What are allowable activities using Title II, Part A funds?
- Professional development for teachers, principals (other school leaders).
- Recruitment, selection, and hiring of the most promising educators.
- Payment of stipends/signing bonuses.
What are some examples of activities that are considered professional development?
- Conduct staff study groups at the school (e.g., pay stipends for staff, purchase books and materials, contract with speakers pertaining to the subject of the study).
- Pay for professional development costs associated with bringing a new supplemental program into the school.
- Pay staff stipends and benefits for curricular mapping activities and other standards-related activities.
- Hire instructional coaches to assist staff with instruction and assessment in reading and/ or math.
- Pay registration fees and travel expenses for trainings, within reason.
- Pay costs of substitute teachers while regular teachers are participating in professional development.
- Pay costs associated with bringing a speaker or consultant into the school to work with staff on data analysis.
Define “cost is unreasonable”. What is unreasonable and how is that defined?
The federal government defines reasonable costs: A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. The question of reasonableness is particularly important when governmental units or components are predominately federally funded. In determining reasonableness of a given cost, consideration shall be given to:
- Whether the cost is of a type generally recognized as ordinary and necessary for the operation of the governmental unit or the performance of the Federal award.
- The restraints or requirements imposed by such factors as: sound business practices; arm’s length bargaining; Federal, State and other laws and regulations; and, terms and conditions of the Federal award.
- Market prices for comparable goods or services.
- Whether the individuals concerned acted with prudence in the circumstances considering their responsibilities to the governmental unit, its employees, the public at large, and the Federal Government.
What is the definition of high quality professional development?
- Evidence based
- Raises student achievement
- Improves and changes teaching practices
- Addresses the needs of students with different learning styles
- Improves student classroom behavior
- Involves parents in the student’s education
- Addresses using data and assessments to improve classroom practice
- Is based on a needs assessmentIs ongoing and job-embedded
May LEAs use Title II, Part A funds to purchase supplies or instructional materials that are used as part of professional development activities?
Title II, Part A funds may be used to purchase materials and supplies if they are necessary for the professional development activities, including the materials (such as graphing calculators) that a teacher will need in order to apply the professional development in a classroom setting. However, Title II, Part A does not permit the use of program funds to purchase materials and supplies that are not directly connected to the teachers’ professional development.
When can Title II, Part A funds be used to pay teacher salaries?
Title II, Part A funds can, as part of an overall strategy to improve teacher quality, be used for teacher incentives (e.g., as stipends for teachers recruited to fill hard-to-fill positions or to retain teachers who have been effective in helping low-achieving students succeed) or to pay the salaries of master teachers who provide or coordinate professional development services for other teachers.
When can Title II, Part A funds be used to pay substitute teacher salaries?
(if, and only if)
- Using Title II, Part A funds is allowable if, and only if, the teachers are participating in Title II-funded “programs and activities that are designed to improve the quality of the teacher force, such as…innovative professional development programs…” [Section 2123(a)(5)(A)].
LEAs also must ensure that the hiring of these substitutes supplements, and does not supplant, the use of local and State funds they would otherwise be spending for such substitutes.
What is supplanting?
- Using federal funds to pay for a position that was previously supported by local and state funds;
- Using federal funds to pay for materials or activities that are the district’s responsibility;
- Using federal funds to pay for the activities or materials in one school that are paid for with state and local funds in other district schools.
What is the Rule of Supplement not Supplant?
Under the Federal “supplement not supplant” requirement, LEAs may use Federal funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of the Federal funds, be made available from non-Federal sources. In no case may a school district use Federal program funds to supplant—take the place of—funds from non-Federal sources.
Funds from Title programs are to be supplemental in nature.
- Using Federal funds to carry out activities mandated by local, state law or policy or other federal law violates the non-supplanting requirement.
- In no event shall LEAs decrease state or local funds for particular activities simply because Title II, Part A funds are available.
May LEAs use Title II, Part A funds to purchase supplies or instructional materials that are used as part of professional development activities?
Yes, but only if the expenditures, like any costs paid for by Federal program funds, are reasonable and necessary to carry out these activities.
May an LEA use Title II, Part A funds to pay out-of-area recruitment costs and moving expenses that may be needed in order to recruit and relocate new teachers?
Yes. There are circumstances in which the use of Title II, Part A funds to pay out-of-area travel and relocation costs would be reasonable and necessary to recruit individuals subsequently hired to meet an LEAs teacher shortage needs. To the extent that out-of-area recruitment itself is reasonable and necessary, relocation costs may be paid as a stipend or other financial incentive if, as with any cost the program would assume, the incentives are reasonable and necessary.
When may an LEA use Title II, Part A funds for programs to recruit and retain pupil services personnel (e.g., guidance counselors)?
An LEA may use Title II, Part A funds for these activities, but only if the LEA is making progress toward meeting the annual measurable objectives described in Title I, Section 1119(a)(2) of ESEA, and in a manner consistent with mechanisms to assist schools in effectively recruiting and retaining effective teachers and principals.
May LEAs use Title II, Part A funds to provide training to enhance the involvement of parents in their child’s education?
Yes, LEAs may use program funds to provide training to enhance the involvement of parents in their child’s education parental involvement is best encouraged through regular, two-way, and meaningful communications about student learning and other school activities. Effective strategies may include (1) promoting the understanding that parents are true partners in their children’s education and communicating the need for parents to help their children succeed in school, and (2) providing parents with specific suggestions, on an ongoing basis, about ways to encourage learning at home and ways to be actively involved in their child’s education at school.
May schools and districts use Title II, Part A funds to pay for the cost of attending out-of-state conferences?
If attending a conference is necessary to achieve the goals and objectives of the grant, and if the expenses are reasonable, Title II, Part A funds may be used to pay for travel expenses.
May a grantee receiving funds from the U.S. Department of Education use its Federal grant funds to host a meeting or conference?
Yes. Federal grant funds may be used to host a meeting or conference if doing so is:
- Consistent with its approved application or plan;
- For purposes that are directly relevant to the program and the operation of the grant, such as for conveying technical information related to the objectives of the grant; and
- Reasonable and necessary to achieve the goals and objectives of the approved grant.
What are examples of “technical information” that may be conveyed at a meeting or conference?
Examples of technical information include, but are not limited to, the following, each of which must be related to implementing the program or project funded by the grant:
- Specific programmatic, administrative, or fiscal accountability requirements;
- Best practices in a particular field;
- Theoretical, empirical, or methodological advances in a particular field;
- Effective methods of training or professional development; and
- Effective grant management and accountability.
What factors should a grantee consider when deciding whether to host a meeting or conference?
Grantees should consider whether a face-to-face meeting or conference is the most effective or efficient way to achieve the desired result and whether there are alternatives, such as webinars or video conferences, that would be equally or similarly effective and more efficient in terms of time and costs than a face-to-face meeting. In addition, grantees should consider how the meeting or conference will be perceived by the public; for example, will the meeting or conference be perceived as a good use of taxpayer dollars?
Using Federal Grant Funds to Pay for Food and Travel
When a grantee is hosting a meeting, may the grantee use Federal grant funds to pay for food, beverages, or snacks?
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 grantee is hosting a meeting, the grantee should structure the agenda for the meeting so that there is time for participants to purchase their own food, beverages, and snacks. In addition, when planning a meeting, grantees 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. Grantees, therefore, will have to make a compelling case that the unique circumstances they have identified would justify these costs as reasonable and necessary.
May Federal grant funds be used to pay for food and beverages during a reception or a “networking” session?
In virtually all cases, using grant funds to pay for food and beverages for receptions and “networking” sessions is not justified because participation in such activities is rarely necessary to achieve the purpose of the meeting or conference.
May a grantee enter into a contract with a hotel under which Federal grant funds will be used to provide meals, snacks, and beverages as part of the cost for meeting rooms and other allowable conference-related costs?
Federal grant funds may only be used for expenses that are reasonable and necessary. In planning a conference or meeting and negotiating with vendors for meeting space and other relevant goods and services, grantees may only pay for allowable costs. If a hotel vendor embeds food and beverage costs into a hotel contract for meeting space, the grantee should work with the hotel to have the food and beverage costs identified and “backed out” of the contract, and have the price they are paying for meeting space appropriately adjusted to reflect the fact that food and beverages are not being purchased. The fact that food and beverages are embedded in a contract for meeting space does not mean that the food and beverages are being provided at no cost to the grantee.
What if a hotel or other venue provides “complimentary” beverages (e.g., coffee, tea) and there is no charge to the grantee hosting the meeting?
The grantee has an obligation, under these circumstances, to confirm that the beverages are truly complimentary and will not be reflected as a charge to the grant in another area. For example, many hotels provide complimentary beverages to all guests who attend a meeting at their facility without reflecting the costs of those beverages in other items that their guests or, in this case, the grantee purchases. As noted above, it would not be acceptable for a vendor to embed the cost of beverages in other costs, such as meeting space.
May indirect cost funds be used to pay for food and beverages?
The cost of food and beverages, because they are easily associated with a specific cost objective, such as a Department grant, are properly treated as direct costs, rather than indirect costs. As noted above, Federal grant funds cannot be used to pay for food and beverages unless doing so is reasonable and necessary.
May Federal grant funds be used to pay for alcoholic beverages?
No. Use of Federal grant funds to pay for the cost of alcoholic beverages is strictly prohibited.
May a grantee use non-Federal resources (e.g., State or local resources) to pay for food or beverages at a meeting or conference that is being held to meet the goals and objectives of its grant?
Grantees should follow their own policies and procedures and State and local law for using non-Federal resources to pay for food or beverages, including its policies and procedures for accepting gifts or in-kind contributions from third parties. However, if non-Federal funds are used to pay for food at a grantee-sponsored meeting or conference, the grantee should make clear through a written disclaimer or announcement (e.g., a note on the agenda for the meeting) that Federal grant funds were not used to pay for the cost of the food or beverages. Grantees should also be sure that any food and beverages provided with non-Federal funds are appropriate for the grantee event, and do not detract from the event’s purpose.
May grantees provide meeting participants with the option of paying for food and beverages (e.g., could a grantee have boxed lunches provided at cost for participants)?
Yes. Grantees may offer meeting participants the option of paying for food (such as lunch, breakfast, or snacks) and beverages, and arrange for these items to be available at the meeting.
Using Federal Grant Funds to Pay for Costs of Attending a Meeting or Conference Sponsored by ED or a Third Party
May grantees use Federal grant funds to pay for the cost of attending a meeting or conference?
If attending a meeting or conference is necessary to achieve the goals and objectives of the grant, and if the expenses are reasonable (based on the grantee’s own policies and procedures, and State and local laws), Federal grant funds may be used to pay for travel expenses of grantee employees, consultants, or experts to attend a meeting or conference. To determine whether a meeting or conference is “necessary,” grantees should consider whether the goals and objectives of the grant can be achieved without the meeting or conference and whether there is an equally effective and more efficient way (in terms of time and money) to achieve the goals and objectives of the grant (see question #3). To determine whether the expenses are “reasonable,” grantees should consider how the costs (e.g., lodging, travel, registration fees) compare with other similar events and whether the public would view the expenses as a worthwhile use of Federal funds.
What should a grantee consider when planning to use Federal grant funds for attending a meeting or conference?
Among other considerations, grantees should consider how many people should attend a meeting or conference on its behalf. The number of attendees should be reasonable and necessary to accomplish the goals and objectives of the grant. The grantee should also determine whether it is necessary to attend the entire meeting or conference, or whether attending only a portion of the meeting or conference is reasonable and necessary.
What travel expenses may be paid for with Federal grant funds?
Grantees may use Federal grant funds for travel expenses only to the extent such costs are reasonable and necessary and do not exceed charges normally allowed by the grantee in its regular operations consistent with its written travel policies. In the absence of an acceptable written policy regarding travel costs, grantees must follow the Federal travel and subsistence rates established by the General Services Administration. Federal grant funds may be used to pay expenses for transportation, per diem, and lodging if the costs are reasonable and necessary.
What resources are available to help grantees determine whether costs associated with meetings and conferences are reasonable and necessary?
Grantees must follow all applicable statutory and regulatory requirements in determining whether costs are reasonable and necessary, especially the U.S. Office of Management and Budget’s Cost Principles for Federal grants located at: 2 CFR Part 200 Uniform Administrative Requirements, cost principles, and Audit Requirements for Federal Awards
May Federal grant funds be used to pay for entertainment?
No. Federal grant funds may not be used to pay for entertainment, which includes costs for amusement, diversion, and social activities.
Is it allowable for a person whose travel costs are being paid with Federal grant funds to attend a conference in Washington, DC, and lobby members of Congress while in town?
Appropriated funds may not, except under very limited circumstances, be used for expenses related to any activity designed to influence the enactment of legislation, appropriations, regulations, administrative actions, or Executive Orders proposed or pending before the Congress or the Administration. To the extent that a portion of time at a conference is spent on lobbying activities, costs associated with the lobbying, including transportation to and from Washington, DC, lodging, and per diem, may not be charged to the Federal grant. For example, if a meeting or conference lasts for two days and a visit to lobby a member of Congress requires an additional day of travel, 1/3 of all costs involved in attending the meeting or conference, including travel to and from Washington, DC, may not be charged to the grant.
What are the consequences of using Federal grant funds for unallowable expenses?
The Department may seek to recover any Federal grant funds for activities deemed to be ineligible under program guidelines.
What are the requirements for conducting a needs assessment?
The law states that the needs assessment must reflect the needs for professional development “as identified by the (LEA) and school staff,” and requires the LEA to conduct its needs assessment “with the involvement of teachers”. How it does so (e.g., through surveys, focus groups, and other means of collecting data) is left to the LEA and its staff to decide.
What is the purpose of the needs assessment?
The purpose of the needs assessment is to determine the needs of the LEA’s teaching force as a basis for continuous improvement and ensuring that all students meet challenging State content and academic achievement standards. An LEA may want to use information such as student achievement data, information about numbers of teachers (disaggregated by subject taught, grade level, and effectiveness rating), assessments by administrators and mentor teachers who evaluate teacher and student performance, and teacher self-evaluations.
What must be addressed in the LEA Title II, Part A plan?
Section 427 of the General Education Provisions Act (20 U.S.C. §1228a(a)) requires each LEA to include in its application for Title II, Part A funds a description of the steps the applicant proposes to take to ensure equitable access to, and participation in, its Federally-assisted program for students, teachers, and other program beneficiaries with special needs.
Who should participate in the needs assessment?
LEAs are required to meaningfully consult with teachers, principals and other school leaders, paraprofessionals, specialized instructional support personnel, charter school leaders, parents, community partners, and other organizations or partners with relevant and demonstrated expertise in programs and activities designed to meet the statutory purpose of Title II, Part A.
Private/Non Public Schools (PNP)
Are quarterly consultation meetings required?
Yes, New Mexico School Districts are required to provide PNP schools with timely and meaningful opportunity for consultation. The Quarterly Consultation Meetings provide the forum to meet this requirement.
During consultation, PNP schools are encouraged to share their professional development needs and provide feedback on Title II Part A services.
Do campuses have to attend an individual quarterly consultation meeting?
New Mexico School Districts are required to provide PNP schools with timely and meaningful opportunity for consultation. Attendance is recommended because the needs of PNP schools may change throughout the year and programs may need to be adjusted to reflect those changes. PNP schools may choose not to attend each quarterly consultation meeting if they feel that their needs are being adequately addressed. However, if a PNP school chooses not to participate in an individual consultation meeting, then the New Mexico School District requests that an email be sent stating that the PNP school’s needs are currently being addressed and that no changes to the current program are needed. This will help to ensure that the PNP school’s needs are not inadvertently overlooked.
Can you provide quarterly budget balances for each school and the Department of Catholic Schools (DCS)?
Quarterly budget balances for each school and the DCS will be shared and discussed at individual quarterly consultation meetings. In addition, budget balances are available to each school and the DCS at any time. Balances will be provided via email upon request.
Can Title I Part A funds be used to pay for substitutes for private school teachers to attend PD?
Title I or II Part A funds may not be used to pay for PNP substitutes or PNP teacher salaries.
Are teachers eligible to receive stipends for attending PD that occur beyond their normal contracted hours?
Teachers are eligible to receive a stipend from their school’s Title II Part A budget allocation for attending professional learning sessions that occur beyond their normal contracted hours if it meets the needs of the PNP school and is reasonable and necessary.
Is there a limit on the stipend amount?
Title II, Part A funds may be used to pay stipends for private school teachers if stipends are reasonable and necessary to carry out the objectives of the grant and are fair and equitable.