MN Perkins CTE Funding 2015-16

Requirements and Uses of Funds

Presenters

Jeralyn Jargo, State Director, Career Technical Education,

Minnesota State Colleges and Universities

jeralyn.jargo@so.mnscu.edu 651-201-1650

Debra Hsu, Associate Director, Career Technical Education,

Minnesota State Colleges and Universities

Debra.Hsu@so.mnscu.edu 651-201-1686

Michelle Kamenov, Supervisor, Office of Career and College

Success, Minnesota Department of Education

michelle.kamenov@state.mn.us 651-582-84342

Goals for Part I

Review state - federal fiscal regulations and legislation,

Board of Trustee policies-procedures and MDE regulations

governing MN CTE-Perkins financial procedures

Review Minnesota state allocation and budget

Explain the distribution of Perkins funds to local consortia

Review required and permissive uses of funds

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The Carl D. Perkins Career and

Technical Education Act of 2006

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Carl D. Perkins Career Technical

Education Act, 2006

The purpose of this Act is to develop more

fully the academic and career and

technical skills of secondary education

students and postsecondary education

students who elect to enroll in career

and technical education programs

Carl D. Perkins Career and Technical Education Act of 2006, Section 2

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Authorization

There is authorized to be appropriated to

carry out this Act … such sums as

may be necessary for each of the

fiscal years 2007 through 2012.

Carl D. Perkins Career and Technical Education Act of 2006, Section 9

• Until the Perkins Act reauthorization, the

current act remains in effect-thus in

FFY2015.

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Appropriation

(millions) FFY2011

Actual

FFY2012

Actual

FFY2013

Actual

FFY2014

Actual

FFY2015

Actual

State Grants 1,162 1,123 1064 1,118 1,117

National

Programs

8 8 7 7 7

Tech Prep 0 0 0 0 0

Total 1,170 1,131 1,071 1,125 1,125

Source: http://www2.ed.gov/about/overview/budget/tables.html

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Tydings Amendment and

First In/First Out (FIFO)

Federal fiscal year for Perkins CTE is from October 1

through September 30.

However, states may receive a portion of their funds

beginning on July 1 prior to the beginning of the

fiscal year and have 12 months beyond the fiscal

year to expend funds.

This extension is referred to as the Tydings Amendment.

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Funding Cycle-Perkins CTE Award Federal Fiscal Year (FFY) 2015

(2015-2016)

October 1, 2015 September 30, 2016

FFY 2015

SFY 2016FFY 2015

TydingsForward

Funding

September 30, 2017

STA

TE

LO

CA

L Unexpended funds returned to stateForward

Funding

9

Funding Cycle-Perkins CTE Award Federal Fiscal Year (FFY) 2015

(2015-2016)

October 1, 2015 September 30, 2016

July 1, 2015

FFY 2015

FY 2015SFY2016

SFY 2016FFY 2015

TydingsForward

Funding

Reallocation

FFY 2015

SFY 2016

June 30, 2017June 30, 2016

September 30, 2017

FIFO

STA

TE

LO

CA

L

Forward

Funding

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Perkins Award Letter

Basic and Reserve

AllocationsForward Funding

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Minnesota Perkins Funding 2015-2016 (SFY16, FFY15)

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MN Perkins CTE Funds 2015-2016

Federal Fiscal Year 2015, State Fiscal Year 2016

FFY2015 Actual

Title I Allocation 16,684,637

Title I Formula Funds 12,763,747

Title I Reserve Funds 1,418,194

State Administration 834,232

State Leadership 1,668,464

Title II Allocation (Tech Prep) 0

Amount of Tech Prep to be Consolidated with Basic Grant

0

Total 16,684,637

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MN State Colleges and Universities (in collaboration

with Minnesota Department of Education)

–Serves as fiscal agent for state Perkins CTE grants

–Implement 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 state statutes

–Drive decisions based on policies and procedures mandated in

the federal and state laws

–Perform monitoring of local consortium 14

Governing Documents

Federal

• Perkins Act P.L. 109-270 –expectations for use of funds.

• Code of Federal Regulations (CFR) – Promulgated rules in federal register.

– Education Department General Administrative Regulations (EDGAR)

– Office of Management and Budget (OMB) Circulars –restrictions on the use of funds.

State

• Minnesota Laws/State Grant Policies [MN Statute § 16B.97 –Grants Management] – managing grants as related to payments, monitoring, closeout, etc.

• Minnesota Rules – secondary credentialing, program approval requirements.

• MnSCU Board of Trustees Policies and Chancellor’s Procedures.

• Minnesota State Plan for CTE --use of funds specific to Minnesota

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EDGAR-US Department of Education

Office of Management and Budget OMB

Circulars

•OMB A-21 Cost Principles Educational Institutions—(Colleges and MnSCU)

•OMB A-87 Cost Principles—State (MDE), Local Agencies (ISD), Tribal Governments

•OMB A-110 Admin Grants & Agreements

•OMB A-133 Standards for Audit of non federal agencies expending federal funds

Code of Federal Regulations CFR

• CFR 74-C Post-Award Requirements

• Financial and program management

• Standards for financial management Systems

• Cost sharing or managing

• Equipment

• Codes of conduct

• Contract Provisions

• CFR 80-C Post-Award Requirements

• State must expend, account for grant funds as per state laws

• Fiscal control and accounting procedures must be sufficient to

• Permit 1) reports required by the grant and legislation and 2) tracing of funds and expenditures that ensures compliance with statutes

• Financial systems of local consortia and sub grantees standards—reporting, accounting records, internal control, budget control, allowable costs, source documentation, cash management, sub grants, monitoring.

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Requirements to Receive Perkins Funds

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To Receive Perkins Funds

Secondary

• State-approved CTE Program(s)

• Utilizing appropriately licensed staff

Post Secondary• On MnSCU Approved Program

Inventory – Procedure 3.36.1

– Offered by state college

– Perkins eligible; Classification of Instructional Programs (CIP) and Career Pathway identified

– Leads to certificate, diploma, AAS or AS

• Faculty meet minimum qualifications of career technical credential field –Policy 3.32 Procedure 3.32.1

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To Receive Perkins Funds

• Participate in one of the MN Perkins CTE consortia

– Each consortium must have at least one eligible

secondary recipient and at least one eligible

postsecondary recipient

– No district nor college may belong to more than one

consortium

– A charter school with a state-approved CTE

program must be invited to participate in a

consortium19

To Receive PerkinsFunds

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To Receive Perkins Funds

Consortia are encouraged to consider other

potential partners who may participate but

may not directly receive funds

• WorkForce Centers

• Adult Basic Education Programs

• 4-year Universities

• Non-public schools and institutions

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The consortium must develop a single

local/regional plan

• The plan must address secondary basic grant

programs, postsecondary basic grant

programs, and former tech prep activities

• The plan must address all required Perkins

activities organized around five broad goals

• The plan must be signed by each

participating college president and each

participating school superintendent

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The consortium must identify one secondary

fiscal host and one postsecondary fiscal

host to receive and manage Perkins funds in

accordance with the local plan

• Consortium funds may not be commingled,

but may be used across

secondary/postsecondary lines

• The signed local plan is the legal document

governing use of the funds – no other joint

powers agreement is required

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Expectations of the Local

Consortium Perkins Coordinators

• Facilitate development of the local consortium plan

and budget

• Coordinate development and implementation of

programs of study and technical skill assessments

• Ensure submission of student data and accountability

report—Annual Performance Report (APR)

• Negotiate accountability performance targets

• Facilitate brokering with other consortia

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Expectations of the Local

Consortium Perkins Fiscal Hosts

• Manage the money per the agreements in

the consortium plan

• Sub-grant funds to other school

districts/colleges as appropriate and

according to the consortium plan

• Manage the draw-down of funds

• Responsible for accurate and timely

submission of fiscal information

• Maintain an audit trail25

Distribution of Perkins Funds to Local

Consortia

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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 3505.1700 27

Secondary/Postsecondary Split

MDE and MnSCU have negotiated a split

under which:

• 42% of funds are distributed to secondary

recipients, and

• 58% of funds are distributed to

postsecondary recipients.

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Secondary Distribution

The Perkins Act specifies that once the split is

determined, funds will be distributed to

secondary recipients on the following basis:

• 30% will be distributed on the basis of

individuals between the ages of 5 and 17

inclusive using the most recent US Census

data available

• 70% will be distributed on the basis of

individuals between the ages of 5 and 17

inclusive in households of poverty using the

most recent US Census data available 29

Postsecondary Distribution

The Perkins Act specifies that once the split is

determined, funds will be distributed to

postsecondary recipients on the following basis:

• 100% will be distributed on the basis of

individuals in career and technical education

programs receiving PELL or Bureau of Indian

Affairs assistance

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Reserve Distribution

The Perkins Act allows states to utilize an

alternate method to distribute up to 10% of

Perkins funds to address any of three factors:

1. rural areas; MN

2. areas with high percentages of career and

technical education students; and

3. areas with high numbers of career and

technical education students. MN

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Reserve Distribution

The state distributes:

• half of the reserve on the basis of the

geographic area of the consortium

• half of the reserve on the basis of the number

of CTE participants in secondary and

postsecondary programs, weighted 3:1 toward

secondary participation to reflect programming

formerly conducted under tech prep

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Reallocation:

Funds are received by the local consortium for the period of the state fiscal year only (July 1 through June 30). At the end of this period, unused funds are returned to the state.

33

The state will collect unused basic and reserve funds and will redistribute those funds to all local consortia on the basis of the distribution formula.

Unused secondary funds are reallocated to secondary basic and reserve; unused postsecondary funds are reallocated to postsecondary basic and reserve.

This occurs as early in the fall as possible.

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Reallocation:

• Redistributed funds will be handled as a separate Reallocated award.

• Funds will be used in accordance with the current year’s local plan – changes must be approved by state staff.

• Once reallocated, redistributed funds should be used before the current year funds – First In/First Out.

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Reallocation:

So, how much of the Perkins allocation

belongs to an individual district or

college?

Nada

Zilch

Nuttin’Notapenny

Perkins is not an entitlement!

Naught

Zip

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Minnesota relies on the language from Section

131(f)(2) of the Perkins Act which states:

"Funds allocated to a consortium ... shall be

used only for purposes and programs that

are mutually beneficial to all members of

the consortium .... Such funds may not be

reallocated to individual members of the

consortium for purposes or programs

benefitting only 1 member of the

consortium."

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Uses of Perkins CTE Funds

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General Authority

Each eligible recipient that receives funds under this part shall use such funds to improve career and technical education programs.

- Carl D. Perkins Career and Technical Education

Act, Section 135

improve

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Required Activities

The Act requires that certain activities be conducted within career and technical education programs if supported with federal funds. The Act does not require locals to use federal funds for these activities, but all required activities must be addressed in the local plan if Perkins funds are received.

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1. Integration of academics (or liberal arts

and sciences) with career and technical

education programs

2. Link CTE at the secondary and postsecondary

levels through at least one program of study

(MN State Plan requires at least 7/consortium

and as of FY14 at least one Rigorous Program

of Study)

3. Provide students with understanding of all

aspects of an industry

4. Develop, improve or expand the use of

technology in CTE

Required Activities

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5. Provide in-service and pre-service professional development

6. Develop and implement CTE programevaluations

7. Initiate, improve, expand and modernize quality CTE programs

8. Provide services that are of sufficient size, scope and quality to be effective

Required Activities

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9. Provide activities to prepare special populations for high-skill, high-wage, or high-demand occupations that will lead to self-sufficiency

Minnesota has two additional required activities:

10.Collaboration/Brokering of Service/Continuum of Services

11.Articulation, PSEO, Concurrent (Dual) Enrollment, or other recognized strategies

Required Activities

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Permissible Activities

The Act allows certain activities to be conducted within career and technical education programs IF required activities have been addressed.

IF

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1. Involving parents, businesses and labor organizations

2. Providing career guidance and academic counseling

3. Supporting local education and business partnerships

4. Providing programs [specifically designed] for special populations

Permissible Activities

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5. Assisting career and technical student organizations

6. Mentoring and support services

7. Leasing, purchasing or adapting equipment to support academic and technical skill attainment

8. Teacher preparation programs

Permissible Activities

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9. Developing and expanding postsecondary program offerings at times and in formats accessible for all, including distance learning

10.Develop initiatives to facilitate sub-baccalaureate to baccalaureate transfer

11.Support for entrepreneurship education and training

Permissible Activities

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Guidelines for Using Funds

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Local Administration

• Managing the money and managing the data

• May be supported by no more than 5% of consortium grant funds

• If the consortium sub-grants funds, the total of all administrative expenses may not exceed 5% of the consortium award

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Indirect Costs

Indirect costs are the assignable costs of items such as heat and light to an academic program, and those expenses that benefit the entire entity and, therefore, cannot be directly charged to a specific cost category or project activity.

Indirect costs are allowable, but must be included as part of the 5% administrative set-aside.

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Fiscal Host Responsibility

• Receive and safeguard grant funds on behalf of the consortium in accordance with state and federal requirements

• Maintain separate disbursement records and receipts, make financial records/documentation available

• Disburse funds in accordance with the grant

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Salaries for grant related activities – All time

must be documented on the Personnel Activity

Report. After 3 years the staff time must be

sustained by the district and the consortium

should show more funds going to new/

improved programming. Clerical support may

be charged to the grant when working on a

specific goal/objective and not administrative

activities.

Salaries for grant related activities –

Allowable costs:

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• Salaries for grant related activities – All time must be

documented on the Personnel Activity Report. After 3 years the staff time must be

sustained by the district and the consortium should show more funds going to

new/improved programming. Clerical support may be charged to the grant when

working on a specific goal/objective and not administrative activities.

Supplies – Workshop expenses, books or new

curriculum not previously offered, or program

specific to Perkins. You cannot replace

textbooks of an existing program. Promotional

items are not allowed.

Salaries for grant related activities –

Allowable costs:

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Travel costs – meal/lodging for travel to

professional development conferences is

allowable when info. is shared in order to

increase overall program quality.

Salaries for grant related activities –

Allowable costs:

Supplies –

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Equipment Inventories

All secondary equipment must be labeled as Perkins and listed annually on an Equipment Record

For postsecondary fiscal agents, the ISRS inventory must be updated annually

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Supplement, Not Supplant

Supplanting is the unlawful use of federal funds to displace state or local funds.

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Supplement, Not Supplant

Supplanting is determined on a case-by-case basis.

Federal funds cannot displace state or local funds, but a local entity may (in rare cases) use federal funds to support an activity if the local entity can prove that the activity would not have occurred without the federal expenditure.

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Supplement not Supplant – Federal funds may

not be used to pay for services, staff, programs or

materials that would otherwise be paid with state/

local funds. State/local funds must be used for all

activities that are the district/organization responsibility.

• Test #1 – Was the activity paid for in the prior year with

non-federal funds?

• Test #2 – Was the activity required by state/local law or

policy?

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ALWAYS check with the state before entertaining any spending decision that may be construed as supplanting!

If the district or the college can prove in the absence of federal funds it would have eliminated the activity, it may use the federal funds to support the activity, if allowable under Perkins.

ALWAYS

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Perkins CTE Financial Resources

Perkins Act P.L. 109-270

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

www.whitehouse.gov/omb/circulars_default

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Perkins CTE Financial Resources

Minnesota State Plan for

Career Technical Educationwww.cte.mnscu.edu/perkinsIV/MN_State_Plan/index.html

Minnesota Legislation and Rules

www.leg.state.mn.us/

Perkins IV Operational Handbook Section III p. 24

Financial Requirements

www.cte.mnscu.edu/consortium_resources/index

FAQs on CTE Website

www.cte.mnscu.edu/index.html

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FAQs on www.cte.mnscu.edu

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Enter your questions in the “Chat” field

OR request to unmute your phone line

and ask your questions.

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It helps us all do better.

Questions!

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MnSCU Career and Technical Education

www.cte.mnscu.edu/

Webinar recordings, presentation PowerPoints

www.cte.mnscu.edu/professionaldevelopment/

finance-and-accountability.html

MDE Office of Career and College Success

http://education.state.mn.us/MDE/StuSuc/CareerEd/index.html

Materials

Treatment of Money Detail-

SecondaryThursday, Sept. 24, 1pm

Treatment of Money Detail-

PostsecondaryMonday, Sept. 28, 1pm

Perkins Fiscal Webinars

CTE Webinar Series

www.cte.mnscu.edu/professionaldevelopment/finance-and-accountability.html

Perkins Consortium Coordinators MeetingSave the Date!

November 4, 2015

Normandale Community College

www.cteworksminnesota.org/registration/coordinators-meeting/

2015 CTE Works! Summit

Snapshots From MN Career Technical Education

Keynote: Emily Hanford, American RadioWorks

November 5, 2015

Sheraton West, Minnetonka, MN

www.cteworksminnesota.org

Upcoming Events

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available for teachers for this series of webinars (1 Hour per webinar). In

order to get the necessary certificates you MUST complete the session

evaluation.

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