1. Carl D. Perkins Career & Technical Education Act of 2006 The Law, The Myths, The Legends February 2015

2. Question #1 Are computing devices considered supplies or equipment? Do I need to maintain inventory records for them?

3. Answer #1 1.Supplies (<$5000 per device). However computing devices are deemed “pilferable”. 2.YES – you must maintain effective control/ accountability and safeguard ALL assets and assure they are used solely for authorized purposes.

4. Question #2 What information must be included in an EDGAR inventory list? How often must you reconcile the list?

5. Answer #2 Description of property Serial # or ID # Source of funding Who holds title Acquisition date Cost of the property % of federal participation Location, use and condition Ultimate disposition data (date, sale $) At least once every 2 years.

6. Question #3 Can you use equipment purchased with Perkins funds for non-CTE programs?

7. Answer #3 1. Proportionality – if the goods/services are assigned in accordance with the benefits received 2. You MUST also make the equipment available for use in other programs supported by Perkins, provided that such use will not interfere with work for which it was originally acquired.

8. Answer #3 3. First preference for other use must be given to other programs supported by Perkins. Second preference must be given to programs under other federal awards (Sp Ed, Titles, etc). Use for non-federally funded programs is also permissible – third preference.

9. Question #4 Can you pay for administrative and clerical staff using Perkins funds?

10. Answer #4 Normally NO – treated as indirect costs. Direct charging may be appropriate only if Services are integral to the project, AND Individuals involved can be specifically identified with the project, AND Costs are explicitly included in the budget, AND The costs are also not recovered as indirect costs. Remember the 5% cap on administrative costs.

11. Question #5 What are some of the criteria that must be met in order for purchases to be ALLOWABLE UNDER P ERKINS ?

12. Answer #5 Necessary and reasonable Conform with federal law and grant terms Consistent with state policy Consistently treated In accordance with GAAP Adequately documented

13. Question #6 What are the new written policies and procedures that each LEA must have?

14. Answer #6 Cash management Allowable costs Procurement Conflict of interest Gratuities Travel

15. Question #7 What are some of the new monitoring requirements?

16. Answer #7  Based on risk of non- compliance  May use technical assistance, on-site reviews, or desk audits

17. Question #8  What is the “Procurement Bear Claw”?  It applies to ALL purchases