1. CALIFORNIA DEPARTMENT OF EDUCATION Tom Torlakson, State Superintendent of Public Instruction New Perkins Coordinator Training Perkins Use of Funds Co-presented by: R. Mary Gallet, Ph.D –Regions 3,8,10 Sherry Davis, Ed.D. –Regions 1,11&part of 7 Career Technical Education Administration and Management /C-TEAM

2. TOM TORLAKSON State Superintendent of Public Instruction Workshop Objectives 1.Review Perkins IV eligibility requirements 2.Discuss allowable and unallowable expenditures 3.Claiming the funds

3. TOM TORLAKSON State Superintendent of Public Instruction What Federal and State Rules Apply to Perkins IV Funding? Perkins Career Technical Education Act of 2006 2008–12 State Plan for CTE EDGAR (Education Department General Administration Regulations) OMB Circulars (Office of Management and Budget) –Circular A-87 Cost Principals – State and Local –Circular A-133 Single Audit Requirements 3

4. TOM TORLAKSON State Superintendent of Public Instruction Purpose of the Funds Section 135(a) of Perkins IV states, “Each eligible recipient (LEA) of the Section 131 and 132 funds shall use these funds to improve CTE programs.” AVA Audit Handbook Chapter 4 While the regulations do not provide a definition of “program improvement,” it is clear that the funds may not be used to simply maintain the status quo.

5. TOM TORLAKSON State Superintendent of Public Instruction To Improve CTE Programs (Cont.) IMPROVE: modify or update existing programs ENHANCE: the effectiveness of existing programs EXPAND: develop and implement new programs or provide additional offerings The CDE has interpreted this to mean that funds may only be used to support activities intended to:

6. TOM TORLAKSON State Superintendent of Public Instruction Basic Criteria for Expending the Funds Expenditures Must: –Meet the purpose of the Act –Be necessary and reasonable Expenditures May Not be Used for: –General purposes –Maintenance of existing programs 6

7. TOM TORLAKSON State Superintendent of Public Instruction Types of Costs that can Generally be Considered Eligible Administrative Costs (5%) Personnel Services (time distribution records) Stipends Instructional Materials Travel Instructional Equipment 7

8. TOM TORLAKSON State Superintendent of Public Instruction What Types of Costs are NOT Eligible? 1.Student expenses or direct assistance to students * 2.Entertainment 3.Awards and memorabilia 4.Individual memberships 5.Membership with orgs. that lobby 6.College tuition, fees, books 7.Fines and penalties 8.Insurance/self-insurance 8

9. TOM TORLAKSON State Superintendent of Public Instruction What Types of Costs are NOT Eligible? 9.Expenses that supplant 10.Audits, except single audit 11.Contributions and donations 12.Contingencies 13.Facilities and furniture 14.General advertising 15.Alcohol 16.Fund raising 17.General administration 9

10. TOM TORLAKSON State Superintendent of Public Instruction Requirements for Uses of Perkins IV, Title I, Part C Funds 1.Strengthen academic and career technical skills of students thru integration 2.Link CTE secondary and postsecondary programs (at least 1 program of study) 3.Provide students with strong experience and understanding in all aspects of an industry (WBL: Work-Based) 4. Develop, improve or expand use of technology 10

11. TOM TORLAKSON State Superintendent of Public Instruction Requirements for Uses of Perkins IV, Title I, Part C Funds 5. Professional development 6. Evaluate programs with emphasis on spec. pops. 7. Initiate, improve, expand and modernize quality programs 8. Provide activities, services and be of sufficient, size, scope and quality 9. Prepare spec. pops. for high skill, high wage, or high demand, occupations 11

12. TOM TORLAKSON State Superintendent of Public Instruction Are Local Recipients Required to Budget and Expend Funds in all 9 Requirements? No. The 9 requirements are elements required in programs eligible for funding –If deficiencies exists, Perkins funds can address those deficiencies –If all 9 are already met, funding can be used in the permissive areas 12

13. TOM TORLAKSON State Superintendent of Public Instruction Twenty Permissive Uses of Funds 1.Involve parents, business and labor in planning & operation 2.Career guidance & academic counseling 3.Business Partnerships - Work-related experience students & faculty 4. Programs for spec. pops. 5. CTE student organizations 6.Mentoring & support services 7.Upgrading equipment 13

14. TOM TORLAKSON State Superintendent of Public Instruction Twenty Permissive Uses of Funds 8.Teacher prep. Programs 9.Distance ed. 10.Assist transition to BA degree programs 11. Support entrepreneurship education 12. Initiatives for secondary students obtaining postsecondary credit to count towards an AA/AS or BA/BS degree 13. Support small CTE learning communities 14. Family & consumer sciences 14

15. TOM TORLAKSON State Superintendent of Public Instruction Twenty Permissive Uses of Funds 15.Adult CTE programs 16.Job placement programs 17.Support Nontraditional activities 18.Automotive technologies 19.Pooling funds – Innovative Projects data & accountability, assessments 20.Support other CTE programs 15

16. TOM TORLAKSON State Superintendent of Public Instruction Supplement vs. Supplant Perkins IV funds must supplement, or augment, and not supplant state or local funds. Federal funds may not result in a decrease of state or local funding that would have been available to conduct the activity had federal funds not been received. LEAs must be able to demonstrate that federal funds are added to the amount of state and local funds that would be made available for uses specified in the local plan.

17. TOM TORLAKSON State Superintendent of Public Instruction Supplement, Not Supplant !! Cannot use Federal Funds to pay for Services, Staff, Programs, or Materials that would otherwise be paid with State or Local Funds Always ask: “What would have happened in the absence of federal funds?”

18. TOM TORLAKSON State Superintendent of Public Instruction May Federal Funds be Used to Support a Program Supported Last Year with Non-Federal Funds? No. This would be supplanting Exception: –Must be evaluated case-by-case –If impossible to continue without federal funds, may not be supplanting 18

19. TOM TORLAKSON State Superintendent of Public Instruction State Plan Policies

20. TOM TORLAKSON State Superintendent of Public Instruction 85% must be spent in CTE classrooms 10% can be spent on other CTE activities outside the classroom Up to 5% can be spent on Program Administration 85% 10% 5% Use of Perkins IV Funds

21. TOM TORLAKSON State Superintendent of Public Instruction No less than 85 percent of the LEA’s allocation must be spent to directly improve, enhance or expand CTE programs and courses identified in the approved local plan and annual application for funds. goes to CTE classes Use of Perkins IV Funds (Cont.)

22. TOM TORLAKSON State Superintendent of Public Instruction 85% goes to CTE classes Program planning, development, validation and accountability activities –Curriculum development –Professional development activities, internships for teachers and activities that address integration of academics and CTE –Instructional equipment related to a CTE industry sector

23. TOM TORLAKSON State Superintendent of Public Instruction 85% goes to CTE classes (Cont.) –Additional instructor costs incurred by the expansion of existing programs or addition of a new program requiring additional FTEs (3-year limitation) –Staff and operational costs for state and nationally recognized career technical student organizations (CTSOs) –Programs for Special Population students enrolled in CTE programs

24. TOM TORLAKSON State Superintendent of Public Instruction Up to 10 percent of the grant allocation may be expended to provide other activities that support CTE and that may not occur in a classroom. $$ for the classroom $$ for the classroom 10% Use of Perkins IV Funds (Cont.)

25. TOM TORLAKSON State Superintendent of Public Instruction 10% supports other CTE activities Career guidance and academic counseling for students participating in CTE Involving parents, business, labor in design, implementation, evaluation of CTE

26. TOM TORLAKSON State Superintendent of Public Instruction 10% supports other CTE activities (cont.) Developing and expanding programs for adults at times and in formats accessible for students, including working students Providing CTE programs for adults and school dropouts to complete secondary education or upgrade technical skills Provide CTE completers with placement assistance in jobs, advanced education or training

27. TOM TORLAKSON State Superintendent of Public Instruction Up to 5 percent of the grant allocation may be charged for the direct or indirect costs of administering the grant. $$ for the classroom $$ for the classroom Other CTE Activities 5% Use of Perkins IV Funds (Cont.)

28. TOM TORLAKSON State Superintendent of Public Instruction An LEA usually applies its indirect cost rate for the administration of a grant in order to cover agency wide, general management costs. Annually, the CDE negotiates with every LEA to determine an indirect cost rate that the LEA can charge for their indirect costs. Use of Perkins IV Funds (Cont.)

29. TOM TORLAKSON State Superintendent of Public Instruction Indirect Costs an LEA may charge indirect costs up to the CDE approved indirect cost rate if that rate is less than 5%. If the LEA’s approved indirect cost rate is greater than 5%, the LEA can only charge 5% indirect cost rate, no more.

30. TOM TORLAKSON State Superintendent of Public Instruction Middle School Participation in the Perkins IV Funds Middle school (grades 7 and 8) CTE courses may be assisted with Section 131 (secondary) funds only if the courses are directly connected to an approved sequence of courses conducted by a high school.

31. TOM TORLAKSON State Superintendent of Public Instruction ROCP Participation in the Section 131 Funds ROCPs may receive funds directed to county offices of education (COE). Section 131 allocations to COEs will no longer be restricted to court and community school use. Some or all of a COE allocation could be used for ROCP program improvements, which could include programs for court and community school students.

32. TOM TORLAKSON State Superintendent of Public Instruction Consortiums Allocations Sections 131 and 132 consortium funds may not be redistributed to individual members for purposes or programs that benefit only one member. Funds allocated to a consortium formed to meet the minimum allocation requirement may be used only for purposes and programs that are mutually beneficial to all members of the consortium.

33. TOM TORLAKSON State Superintendent of Public Instruction Use Funds to Support Work Experience Education Sections 131 and 132 funds may not be used to assist general Work Experience Education (WEE). Funds may support WEE activities if: –they are a planned and listed component of a CTE program; –are integral to one or more of the approved sequences of courses in the LEA’s local plan and annual application for funds; and –comply with applicable State and Federal regulations.

34. TOM TORLAKSON State Superintendent of Public Instruction Local Policies?

35. TOM TORLAKSON State Superintendent of Public Instruction Local Policies The LEA has discretion on which CTE programs receive funds The LEA has discretion on how to distribute the funds locally The funds can only be expended on qualified CTE programs

36. TOM TORLAKSON State Superintendent of Public Instruction Carefully consider Distribution of funds should not depend on the number of students currently served, but on the needs of the program and the students in those programs. What are the demands of the local economy? Which industry sector will have jobs in the community in 5-10 years? NOT what programs do students like best.

37. TOM TORLAKSON State Superintendent of Public Instruction Carefully consider Each CTE program does not have to get funds every year; rotate through programs over a 2–4 year cycle. This is especially important if an LEA gets limited Perkins funds. Having equipment in the classrooms that meets current industry standards. Providing professional development for teachers to remain current with all aspects of their industry sector.

38. TOM TORLAKSON State Superintendent of Public Instruction Pay substitute costs to participate in professional development, curriculum or CTE assessment development, to articulate with community college staff on Programs of Study. Stipend a teacher to be a CTSO advisor. Stipend a teacher to do an industry externship during summer or a break. Pay a clerk to call former CTE students (after hours) to gather E-2 data. Carefully consider

39. TOM TORLAKSON State Superintendent of Public Instruction Purchase CTE Equipment Upgrade equipment for CTE programs to align with industry standards. Equipment must be directly related to the CTE industry sector, NOT equipment that the district provides to academic teachers, i.e. LCD projectors or SmartBoards. NO hand-held assessment devices, iPads, etc.

40. TOM TORLAKSON State Superintendent of Public Instruction What are the Rules on Perkins IV Equipment Purchase & Inventory? Equipment is defined as having a purchase price of $5,000 or more and a useful life of one year or longer Equipment shall be maintained in a trace inventory system if the equipment is worth $500 or more and a useful life of one year or longer Equipment shall be identified as having been purchased with Perkins funds 40

41. TOM TORLAKSON State Superintendent of Public Instruction CTE Equipment – Capital Outlay CTE Equipment over $5000 per item is considered Capital Outlay Permission is required to purchase any Capital Outlay piece of equipment Complete the form found on the CDE Perkins Web page: http://www.cde.ca.gov/ci/ct/pk/documents/ou tlay.doc E-mail the form to your CDE consultant who will review and approve the expenditure

42. TOM TORLAKSON State Superintendent of Public Instruction CTE Equipment CTE equipment purchased totally or in part with federal funds is subject to both federal and state laws, rules and regulations. The LEA is required to establish property-management policies and procedures and to maintain equipment inventory-control records. Education Code 35168

43. TOM TORLAKSON State Superintendent of Public Instruction What are the Rules on Perkins IV Equipment Usage and Disposition? May not be used to compete unfairly with business When no longer needed for original purpose or other federal programs: –Current fair market value of $5,000 or less, can keep or dispose of with no strings attached –Current fair market value of more than $5,000 – may retain or sell the equipment as long as the Federal agency is provided compensation Project Monitor must be notified when equipment is being sold, traded or transferred from one program to another. 43

44. TOM TORLAKSON State Superintendent of Public Instruction

45. Books and Supplies Supplemental textbooks, NOT primary textbooks, unless they are for a new CTE course, never offered before. Supplies that improve, enhance or expand the program in order to keep up with industry standards Do NOT buy the day-to-day supplies to maintain an existing program (no food in a culinary arts program, no nails in a wood shop, no rags in an auto shop, no ink cartridges or paper).

46. TOM TORLAKSON State Superintendent of Public Instruction Contract Services Contract with a CTE professional development provider Travel and registration costs for CTE teachers to attend state or local conferences to learn about CTE program development, planning, implementation or assessment Student transportation to visit an industry related facility; NOT college field trips for all students.

47. TOM TORLAKSON State Superintendent of Public Instruction What Expenditures CANNOT Be Made with Perkins IV Funds?

48. TOM TORLAKSON State Superintendent of Public Instruction Unallowable Expenditures Individual dues/memberships for professional societies or organizations Gifts, door prizes, trophies, awards that become the personal property of a student, teacher, etc. Instructional aids, uniforms, tools or other items that may be retained by students Promotional items, such as T-shirts, pens, cups, key chains and other memorabilia.

49. TOM TORLAKSON State Superintendent of Public Instruction Unallowable Expenditures (Cont.) Lodging, food, dues, individual transportation for students in CTSOs Out-of-state travel for students Conference travel not related to CTE program improvement Meals, banquets, entertainment – No food for meetings

50. TOM TORLAKSON State Superintendent of Public Instruction Equipment and supplies for building maintenance Furniture, files and equipment used by a CTE teacher (if the LEA provides the academic classrooms with laptop computer, LCD projector, SmartBoard, etc., the same equipment must be provided in CTE classrooms) Unallowable Expenditures (Cont.)

51. TOM TORLAKSON State Superintendent of Public Instruction Standard classroom furniture not specific and unique to the CTE program (tables, chairs, desks, etc.) General storage files or cabinets not designed to store specific tools or equipment Vehicles such as automobiles, trucks, buses, utility vehicles, airplanes, boats, golf carts Unallowable Expenditures (Cont.)

52. TOM TORLAKSON State Superintendent of Public Instruction Constructing, renovating or remodeling facilities Equipment or supplies not used directly to teach CTE skills to students Salaries or wages paid to students College testing fees for students, college course fees for teachers, distance learning fees Unallowable Expenditures (Cont.)

53. TOM TORLAKSON State Superintendent of Public Instruction Tuition for either technical or academic courses for a teacher to meet degree or certificate requirements Costs of advertising and public relations designed to solely promote the LEA Career guidance materials for ALL students: LEAs cannot purchase COIN, Career Cruising, EUREKA, Choices, Kuder with Perkins funds. Unallowable Expenditures (Cont.)

54. TOM TORLAKSON State Superintendent of Public Instruction http://www.californiacareers.info//

55. TOM TORLAKSON State Superintendent of Public Instruction Things to Remember The cost must be directly related to a CTE program identified in the LEA's local CTE plan and annual application The activity must be intended to improve the targeted CTE program The cost must be "necessary" and "reasonable" for proper and efficient administration of the CTE program

56. TOM TORLAKSON State Superintendent of Public Instruction Things to Remember (Cont.) The cost must be specific to the targeted program—as opposed to a general expense required to carry out the LEA’s overall responsibilities Finally, the real test comes in comparing the use of the district's allocated funds to other potential program improvement uses

57. TOM TORLAKSON State Superintendent of Public Instruction Questions to Ask Yourself Who is requesting this purchase? i.e. CTE Teacher What is the request? Why is this expenditure necessary and is the cost reasonable? How was this activity, service or supply paid for in the past? What would you do if you did not have the Perkins funds?

58. TOM TORLAKSON State Superintendent of Public Instruction Show me the money!

59. TOM TORLAKSON State Superintendent of Public Instruction Perkins IV funds are provided to LEAs on a reimbursement basis only.

60. TOM TORLAKSON State Superintendent of Public Instruction Payment Procedures The Education Department General Administrative Regulations (EDGAR) requires federal funds to be expended within 72 hours of receipt at the local level. We know that is unlikely to happen in California; therefore, CDE reimburses LEAs for approved CTE expenditures.

61. TOM TORLAKSON State Superintendent of Public Instruction Payment Timeline Quarterly claims for reimbursements may be submitted four times a year, preferably before the deadline date. Grant Quarter Months in which Expenditures Occurred Deadline to Submit VE-5 FirstJuly, August, SeptemberOctober 31 SecondOctober, November, December January 31 ThirdJanuary, February, MarchApril 30 FinalApril, May, JuneSeptember 1

62. TOM TORLAKSON State Superintendent of Public Instruction Payment Timeline Filing of a Second Quarter claim in January, (mid-year), is MANDATORY. Grant Quarter Months in which Expenditures Occurred Deadline to Submit VE-5 FirstJuly, August, SeptemberOctober 31 SecondOctober, November, December January 31 ThirdJanuary, February, MarchApril 30 FinalApril, May, JuneSeptember 1

63. TOM TORLAKSON State Superintendent of Public Instruction Payment Timeline All funds must be expended or legally obligated by June 30, 2010. Any funds left unclaimed by an LEA will revert to the CDE for reallocation to other LEAs in 2011–12. This means NO carryover.

64. TOM TORLAKSON State Superintendent of Public Instruction When are Funds Considered Obligated? Type of Cost Equipment & Supplies Work of Employees Contracted Services Utilities Rental Travel Conference Registration Obligation Occurs Date of Purchase Order When Work is Done Date of Written Agreement When Used When Travel is Taken When Fee is Paid 64

65. TOM TORLAKSON State Superintendent of Public Instruction how Perkins funds can be spent, allowable and unallowable expenditures, getting reimbursement payments in a timely manner, contact the CDE consultant or analyst responsible for your grant. If you have any questions about:

66. TOM TORLAKSON State Superintendent of Public Instruction THANK YOU