1. Perkins Fiscal Considerations ~ Postsecondary 2017 CTE Fall Webinar Series

2. Minnesota State Colleges and Universities
Today’s Presenters
Minnesota State Colleges and Universities
Jeralyn Jargo State Director, Career Technical Education
Judy Bradford
Grants Accountant, Finance Division

3. Goals
Overview of Perkins allocation from federal funding source to local consortium implementation
Budget, plan, cash management, goal, and target monitoring
Clarify reallocation and leadership funds
Explain process for monitoring of fiscal assets and processes
Jeralyn 3

4. Secondary/ Postsecondary Split
ALLOTMENT AVAILABILITY OF FEDERAL FUNDS
A cooperative agreement between the Commissioner of Education and Minnesota State Colleges and Universities will annually provide for the distribution of federal funds between secondary and postsecondary career and technical programs. Distribution to local education agencies must be determined by state and federal law.
~ Minnesota Rule
~ Dependency on Approved State Plan
What is the allotment of Perkins funds and how is it determined in Minnesota?
Jeralyn
The state allocation has been 16 million, six hundred and eighty four thousand, six hundred thirty seven dollars for several years. If there is good news it would be that a hold harmless clause in the current Perkins Law will not reduce our allocation below that million. Section 111 of the law explains the formula that calculated our original allocation in detail. It is quite complicated. Two major factors however are the age cohort data (weighted most heavily towards year old) and per capita income data.
The division of state funds between secondary and postsecondary recipients is in Minnesota law as stated in this slide. 4

5. Leadership Primary Function: Fiscal Responsibility
MN State Colleges & Universities as Fiscal Agent
Implements federal regulations and cost principles
State, local, and Indian tribal governments
Educational institutions (colleges and school districts by consortium)
Ensure compliance with federal and state statutes
Perform monitoring of local consortia
Provide technical assistance to the local consortia
Jeralyn
Minnesota State Colleges and Universities serves as fiscal agent for state Perkins CTE grants
Implements federal regulations and cost principles for state, local, and Indian tribal governments and for educational institutions--(colleges and school districts by consortium)
Ensure compliance with federal and state statutes
Drive decisions based on policies and procedures mandated in the federal and state laws
Perform monitoring of local consortia
Provide technical assistance to the local consortia

6. MN Perkins Budget Distribution (Oct. 1, 2017)
85% of the State’s funding goes to local consortia by formula
Distributing Perkins funds to the consortia is easier said than done. If people on this webinar have questions, they can type them into the chat box at anytime. This pie chart represents the overview of how Minnesota leadership distributes and uses Perkins funds.
Jeralyn - The % of distribution is part of our State Plan and while the numbers recorded reflect 2014 there has not been significant changes since then as the federal allotment has remained unchanged. Some changes have occurred at the local distribution point.
Federal Total allocation of just under 17 million comes to the state. That immediately gets split, by federal law, to reflect the 85% that will be distributed at the consortia level and the remainder divided between state leadership and state administration as allowed by federal law.
The 85% that goes to the consortia is divided into 90% basic grant- formula calculation using secondary and postsecondary number and distributed to each consortium by Minnesota State Plan. The 10% reserve, in Minnesota, has also been distributed by formula calculation.
The 15% that goes to state leadership and administration is split with NO MORE THAN 5% going to state administration which is split between Minnesota State Colleges and Universities and Minnesota Department of Education.
The 10% leadership dollars are also split. Notice the post secondary award is a greater % and must provide the $50,000 for state institutions, and the $60,000 for non-trad training as required. The postsecondary leadership funds also support state wide initiatives such as CTE Works conference, TSA work, Mentor-mentee initiative; the MDE contribution includes the salary and expenses of their staff participation.

7. MN Perkins Budget Distribution
(Oct. 1, 2017)

8. Local Consortium Award Allocations
Local Consortium Perkins Plan Approval Notification and Fiscal Information include the award ed to the Superintendent and the President at the fiscal host district and college with copies to local consortium fiscal and Perkins contacts upon state approval of the local consortium plan. Approximately July 1st.
Jeralyn
Allocation Award letters were sent to each local consortium host President and Superintendent with copies to consortium contacts
and fiscal contacts upon approval of Local Consortium plan after July 1, 2016.
All FY17 consortium plans have been approved and the award letter was ed as an attachment to each consortium. If you do not have a copy, contact your Perkins consortium contact or fiscal host.
Minnesota’s Perkins allocation for was consistent with the estimate provided to the consortium February, However, the amounts allocated to your consortium may vary from one year to the next dependent upon your census data, geographical area and Pell recipients. The factors involved in the calculation are explained with more detail in the operational handbook.

9. Sample Perkins CTE Award Letter
Forward Funding
Full Basic and Reserve Funding
Jeralyn
When the local consortium plans have been approved, and the distribution amounts calculated, award letters are sent to each local consortium host President or Superintendent with copies to consortium contacts and fiscal contacts.
The letters indicate the amount of the full award, along with the corresponding GLs
And the amount of the award that can be used during the forward funding timeframe.

10. Basic vs Reserve
The separation of Basic and Reserve is based on the using two separate formulas
Federal law separated Reserve dollars so states had the option to distribute additional dollars to rural or high number programs based on need
Definitions of required, permissive, allowable expenditures are the same for Basic and Reserve
Required and permissive use of funds
Jeralyn
Allocation Award letters were sent to each local consortium host President and Superintendent with copies to consortium contacts
and fiscal contacts upon approval of Local Consortium plan after July 1, 2016.
All FY18 consortium plans have been approved and the award letter was ed as an attachment to each consortium. If you do not have a copy, contact your Perkins consortium contact or fiscal host.
Minnesota’s Perkins allocation for was consistent with the estimate provided to the consortium February, However, the amounts allocated to your consortium may vary from one year to the next dependent upon your census data, geographical area and Pell recipients. The factors involved in the calculation are explained with more detail in the operational handbook.
All decisions for expenditures need to go back to THE PLAN- even if the expenditure is permissive-- was it part of the plan of the consortium? Changes can be made but it is a consortium decision not an individual decision.

11. Allocation Cycle MN Receives US DOE Grant Award Letter
July 1, Year X State Receives Forward Funding
Basic and Reserve Awards to Local Consortia
Full Funding Year X
October 1
Cut off for Year X-1 Spending
June 30
Denise – Judy – As the grant accountant. Can you walk us through the annual funding cycle?
Judy - This is a funding cycle for a specific US DOE Perkins CTE Grant Award. The federal fiscal year starts Oct. 1 but the state usually receives a “forward funding” amount July 1 or shortly thereafter and we send that award/approval letter to the local consortia as soon as we have calculated the formulas for each consortia and approved the local application plan, usually beginning the second week in July. So let us go through the cycle for the Oct grant award

12. Consortium Budget and Planning Considerations
Consortium’s approved local application outlines budgeted spending for the entire award
Spending should be reviewed throughout the year to verify and ensure spending is following approved plan
All award monies must be encumbered by June 30th of the award year, with all transactions concluded prior to August 15th
Cash Management
Judy
Local consortium approved FY18 local application outlines budgeted spending for the entire award
Spending should be reviewed throughout the year to verify and ensure spending is following approved plan
To avoid the need for reallocation, all award monies should be encumbered prior to the June 30th cutoff
Your consortium and Perkins coordinator will need to submit an adjusted Post Secondary Budget and Secondary Budget for the reallocated allocation on the FY15 Budget Summary in your online application at at that time.
It is essential that you work as a consortium to accomplish the goals of your approved plan AND pay attention to your budget. Six months into your academic year you should have spent 50% of your budget at a minimum. Even better, make all you equipment purchases in the first quarter of the year so that students can actually benefit from it.
In a perfect world all plan goals are achieved and we have ZERO dollars reallocated because the money was spent as approved in the plan and in the time approved.
A caveat: the majority of spending is targeted for personnel. Follow your budget so that your personnel dollars can actually be utilized for personnel. If your budget plan for a hire July 1- the PD would need to be ready. 8

13. Allocation Cycle MN Receives US DOE Grant Award Letter Judy
July 1, Year X State Receives Forward Funding
Basic and Reserve Awards to Local Consortia
Full Funding Year X
October 1
Reallocation Of Year X-1 Award Letters
January
Capture Year X remaining to be reallocated in January
June 30
Cut off for Year X and X-1 Spending
Capture Year X-1 remaining to be returned to USDOE
Judy
This is a graphic of the funding cycle for a specific US DOE Perkins CTE Grant Award.
The money awarded in year X –green circles- is being spent from July1 until June 30. On June 30 unspent money is recaptured and reallocated, by formula, to consortium. The money recaptured from secondary gets reallocated back to secondary; the money recaptured from postsecondary gets reallocated back to postsecondary. Because of the formula, what’s recaptured from your individual consortium could be more or less than any reallocation. The emphasizes the importance of the consortium’s need to spend their allocation in the first year of the award. The distribution of reallocated funds happens approximately January.
On the graphic, you notice the blue circle indicating the reallocated award from Year X-1. That represents the previous year’s recaptured and reallocated dollars.
Last year’s reallocated money, which you received last January, must be spent by June 30, or as the top blue circle indicates, would be returned to the Dept. of Education.

14. Reallocation Award Letter — Coming Later Prior Year Reallocation
FIFO
Jeralyn
Each consortium may anticipate that there will be an additional reallocation later this year of recaptured Basic and Reserve funds not used by Perkins consortia during the school year. Notification of these amounts and the process to receive the award will be sent after the funds to be redistributed are calculated, probably in November, 2015.
Due to the First In, First Out principal the consortium should expend the reallocated amounts before the FY16 basic and reserve funds from the July1, 2015
allocations for activities in the approved local consortium plan.
[click x 2]
FIFO

15. Unexpended Consortium Funds Recaptured and Reallocated
Local consortium contacts will need to review their approved local application and decide where to make necessary budget changes if reallocated funds are awarded
Fiscal hosts and Perkins contacts will need to submit an adjusted Post Secondary Budget to add the reallocated basic and reserve dollars.
After the revised budget and plan expenditures is approved it is important to start spending the reallocated funds
Critical to spend based on FIFO
Jeralyn
Your consortium and Perkins coordinator will need to submit an adjusted Post Secondary Budget and Secondary Budget for the reallocated allocation on the FY15 Budget Summary in your online application at at that time.

16. How State Leadership Dollars are Expended
10% of the State Award may be used as Leadership funds
Of that 10%, based on Federal requirements, $110, are set aside from the Postsecondary Leadership funds for State Institutions and Non-Trad
Additional Leadership dollars may be awarded to campuses based on:
Collaboration between the System Office and campuses for projects through Intra-agency agreement between system office and the receiving college
Intra-agency agreement for Temporary Special Assignment of Personnel
Professional-technical contracts
Denise – If you have questions about reallocations, type them in the chat box. Jeralyn, in the distribution chart, 10% of Perkins funds are set aside for leadership projects. Can you explain how these are distributed?
Jeralyn:
At times the system office uses State Leadership or Administration funds to fund projects or activities at a particular college e.g. technical assessment projects, learning communities, OCR visits. For these purposes, we use either the Intra-agency agreement on the finance webpage or in some cases, the Intra-agency agreement or approval letter for Temporary Special Assignment of Personnel on the system human resources webpage. Communication among the system office CTE staff, the college supervisor of the employee and the college human resources prior to the execution of the Temporary Special Assignment is essential. This helps us track the fund usage throughout the year by Purchase Order Number and uses established finance procedures and forms available on the website, more familiar to finance staff.
We have used Perkins agreements to distribute these funds to the college. In FY16 (as we did in FY15) we will use only the intra-agency agreements to provide more consistent service and better accountability for funds.

17. Intra-Agency Agreements Between System Office and College
The college sets up a separate cost center within a NON-PERKINS Appropriation for each intra-agency agreement
To receive reimbursement:
College invoices the System Office for expenditures incurred based on the agreement parameters, using object code 9806, Inter MnSCU transfer revenue
System office pays the college
College records the payment to the Non-Perkins cost center
Judy
Once the Intra-Agency Agreement is executed, the Campus receiving Leadership funds will:
Set up a CC within a non-perkins GL of your choice
Generate a receivable for the total amount
Send invoice(s) to System Office, att’n.: Florence Newton
System Office will pay the invoice
5) Campus receipts the funds to the outstanding receivable

18. Year End Considerations
Based on the established time lines, the System Office will perform a year-end reconciliation of the Perkin’s grant ensuring all institutions have been reimbursed for all expenses incurred within the timeline, and that there is no overspending
Unspent award money is recaptured and redistributed to either the system office or the consortia, based on Federal requirements.
Unspent reallocated funds are returned to the System Office and potentially returned to the USDOE
Unspent funds are recaptured and awarded (reallocated) back to the consortia based on a formula
Judy
At the end of the fiscal year the system office reconciles the grant activity to verify eligible expenses have been reimbursed and within the grant award amount.
Draws for the new year will not start until the previous year has been reconciled and all expenditures have been accounted for in the appropriate GLs
Any unspent FY14 reallocated funds are returned to the system office and not redistributed back to the consortia. Any unspent FY15 funds are recaptured from all consortium. In January or February the recaptured funds are reallocated to the consortia based on a formula. Because of the recapture requirements it is important to starting spending the reallocated funds once they are awarded. Otherwise the consortia forfeits monies that should have gone towards plan expenses.

19. Consortium Monitoring
The System Office conducts annual audits and monitoring visits at designated consortia
Each consortium will be monitored at least once within a three year time frame
Included in the monitoring, is a fiscal desk audit of the previous year’s fiscal activity
Schedule and procedure:
Judy: In FY18, as in prior years, the system office will conduct fiscal audits at designated consortia. Prior to the visit we will send a list of FY17 transactions for which the fiscal contact will provide the requested documents. Starting the year, we are required to review your list of assets purchased with Perkins funds and documentation that this list is reviewed a minimum of once every two years. These documents will be reviewed for compliance with Perkins, State of MN, MnSCU’s policy and procedures, and Generally Accepted Accounting Principles to determine if there are any findings that should be addressed
The consortium who will be monitored FY 18 have been notified. The monitoring visits and post-secondary fiscal audit schedules will soon be posted on the CTE website. We are in the process of negotiating dates. In addition in the Operational Handbook you can find the fiscal post-secondary desk audit procedures under the heading of “monitoring for local consortia”.

20. In conclusion:
Due diligence of the Perkins plan is the responsibility of the consortia leaders, which includes proper fiscal management.
Is the spending directed at improving career and technical education?
Is it required, permissive, or allowable?
Does it pass the supplement NOT supplant test?
Business practice must be in compliance with Federal, EDGAR, guidelines as well as State, and Minnesota State Colleges and Universities policies and procedures.
Jeralyn

21. Perkins CTE Federal Resources
Perkins Act P.L www2.ed.gov/policy/sectech/leg/perkins/index.html
US Department of Education General Administrative Regulations EDGAR -Code of Federal Regulations CFR
www2.ed.gov/policy/fund/reg/edgarReg/edgar.html
Office of Management and Budget -OMB Circulars
Here are the urls to federal laws and regulations related to Perkins CTE and federal grants.

22. Perkins MN Financial Resources
Local Consortium Applications Perkins IV Operational Handbook Required and permissive use of funds
Here are the urls to access state resources we have mentioned in the webinar.

23. CTE Professional Development Resources
professionaldevelopment/monthly-webinars.html
Webinar Recordings, PowerPoints
Schedule for Fall Webinar Series
Calendar of Monthly Webinars – Thursdays, 9am

24. Perkins Fiscal Considerations ~ Postsecondary
State Director, Career Technical Education Grants Accountant, Finance Division
Enter your questions in the “Chat” field OR request to unmute your phone line and ask your questions.