Federal and State Programs Allowable Use FAQ



Office of Educational SupportsFederal and State Programs Allowable UseFrequently Asked QuestionsDisclaimer: The information contained within this document regarding Federal programs is based on the Elementary and Secondary Education Act of 1965 (ESEA) as amended by the Every Student Succeeds Act of 2015 (ESSA) and related Federal guidance and regulations. The full text of ESEA can be found on the USED website.The information contained within this document regarding State programs is based on current State law.If any of the information contained within this document contradicts current law or regulations, the current law and regulations shall supersede the information provided in this document. TOC \o "1-3" \h \z \u General Questions PAGEREF _Toc45009681 \h 2Q1What types of activities are generally allowable under each of the Federal and State programs? PAGEREF _Toc45009682 \h 2Professional Development/Professional Learning (PD) PAGEREF _Toc45009683 \h 2Q1May Local Educational Agencies (LEAs) use Federal funds for professional memberships? PAGEREF _Toc45009684 \h 2Q2May LEAs use Federal funds to reimburse employees for meal costs when attending a PD activity when an overnight stay is required? PAGEREF _Toc45009685 \h 2Q3May LEAs use Federal funds to reimburse employees for meal costs when attending a PD activity when an overnight stay is not required? PAGEREF _Toc45009686 \h 2Q4May LEAs use Federal funds to pay for food or beverage costs when hosting a PD activity? PAGEREF _Toc45009687 \h 3Recruitment, Retention, Performance-based pay, and Advancement and Professional Growth PAGEREF _Toc45009688 \h 3Q1.What is the difference between recruitment, retention, performance-based pay, and advancement and professional growth? PAGEREF _Toc45009689 \h 3Q2.May LEAs use Title II, Part A funds for costs related to recruitment, retention, or performance-based pay? PAGEREF _Toc45009690 \h 4Q3.May LEAs use Title II, Part A funds for costs related to paraprofessional, teacher, principal or other school leader advancement and professional growth? PAGEREF _Toc45009691 \h 5Q4.What must be considered to use recruitment, retention, performance-based pay, or advancement and professional growth strategies? PAGEREF _Toc45009692 \h 5Q5.What types of activities can be funded as part of a recruitment, retention, performance-based pay, or advancement and professional growth strategy? PAGEREF _Toc45009693 \h 2General QuestionsQ1What types of activities are generally allowable under each of the Federal and State programs?A1Please see the Generally Allowable Use of Funds document for a broad overview of the types of activities allowable under each of the Federal and State programs.Professional Development/Professional Learning (PD)Q1May Local Educational Agencies (LEAs) use Federal funds for professional memberships?A1Professional memberships are allowable in Federal programs if they provide resources to members which could be considered PD opportunities. The need for the professional membership must align with the identified local needs addressed in the District Improvement Plan. The cost for the membership must be budgeted using object code 7410 under “Other Expenses” with the specific name of the membership included in the Budget Detail description. For additional information please see the Function and Object Code FAQ document.Q2May LEAs use Federal funds to reimburse employees for meal costs when attending a PD activity when an overnight stay is required?A2Reimbursement for meal costs are allowable in Federal programs when attending a PD activity requires an overnight stay by the participating employee(s). When an overnight stay is required, Federal funds may be used to pay for all travel costs, including meals, if the costs are reasonable, necessary, and approved in the grant budget. LEAs must be sure to follow their own travel and per diem rules when using Federal funds to pay for travel.Q3May LEAs use Federal funds to reimburse employees for meal costs when attending a PD activity when an overnight stay is not required?A3Generally, there is a very high burden of proof to show that reimbursement for meals with Federal funds is necessary to meet the goals and objectives of a Federal grant when an overnight stay is not required. 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. LEAs, therefore, will have to make a compelling case that the unique circumstances they have identified would justify these costs as reasonable and necessary.Federal funds may be used to cover other non-meal related costs (mileage, parking, tolls, etc.) to support participation of the employee at the PD activity. The LEA can also consider using non-Federal resources to pay for meals at the meeting or conference if the costs are consistent with the LEA’s policies and procedures for using non-Federal resources to pay for meals. If Federal funds are used to reimburse meals where an overnight stay is not required, such costs would be considered fringe benefits and, in most cases, would need to be budgeted as salaries and benefits to ensure the appropriate tax treatment of the payment to the employee. LEA’s must ensure applicable tax law is followed in such cases.Q4May LEAs use Federal funds to pay for food or beverage costs when hosting a PD activity?A4Generally, 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 LEA is hosting a meeting, the LEA 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, LEAs 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. LEAs, therefore, will have to make a compelling case that the unique circumstances they have identified would justify these costs as reasonable and necessary.For additional information please see the Frequently Asked Questions on Using Federal Funds for Conferences and Meetings document.Recruitment, Retention, Performance-based pay, and Advancement and Professional GrowthQ1.What is the difference between recruitment, retention, performance-based pay, and advancement and professional growth?A1.Recruitment: Includes strategies designed to assist a LEA with hiring new teachers, principals, or other school leaders that were previously working in non-teaching professions, recent graduates of institutions of higher education, or working in other LEAs.Retention: Includes strategies designed to assist a LEA with keeping currently employed and effective teachers, principals, or other school leaders.Performance-based Pay: Includes strategies to reward effective teachers, principals, and other school leaders as determined by the locally adopted teacher and administrator evaluation systems.Advancement and Professional Growth: Includes strategies to support currently employed and effective paraprofessionals, teachers, principals, and other school leaders to enhance their skills and move into a new educational role within the same LEA. (Paraprofessional to Teacher, Teacher to Administrator, Principal to Superintendent)Q2.May LEAs use Title II, Part A funds for costs related to recruitment, retention, or performance-based pay?A2.Yes. The Title II, Part A program is designed, among other things, to provide students from low-income families and minority students with greater access to effective teachers, principals, and other school leaders. [ESEA Section 2001(4)] In a case where the root cause analysis demonstrated that appropriate incentives were not in place to help ensure that excellent educators are attracted to and remain in high-need schools, Title II, Part A funds could be used to incentivize and reward excellent educators serving in those schools. An LEA might also consider other specific strategies designed to provide such students greater access to effective teachers, principals, and other school leaders. [ESSA Title II, Part A Guidance – Supporting Educators, pg. 21, Sept. 27, 2016]Schools in an LEA that meet both of the following criteria may be eligible for the implementation of recruitment, retention, or performance-based pay strategies [ESEA Section 2103(b)(3)(B), ESEA Section 1111(g)(1)(B)]:Have a significant population of low-income or minority children, andHave a high percentage of students not meeting the challenging State academic standards.The school must also meet at least one of the following three criteria:Have a high percentage of ineffective teachers or administrators [MCL 380.1249 and MCL 380.1249b], orHave a high percentage of out-of-field teachers (working under a substitute permit, temporary teacher employment authorization, or interim teaching certificate), orHave a high percentage of inexperienced teachers or administrators (within the first 3 years of employment [MCL 380.1526]).Additionally, the teacher(s), principal(s) or other school leader(s) involved must have received a rating of either “Effective” or “Highly Effective” [ESEA Section 2103(b)(3)(B), MCL 380.1249(1)(c)(ii) and MCL 380.1249b]If an incentive is included in a board policy or contract, the policy or contract must state that receipt of the incentive is based upon the availability of federal funds. Title II, Part A incentive pay must be supplemental and cannot be offered using Title II, Part A funds to some staff if it is available to other staff within the LEA using general funds or other local resources. [ESEA Section 2301]An LEA utilizing such incentives must monitor and evaluate the use of the incentive at least annually to show how the use of the incentive has improved access for low-income and minority students to effective teachers, principals, and other school leaders and make such information readily available to the public. [ESEA Section 2104]Q3.May LEAs use Title II, Part A funds for costs related to paraprofessional, teacher, principal or other school leader advancement and professional growth?A3.Yes. The Title II, Part A program is designed, among other things, to increase the number of teachers, principals, and other school leaders who are effective in improving student academic achievement in schools. [ESEA Section 2001(3)] In a case where the root cause analysis demonstrated a limited supply of teachers willing to work and remain in high-need schools, or leaders willing to serve in those schools, Title II, Part A funds could be used to support training or incentives to existing staff to support advancement and professional growth with an emphasis on leadership opportunities. [ESEA Section 2103(b)(3)(B)(iii)].Sample programs may include training programs to equip paraprofessionals to become teachers, development of hybrid teacher/leader and leadership positions, training programs to equip teachers to become school leaders or to receive additional certifications in high need-need areas, and programs that equip principals to assume other school leadership responsibilities. [ESSA Title II, Part A Guidance – Supporting Educators, pg. 23, Sept. 27, 2016]Such programs, with a primary focus of paraprofessional, teacher, principal or other school leader advancement, must meet the same criteria outlined above in Q&A 2 for costs related to recruitment, retention, or performance-based pay.Q4.What must be considered to use recruitment, retention, performance-based pay, or advancement and professional growth strategies?A4.The table below outlines the requirements for each type of strategy:?RequirementsRetention (Section 2103(b)(3)(B)(ii))Performance-based Pay (Section 2103(b)(3)(B)(ii))Advancement and Professional Growth (Section 2103(b)(3)(B)(iii))Recruitment- Fully Certified Teachers (Section 2103(b)(3)(B)(i))Recruitment - Alternative Routes to Certification (Section 2103(b)(3)(C))1Must meet Supplement not Supplant requirementsReqReq1ReqReqReq2LEA monitors and evaluates for impact at least annuallyReqReqReqReqReq3Payment is for activity in the program year and paid out during the program yearReqReqReqReqReq?The school has both:4A significant population of low-income and/or minority children, andReqReqReqReqOpt?A high percentage of students not meeting State academic standardsReqReqReqReqOpt?The school has at least one of the following:?A high percentage of ineffective teachers or administrators, orReqReqReqReqOpt5A high percentage of out-of-field teachers, orReqReqReqReqOpt?A high percentage of inexperienced teachers or administratorsReqReqReqReqOpt6The individual received a rating of "Effective" or "Highly Effective"ReqReqReqReqN/A7Individual is already employed by the district as a paraprofessional, teacher, principal, or other school leadersReqReqReqNoNo8Prospective individual is eligible for enrollment in an alternative route programN/AN/AN/AOpt2ReqReq – RequiredOpt – OptionalNo - Not allowedN/A – Not Applicable1 Performance-based Pay must be in excess of any amount paid under MCL 380.12502 Required if adding a certification through an alternative route program to fill an eligible vacancyQ5.What types of activities can be funded as part of a recruitment, retention, performance-based pay, or advancement and professional growth strategy?A5.The table below outlines sample allowable and non-allowable activities for each type of strategy:Sample CostsRetention (Section 2103(b)(3)(B)(ii))Performance Based Pay (Section 2103(b)(3)(B)(ii))Advancement and Professional Growth (Section 2103(b)(3)(B)(iii))Recruitment- Fully Certified Teachers (Section 2103(b)(3)(B)(i))Recruitment - Alternative Routes to Certification (Section 2103(b)(3)(C))Supplemental Salary and Benefits Costs (Hiring Bonus, Incentive Pay, Stipends, etc.) [2 CFR 200.430(f)]YesYesYesYesYesReimbursement for Certification Training Program Costs (Tuition, Fees, Travel Costs) [2 CFR 200.432, 2 CFR 200.466]N/AN/AYesYes1YesEligible Employee Relocation Expense Reimbursement [2 CFR 200.464]N/AN/AN/AYesYesLEA Attendance at Job Fairs (Registration, Materials, Travel Costs) [2 CFR 200.463]N/AN/AN/AYes2Yes2Advertising and Promotion of Job Openings [2 CFR 200.463]N/AN/AN/AYes2Yes2Expert help in screening candidates [2 CFR 200.459]N/AN/AN/AYes2Yes2Michigan Test for Teacher Certification [ESEA Section 2301]NoNoNoNoNoTeacher or Administrator Certification Application or Renewal Costs [ESEA Section 2301]NoNoNoNoNoPerks, Gifts and Tangible Material Rewards [2 CFR 200.421(e)(3) and 2 CFR 200.445]NoNoNoNoNo1 Costs are allowable only for added certification to support employment in an eligible vacancy2 Costs are only allowable to the degree that they support the filling of eligible vacancies ................
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