the performance gap along with strategies that will be implemented to address the gap, which may include the use of Perkins V funds. See section D(5) of this Plan for additional information.
More information about Perkins V Accountability can be found at: https://www.education.ne.gov/nce/cte-data-research/
For Full Detailed Account Codes, see NDE Master Code List: Finance and Organizational Services – Nebraska Department of Education
Object Code: 100–Salaries/200 – Benefits
Use of Perkins funds for personnel services and salaries is an approvable expense if it helps to accomplish the activities identified in the local application. 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. See the allowable uses of funds section within the Perkins Grants Management guide.
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.
Object Code: 300 – Purchased Professional & Technical Services
This category is used for payment of fees to consultants or for professional and technical services. It may also be used for payment from consortiums to schools for stipends to teachers or to reimburse for substitute pay.
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)).
Note: Expenses for CTSO advisors/sponsors attending student organization conferences and/or activities are a local responsibility and are not allowed as an eligible Perkins expenditure. This would be an example of supplanting local fiscal responsibility.
Object Code: 400/500 – Other Purchased Property Services
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 also include travel, conference expenses and other activities that support the requirements of the legislation.
Object code 600 – Supplies
This object code is used for instructional materials and equipment <$5,000. This includes instructional software and materials that are allowable. See the Allowable Uses of Funds section in the Perkins Management guide.
Object code 700 – Capital Assets
This object code is used for instructional materials and equipment >$5,000 per individual item. It is not permissible to purchase residential grade equipment and seek Perkins reimbursement. See the Allowable Uses of Funds section in the Perkins Management guide.
Per Section 135(b), funds made available to eligible recipients under this section shall be used to support CTE programs that are of sufficient size, scope, and quality to be effective that:
- Provide career exploration and career development activities through an organized, systematic framework designed to aid students, including in the middle grades, before enrolling and while participating in a CTE program, in making informed plans and decisions about future education and career opportunities and programs of study;
- Provide professional development for teachers, faculty, school leaders, administrators, specialized instructional support personnel, career guidance and academic counselors, or paraprofessionals;
- Provide within CTE the skills necessary to pursue careers in high-skill, high-wage, and in-demand industry sectors or occupations;
- Support the integration of academic skills into CTE programs and programs of study;
- Plan and carry out elements that support the implementation of CTE programs and programs of study and that result in increasing student achievement of the local levels of performance;
- Develop and implement evaluations of the activities carried out with funds under this part, including evaluations necessary to complete the comprehensive needs assessment (reVISION).
Please refer to Section 135(b) of Perkins V for a comprehensive list of required and permissive uses of Perkins funds. Additional state guidance on allowable uses of funds can be found in the sections below.
Supplanting with Federal Funds
Supplanting occurs when federal dollars replace what is typically paid for by local/state dollars to support CTE programs and activities. If Perkins funds provided a service that the LEA is required to provide under local or state law, supplanting would occur. In other words, Perkins funds cannot be used for an LEA’s general responsibilities.
Perkins funds must supplement, not supplant local or state funds. The filter is always to demonstrate that the expenditure of funds improves or expands CTE programs. In both cases, the expenditure of funds must be above normal operational expenses. Here are some examples:
- It would be appropriate to print outreach materials and recruitment brochures for single parents, students whose parents are active duty military, or students who are English learners, but not to expend funds on printing the general course or college catalog.
- Replacing an old or worn out piece of equipment with a similar piece of equipment would be supplanting local fiscal responsibility. Replacing equipment to upgrade it to current industry standards would be an approvable use of Perkins funds.
- It would be appropriate to refer a student to a remedial or developmental course as needed, but not to pay for an instructor’s salary in that course.
The beginning date when funds can be obligated for approved grant activities
cannot precede (1) the receipt of an approvable application with a budget request for funds for formula grant programs or (2) notification of approval and issuance of the grant award notification (GAN) for competitive and discretionary grants. Obligations/Purchase Orders cannot be made prior to or after the Grant Period.
Obligations/Purchase Orders cannot surpass the 25% allocation limitation (from July 1 to September 30), or after the ending dates of the grant.
Payments for State and Federal grants are made on a reimbursement basis only. There are no scheduled payments nor advance payments.
Although the Federal fiscal year is October 1 to September 30, the Strengthening Career and Technical Education grant (Perkins V) becomes available on July 1. Only 25% of the grant funds are available from July 1 – September 30. The remainder of the grant becomes available on October 1.
See more guidance at Grants Management System: www.education.ne.gov/gms2/
Reallocation of Perkins Funds
Federal funds that are not applied for as of September 1 of the current fiscal year will be reallocated by formula for use during the following fiscal year to LEAs with applications approved for federal funding. The Perkins Act does not allow LEAs to carry forward funds to the next year.
The grant closeout process is to be completed and submitted to NDE by September 1.
Audit guidelines require that an itemized printout of the total expenditures attributed to the approved Career and Technical Education application for the year must accompany all claims for reimbursement. This printout must include the date of purchase, vendor, amount and description of items purchased. The printout should also provide detailed information on any personnel services charged to the Perkins grant. Additional information may be requested, such as accounting ledgers.
The following expenditure items always require supporting documentation including, but not limited to, purchase orders, invoices, and receipts.
- All credit card purchases
- Travel expenditures related to a conference requires adequate documentation (per 2 CFR 200.474)
- Food: generally, there is a very high burden of proof that paying for food and beverages with Federal funds is necessary to meet the goals and objectives of a Federal grant. There may be unique circumstances where the costs would be permissible because they are reasonable and necessary. See the section on meals within the Allowable and Nonallowable Uses of Funds section for more detailed information.
- Reimbursement to individuals
The NDE will review the following for all financial claims:
- Expenditures were pre-approved
- Claims reflect expenditures as reported (equipment/supply purchases must be itemized)
- No more than 5% of allocation administration fee is claimed and documented
- Documentation for Time and Effort is included for all staff and substitute teachers
- Documentation includes copies of invoices, purchase orders, or receipts
- Documentation of accounting records showing where the cost was actually paid (accounting ledger printout)
All ledgers, copies, and supporting documentation should be attached/provided to the claim form before submitting to NDE.
Following these guidelines does not necessarily guarantee reimbursement.
Expenditures funded through the Perkins grant must ultimately enhance instruction for students to gain knowledge and skills that meet industry standards and expectations in high-wage, high-skill, and high-demand occupations.
The following list includes allowable and non-allowable uses of Perkins funds. Note that some non-allowable expenditures have exceptions. Always check with your NDE monitor for questionable purchases and pre-approval. All Perkins funds must adhere to all federal and state laws, policies, and regulations. Visit the NDE’s Finance and Organizational Services website for additional information at https://www.education.ne.gov/fos/.
Administrative expenditures are limited to 5% of the total budget and can be utilized for meeting general requirements of administering the grant (records retention, financial management). The GMS system will provide the indirect cost rate for each recipient 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 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.
Expenses associated with conducting an advisory committee meeting may be considered a direct or indirect administrative cost.
See “Marketing/Promotional Expenses”
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.
Cash awards, medals/pins, plaques, ribbons, trophies, etc. are non-allowable.
Scholarship awards are non-allowable as these are considered a direct-benefit.
Basic hand tools or tools that would not be considered innovative are not allowable (e.g. chisels, clamps, gardening tools, hammers, hand saws, levels, planes, pliers, punches, rasps, screwdrivers, tape measures, trouble lights, vise grips, wrenches). However, there is an exception for ergonomic and/or state-of-the-art tools and tool kits that are part of an innovative program that combines rigorous academic instruction with CTE.
Additionally, purchasing basic tools for the creation of a new program or to align with a new program of study or set of state standards is permissible.
Building or land purchases or modifications, attachments, accessories are non-allowable. Instructional equipment costing more than $5,000 per individual item may be permissible.
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, filament, paper, office supplies, lumber, etc.)
- 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
- All equipment must be housed within CTE programs, not in general use computer or learning labs. Equipment purchased with federal funds must be used for CTE instruction purposes. For example, computers purchased using federal Perkins funds may not be used for general school clerical/office work or library/computer work.
- Equipment purchased by a consortium must be maintained and inventoried by the consortium
- 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.
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.
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.
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 NDE. 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 NDE to document the notification and action of law enforcement officers.
For the purposes of disposing or transferring equipment, current fair market value is determined by obtaining two signed bids from potential purchasers or two appraisals from authorized appraisers for the purpose of disposing of or transferring equipment. When the equipment is being traded in for like or similar equipment used in the same program for the same purpose, the trade in value constitutes the current fair market value of the traded in equipment.
Carry Over Funds
Perkins does not allow carry over funds for the annual grants.
Career and Technical Student Organizations (CTSO)
The following is considered non-allowable uses of Perkins funds: awards for recognition of students, advisors, or other individuals; dues (student or advisor); food for students; jackets/uniform apparel; lodging for students; printing and disseminating of non-instructional materials; registration fees to events, conferences, activities; supplies; transportation of students to CTSO conferences; student/advisor expenses at CTSO conferences.
Cost of local advisors attending CTSO conferences:
Expenses for advisors/sponsors attending CTSO 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. However, districts may break out the percentage of expenses and time certify to be reimbursed for the professional development component of the conference. This is professional development beyond the competitions – not a session on how to prepare your students for competition.
Perkins can pay for time and travel for professional development that improves teaching and learning – not the supervision of students or competition preparation. Documentation would need to be provided as proof that the advisor attends those sessions and is not just there to supervise students and watch the competitions. Perkins could reimburse expenses for that percentage of time, not the entire trip because supervision of students is a local responsibility and expense.
Certifications or Certification Exams
Perkins funds may not be used to pay for an individual certification exams or tests (e.g., Microsoft Office Specialist Certification licensing, OSHA Construction Safety Certification).
Certification Practice tests licensing may be allowable with prior approval and as long as they are directly tied to approved CTE programs of study. On-line college prep tests are non-allowable.
Not approvable except in the instance of removing access or other barriers for a member of a special population, such as single parents participating in special CTE assistance programs. It is recommended to obtain prior approval by the NDE.
Funding to transport students to and from college visits or to and from student state conferences (e.g. CTSO state leadership conferences or competitive events) would be considered direct assistance to students and therefore not allowable.
However, expenses for CTE students to attend field trips, laboratory experiences, and CTE instruction directly related to approved CTE activities is permissible.
Computers must be of industry standard that are found in the business world and directly tied to an approved CTE program of study or other approved activity. Chromebooks are not approvable for purchase with Perkins funds as they are not an industry standard.
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 non-allowable expenditures. (This includes plumbing, wiring or remodeling.)
Consultant fees must be justified in the local application and pre-approved. 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.
Consumable Supplies or Equipment
Standard classroom consumable supplies are non-allowable. These include but are not limited to items such as: 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; toner; filament, and welding rods/wire. However, if the supplies or equipment is for implementing a new approved CTE program of study or updating based on alignment to state standards, supplies to start-up the program may be considered allowable. Prior approval is required.
Contingency or “petty cash” Funds
Direct Assistance to Students
Perkins funds may not be spent on direct assistance to a student on such items or activities as childcare, fees, lodging, meals, textbooks, tools, transportation, and workbooks. However, there is an exception if the assistance is supporting the removal of access or other barriers for a member of a special population, such as single parents participating in special CTE assistance programs. Prior approval is typically required and the following conditions must be met:
- Recipients of the assistance must be individuals who are members of a special populations who are participating in approved CTE programs that are consistent with the goals and purposes of Perkins V.
- Assistance may only be provided to an individual to the extent that is needed to address barriers to the individual’s successful participation in CTE programs.
- Direct financial assistance to individuals must be a part of a broader, more generally focused effort to address the needs of individuals who are members of special populations. Direct assistance to individuals who are members of special populations is not by itself a program for special populations. It should be one element of a larger set of strategies designed to address the needs of special populations.
- Funds must be used to supplement, not supplant, assistance that is otherwise available from non-federal and other federal sources. For example, an eligible recipient could not use Perkins V funds to provide child care for single parents if non-federal or other federal funds previously were made available for this purpose, or if non-federal or other federal funds are used to provide child care services for single parents participating in non-career education programs and these services otherwise would have been available to CTE students in the absence of Perkins funds.
- Direct assistance should be paid to the vendor rather than the student whenever possible. Actual expenses can be reimbursed based on submission of a documented expense voucher. Costs for public transportation or a rate consistent with public transportation may be allowed only to provide student’s transportation to attend an approved CTE activity. Perkins funds cannot be given to students for purchase of uniforms, equipment, or materials. Perkins funds cannot be used for car repair.
Direct assistance to a student not identified as a member of a special population or gender nontraditional is not permissible.
Distance Learning Fees
These types of fess would be non-allowable. This provides a direct benefit to the student.
Expenditures for entertainment or social activities are non-allowable, such as beverages, lodging, meals, non-working meals, transportation, and gratuities.
Instructional equipment that costs less than $5,000 per individual unit 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 to be consistent with technology found in business and industry.
For equipment costing over $5,000, refer to the section above on “Capital Assets.”
Expenditures for equipment must be justified as a needed improvement or addition to a CTE program based on reVISION outcomes. Replacing a piece of equipment with the same piece of equipment because it is worn out is not non-allowable. Purchasing a new industry standard piece of equipment to replace outdated equipment or technology is approvable.
Equipment must also be justified by the curriculum aligned with state model programs of study. It must support the development of current and relevant skills needed in business and industry as identified throughout the reVISION process and aligned with the curriculum provided by the eligible recipient. Professional development to support the new equipment should be included.
Equipment must be retained for use by the CTE programs offered. Perkins funds cannot be used to support purchases for use by the general school population. Equipment may be depreciated using the school/colleges depreciation schedule. LEAs are responsible for 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 current value of the equipment, not the depreciated value. Equipment with a depreciated value of $0 can be sold, however documentation must be on file and the proceeds must be refunded into the CTE program.
Basic tools and equipment such as screwdrivers, pliers, hammers, non-commercial grade plastic food storage containers, residential kitchen equipment and prep tools, etc., are not approvable and are the responsibility of the local schools. See “Basic Tools” for any exceptions.
Any equipment purchased for Food and Culinary Arts classes must be National Sanitation Foundation® (NSF®) certified meeting NSF industry standards.
Equipment for administrative or personal use is non-allowable. Expenditures for equipment that is not specifically used for approved CTE courses/programs of study and housed in appropriate classrooms/labs/workshops are non-allowable. Exceptions may be made for career development/career guidance and other innovative program activities.
Equipment for building maintenance, including supplies, is non-allowable.
Equipment that is mounted or becomes part of a building or structure is non-allowable. Mounted TVs which are part of a CTE program may be permissible with prior justification and approval.
Equipment for a CTE school-based enterprise aligned to a CTE program of study are allowable so long as the equipment follows the same standards for industry as described above. Equipment purchased using Perkins funds may not be used or fundraisers outside of the CTE program and revenue earned must go back to support the CTE program.
Equipment must be inventoried as purchased with Perkins funds for the school, community college, or consortium and identified as such on the equipment.
Ergonomic and state-of-the art tools are allowable if they are part of an approved CTE program and not consumable.
Extended Warranty/Protection Plans
Protection Plans are the responsibility of the LEA. Funds cannot be expended beyond the grant year even with the rationalization of a discounted cost.
Construction, plumbing, remodeling, rewiring or line installation or anything permanently affixed to a building is non-allowable.
Fines and Penalties
Standard classroom furniture not unique to CTE instruction is non-allowable. Storage files or cabinets are non-allowable. However, if the furniture is an integral part of an equipment workstation or to provide reasonable accommodations or remove barriers for CTE students who are members of a special population group they may be considered allowable. Prior approval is required.
Gifts, door prizes, etc.
Non-allowable. Expenses for installing equipment or materials including wiring are not approvable. However, equipment requiring professional factory installation and training (to ensue warranty remains valid) is allowable.
Instructional Resources, Materials, and Supplies
Supplies and materials are allowable expenditures, within reason, used to meet the intent of the program. Appropriate, non-consumable instructional and curriculum materials may include reference books, audio-visual materials, instructional software, curriculum, and the necessary duplication of materials.
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. However, when the books or curriculum are purchased for developing new curriculum not previously offered, such as implementing a new program or aligning curriculum with new program of study state standards, it may be permissible. 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.
Justification must be provided for expending funds on instructional materials and supplies and how they help meet the objectives of the law and local Perkins application. Justification should include a description of how the expenditure helps modernize, improve, or expand CTE offerings and aligns with industry standards and expectations and state standards.
Instructional materials must be non-consumable. Student workbooks are not an approvable expense. Instructional aids that are retained by students or are consumable (one time use) are non-allowable. Exceptions may be made on a case-by-case basis for meeting the needs of students from special populations.
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.
Building, equipment, or personal/institutional insurance is non-allowable.
Interest and Other Financial Costs
Only industry-grade equipment and tools related to an approved CTE program of study are permissible. Any equipment purchased for Food and Culinary Arts classes must be National Sanitation Foundation® (NSF®) certified meeting NSF industry standards. 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).
Rental fees may be allowable with Perkins funds.
Per EDGAR administration of Federal Grants,§ 200.465: Rental costs are allowable to the extent that the rates are reasonable in light of such factors as: rental costs of comparable property, if any; market conditions in the area; alternatives available; and the type, life expectancy, condition, and value of the property leased. Rental arrangements should be reviewed periodically to determine if circumstances have changed, and other options are available.
Legal fees and expenses are allowable only as necessary for the administration of the grant program.
Retainer fees are not allowable costs.
Promotional materials are not approvable. Examples include cups/glasses, banners, folders/bags, gratuitous items, key chains, public relations costs, gifts (of any kind), notepads, pens/pencils, t-shirts, printing and disseminating of non-instructional materials.
Advertising costs are only allowable when they are for program outreach and other specific purposes necessary to meet the requirements of Perkins as well as those outlined in the Local application. Advertising costs for meetings, conventions, or other events including displays, demonstrations, and exhibits are non-allowable. Costs of advertising and public relations designed solely to promote the LEA or its programs is non-allowable.
Repair and/or maintenance of instructional equipment performed by persons other than school district employees is an eligible expenditure. General maintenance agreements for equipment not purchased with Perkins funds are not an eligible expenditure. Maintenance contracts or agreements are non-allowable.
Meals (Food and Beverage)
Banquets and meals are considered entertainment expenses and therefore non-allowable. Working lunches (such as for an advisory committee meeting) may be permissible. Expenditures for working lunches should be considered only when secondary to the meeting. In other words, the meal is not the purpose of the meeting.
The U.S. Department of Education issued “Frequently Asked Questions (FAQ) to assist U.S. Department of Education Grantees to Appropriately Use Federal Funds for Conferences and Meetings” (http://www2.ed.gov/policy/fund/guid/gposbul/faqs-grantee-conferences-may-2013.doc). The FAQ includes a number of questions regarding the use of federal grant funds to pay for food. As a general rule, the FAQ states:
Generally, there is a very high burden of proof to show that paying for food and beverages with federal funds is necessary to meet the goals and objectives of a federal grant. When a Local Education Agency (LEA) is hosting a meeting, the LEA should structure the agenda for the meeting so that there is time for participants to purchase their own foods, beverages, and snacks. In addition, when planning a meeting, LEAs may want to consider a location in which participants have easy access to food and beverages.
While these determinations will be made on a case-by-case basis, and there may be some circumstances where the cost would be permissible, it is likely that those circumstances will be rare. LEAs, will have to make a compelling case that the unique circumstances they have identified would justify these costs as reasonable and necessary.
To evaluate the appropriateness of using federal funds for a working lunch, an LEA should consider and provide responses to the following:
- Is a working lunch necessary?
- A working lunch is only appropriate when all key items on the agenda could not be accomplished without working through lunch.
- LEAs should not determine that a working lunch is desired and then construct an agenda to justify that decision.
- Is the portion of the agenda to be carried out during lunch substantive and integral to the overall purpose of the meeting?
- Inspirational talks, award ceremonies, networking, or informal discussion among attendees would not be appropriate agenda items for a working lunch.
- If a working lunch is not justifiable, an LEA might offer attendees the opportunity to reimburse the LEA for a lunch that the LEA purchases with its general funds and delivers to the meeting site.
- Is there a genuine time constraint that requires the working lunch?
- A working lunch is not permissible if lengthening the duration of the meeting would not unduly disrupt the attendee’s schedule or make the day unreasonably long.
- A working lunch may be appropriate if some participants must travel a considerable distance to attend, because, absent the working lunch, it would not be possible to cover the entire agenda and still provide participants sufficient time to return home in order to avoid the additional cost of lodging.
- If a working lunch is necessary, is the cost of the working lunch reasonable?
- A working lunch cannot contain extravagant items. It is suggested that LEAs follow state rates or another established guideline.
- Has the LEA carefully documented that a working lunch is both reasonable and necessary?
- The LEA must document its justification for using federal funds for the purpose of a working lunch, including any cost savings that result from working through lunch.
Aside from working meals that meet the above guidelines, it is unlikely that other food and beverage costs for a meeting (e.g. breakfast, dinner, snacks, or networking receptions) would be reasonable and necessary. Please remember that entertainment costs, including costs for amusement and social activities, are never allowable.
If non-federal funds are used to pay for food and beverages, the LEA should make clear through a written disclaimer or announcement (e.g., a note on the agenda for the meeting) that federal funds were not used to pay for the cost of the food or beverages.
In providing this guidance, please note that this does not preclude an LEA from paying the travel expense of those attending a conference or meeting that is necessary to carry out its education program.
The NDE may seek to recover any federal grant funds identified, in an audit or through monitoring, as having been used for unallowable costs, including unallowable food and beverage expenses
Membership/Dues, Subscriptions, and Professional Activities
Memberships for students, faculty, or administration for CTSOs, professional organizations, or societies is non-allowable. Dues to professional or other organizations are not approvable.
Memberships for LEAs or consortia to participate in a professional organization may be allowable. The fee must align with the overarching CTE plan for the recipient. 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 purpose of membership. The NDE will review the expenditure to determine if the cost is necessary, reasonable, and allocable to the grant, and contributes to the identified results of reVISION. LEAs must be able to rebut the presumption of supplanting.
Personal Finance Curriculum
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, with Personal Finance curriculum and the Finance program of study, NDE offers no-cost, high-quality, and comparable alternatives. Therefore, this purchase using Federal Perkins funds would not be considered reasonable and allowable.
Purchased Professional & 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 subcontractors, consultants, reimbursement for substitute teachers, training, and working meals (see more information under “meal”).
Middle School (grades 5-8)
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.
Remedial or developmental courses are not approvable.
Salaries and Benefits
Grant funds may 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 circumstances is supplanting allowable. Time and effort documentation must be provided for reimbursement.
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 can be used to provide instructional staff for new positions for a period of not more than three years.
For the first year, Perkins funds may support up to 100% (1 FTE) of a salary. If Perkins funds are requested to support the same position for a second year, up to 50% of the salary will be allowable, with 25% of the salary considered during a third year. After the third year salaries must be supported with local funds as Perkins funds cannot be used to maintain staff.
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. Include all personnel that will be associated with the project. This should include the name of the person or position, how the salary/benefits were calculated, and the total salary for the project.
Please refer to the NDE’s Time and Effort reporting website for additional information, including sample logs: https://www.education.ne.gov/federalprograms/time-and-effort-reporting/. Additional information can also be found in Appendix C.
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 to industry standard. Instructional materials, including software, must enhance instruction for students to gain knowledge and skills that meet industry standards and expectations in H3 occupations. Software should align with content-area and program of study standards, and may be reviewed by a career field specialist for approval. Software renewals are permissible as long as they meet the criteria mentioned previously.
Software to maintain the security of the equipment and or programs is nonallowable.
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 (non-contract time). 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.
Individual student or staff assessments or team building products that are specific to each person are non-allowable, e.g., Strengths Finders, etc.
Student Lab Clothing or Uniforms
First-time materials to start or update a course would be allowable with preapproval. 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) and may be allowable. They 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.
Student / Staff Assessments
Individual student or staff assessments or team building products that are specific to each person are non–allowable, e.g., Strengths Finders, etc.
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 Perkins application. If subcontractors are used, indicate their qualifications and specific responsibilities to the local agency.
Substitute Teacher Salaries
Funds to pay for substitute teachers are an eligible expense if it allows for CTE educators to participate in professional development activities (on-contract time). Supporting documentation, such as sign-in sheets/agendas and payroll records may be requested for reimbursement.
See “Instructional Resources, Materials, and Supplies”
The cost of training provided for teacher development is allowable. This may include the cost of rental space to hold a meeting and similar expenses. Please see the section on “Meals” for more information about working lunches.
Expenditures for travel, including conference expenses, must support the requirements of the legislation and local Perkins application. In-state 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 CTE programs should be identified on the local application for justification of conference participation.
Perkins funds cannot be used for travel outside of the United States.
Tuition for teachers/staff to advance their skills in a CTE related program may be allowable (seek pre-approval). Tuition cannot be reimbursed to help teachers/staff to earn a BS, MA or PhD.
This reimbursement is non-allowable to students including the fees associated with dual-credit or advanced placement coursework and testing. (See Tuition/Postsecondary Fees for Special Needs Students.)
Tuition/Postsecondary Fees for Special Needs Students
Perkins V emphasizes that special populations CTE students must be provided support that will ensure program accessibility and assist them in overcoming barriers that may limit their opportunity for success. However, these approvals would need to be done on a case-by-case basis. Clarification would be required that specifies how the students will acquire current industry skills sets; how they lead students to earning a credential/certificate/degree in an H3 occupational area and are pre-approved before the tuition assistance is offered.
Car repairs are not an allowable expense. Purchasing or leasing buses, airplanes, boats, golf carts, and motorcycles are not allowable. Purchasing of automobiles, tractors, and trailers may be approvable.
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