Career Technical Education

1
Then - 1998 Perkins Intent
On Perkins Flexibility I would like to ask the
Members here today how many of them would like to
have a partner in their business that provides 7
percent of the capital and wants to run the
business? We provide about 7 percent of the
money in this country for vocational education,
and here we sit in Washington and want to say how
it is best to do it in all 50 States, and we
provide 7 percent. We ought to be ashamed of
ourselves. If there is one message that I have
received from educators as a local leader, as a
State house member and a State senator, was get
Washington out of our school districts. We get a
little bit of money from them, and most of our
people are spending the bulk of their time trying
to deal with Federal bureaucracies and Federal
rules. Rep. John Petersen (R-PA)Congressional
Record, page H5537July 22, 1997
2
Now - 2006 Perkins Intent
(b) LOCAL PROGRAM IMPROVEMENT. (1) LOCAL
EVALUATION.Each eligible agency shall evaluate
annually, using the local adjusted levels of
performance described in section 113(b)(4),the
career and technical education activities of each
eligible recipient receiving funds under this
title. (2) PLAN. (A) IN GENERAL.If, after
reviewing the evaluation, the eligible agency
determines that an eligible recipient is not
making substantial progress in achieving the
local adjusted levels of performance, the
eligible agency shall
3
Can I fund this? VTEA funding under scrutiny
What can we fund?

• CCCAOE
• Thursday, March 16, 2006
• Chuck Wiseley

4
Agenda

• Update
• Reauthorization
• Electronic submission status
• Perkins
• Intent
• Regulations
• Review of Managing Perkins Funds I-II
• Appropriate uses
• Documenting use
• Questions
• Frequently asked questions/scenarios
• Questions from participants

5
Fall 2004 Crystal Ball

• 109th Congress
• Some changes in Accountability
• Strengthened
• Common measures
• Wage gain
• Negotiated performance state grantee

6
Reauthorization of the Carl D. Perkins Act

• October 2005 GEPA
• Lack of urgency for legislation
• Funding proposals
• Zero 1.3 billion
• Deficit Reduction Act of 2005 - Katrina
• H.R. 366 and S.250
• Similarities
• Strengthened accountability
• Continuous substantial improvement
• Link secondary post-secondary
• Link funds to improvements
• Differences
• State admin funds from 5 to 2 (HR)
• Tech Prep funding stream

7
Electronic Year To Date Expenditure and Progress
Reports

• Electronic Submissions Only - No Hard Copy
• Web Based   
• VTEA I-C Q3 (2003-4)
• Tech Prep Q1 (2004-5)
• Apprenticeship
• July 2006
• Nursing

8
Funding Flow Changes

• Reimbursement program
• CCC used Apportionments
• Complex
• Estimated expenditures
• Web-based YTD
• Use as an invoice
• Supplimental apportionment payment

9
Agenda

• Update
• Reauthorization
• Electronic submission status
• Perkins
• Intent
• Regulations
• Review of Managing Perkins Funds I-II
• Appropriate uses
• Documenting use
• Questions
• Frequently asked questions/scenarios
• Questions from participants

10
Perkins Funds

• Reasons for separate funding stream
• Show that society values the activity
• Supplement to strengthen area funded
• Risk of a separate funding stream
• Normal funds available will evaporate
• Supplanting rule

11
Intent of 1998 Perkins
On Perkins Goals Far too long we paid little
attention to the 75 percent of youths who do not
go on and complete some 4-year college degree.
Our youth should receive a high quality education
no matter what they plan to do in the future. In
todays vocational-technical education programs,
students need a very high-quality education for
todays world. These students need strong
academics and relevant skills in order to thrive
in todays economy. In H.R. 1853, we have three
overarching goals strengthening academics
broadening the opportunities for
vocational-technical education students and
sending more money to the classroom. Chairman
Bill Goodling (R-PA) Congressional Record, page
5414 July 17, 1997
12
Intent of 1998 Perkins (continued)
On Perkins Flexibility I would like to ask the
Members here today how many of them would like to
have a partner in their business that provides 7
percent of the capital and wants to run the
business? We provide about 7 percent of the
money in this country for vocational education,
and here we sit in Washington and want to say how
it is best to do it in all 50 States, and we
provide 7 percent. We ought to be ashamed of
ourselves. If there is one message that I have
received from educators as a local leader, as a
State house member and a State senator, was get
Washington out of our school districts. We get a
little bit of money from them, and most of our
people are spending the bulk of their time trying
to deal with Federal bureaucracies and Federal
rules. Rep. John Petersen (R-PA)Congressional
Record, page H5537July 22, 1997
13
Intent of 1998 Perkins

• Flexibility
• Removed the prescriptiveness of 90 Act
• Replaced with required uses
• address needs of special population students
• Three new themes
• Strengthening Academics
• Broadening Opportunities
• Sending more funds to the classroom
• Increases Accountability
• Incentives and Sanctions

14
Looking to the future Act

• Districts above local targets on all CI
• Flexible
• Districts below local targets on one or more CI
• Improvement Plans
• Funds will need to be directed to improve low
  performance areas
• Technical assistance after two years

15
Basic criteria for expending funds

• Expenditures must
• Meet the purpose of the act
• Be necessary and reasonable
• Expenditures may not be used for
• General purposes
• Maintenance of existing programs

16
What federal rules apply to VTEA funds?

• Carl D. Perkins Vocational and Technical
  Education Act (VTEA)
• EDGAR (Education Department General
  Administration Regulations)

17
What federal rules apply to VTEA funds?
(Continued)

• OMB Circulars (Office of Management and Budget)
• Circular A-87 Cost Principals State and Local
• Circular A-21 Cost Principals Education
  Institutions
• Circular A-133 Single Audit Requirements
• Circular A-102 Grants and Cooperative Agreements
  with State and Local Governments
• Circular A-110 Uniform Administration
  Requirements for Grants and Agreements with
  Institutions of Higher Education, Hospitals and
  Other Non-Profit Organizations

18
What types of costs are generally considered
eligible?

• Administrative Costs (5)
• Personnel Services (time records)
• Operating Expenses
• Stipends
• Consultants
• Instructional Materials
• Travel
• Instructional Equipment

19
What costs are NOT eligible?

• Student expenses or direct assistance to students
  
• Entertainment
• Awards and memorabilia
• Individual memberships
• Membership with orgs. that lobby
• College tuition, fees, books
• Fines and penalties
• Insurance/self-insurance

• Expense that supplant
• Audits except single audit
• Contributions and donations
• Contingencies
• Facilities and furniture
• General advertising
• Alcohol
• Fund raising
• General administration
• See Notes Page for clarification

20
What are the requirements for VTEA Title IC
expenditures?

• Strengthen academic, voc. tech. skills of
  students
• Provide students with strong experience and
  understanding all aspects of the industry
• Develop expand use of technology
• Professional development

• Evaluate programs with emphasis in spec. pops.
• Initiate, improve, expand and modernize quality
  programs
• Be of sufficient, size, scope and quality
• Link secondary and postsecondary programs

21
May federal funds be used to support a program
that was supported last year with non-federal
funds?

• No. This would be supplanting.
• Exceptions
• Evaluated case-by-case
• If it would be impossible to continue the
  activity without the federal funds, then it may
  not be supplanting (OMB A-133 Compliance
  Supplement G,2.2)

22
What are the permissive uses of VTEA Title IC
funds?

• Involve parents, business and labor in planning
  operation
• Career guidance academic counseling
• Work-related experience
• Programs for spec. pops.
• Education business partnerships
• Voc. student organizations
• Mentoring support services

• Upgrading equipment
• Teacher prep. programs
• Improving and developing new vocational courses
• Family consumer science
• Adult vocational programs
• Job placement programs
• Non-traditional training employment
• Support other voc. programs

23
When are funds considered obligated?

• Type of Cost
• Equip Supplies..
• Work of Employees..
• Contracted Services.
• Utilities.
• Rental...
• Travel
• Conference Registration.

• Obligation Occurs
• Date of purchase order
• When work is done
• Date of written agreement
• When used
• When used
• When travel is taken
• When fee is paid

24
Why are these dates important?

• EDGAR says that a subgrantee of the state may not
  obligate funds until the later of
• The date when the state may obligate funds, or
• The date that the subgrantee submits its
  application to the state in substantially
  approvable form

25
What do auditors look for?

• Financial Statements Expenditure Records
• Internal Controls
• Compliance with Laws and Regulations

See Notes Page for clarification.
26
What do auditors look for?

• Expenditures are documented and allowable
• Compliance issues
• Program offerings
• Student participation
• Assessment
• Funds supplement and not supplant
• Time distribution records
• Minimal time between draw down expenditure no
  cash on hand

• Procurement methods provide free open
  competition and prevent conflict of interest
• Equipment locatable and inventoried
• Obligations incurred in time frame
• Expenditures are budgeted

See Notes Page for clarification.
27
What are the rules on VTEA equipment purchase
inventory?

• Equipment is defined as having a purchase price
  of 200 or more and a useful life of more than
  one year
• Equipment shall be maintained in a trace
  inventory system if the equipment is worth 5,000
  or more and has a useful life of more than one
  year
• Equipment shall be identified as having been
  purchased with VTEA funds

28
What is included in equipment records?

• Description
• Manufacturers serial number or other ID number
• Source, including the award number
• Title vested in the recipient or the federal
  government
• Acquisition date
• Percentage of Federal participation in equipment
  cost
• Location and condition, date information was
  recorded
• Unit acquisition cost
• Date of last physical inventory

29
What are the rules on VTEA equipment use and
disposition?

• May not be used to compete unfairly with business
• When no longer needed for original purpose or
  other federal programs
• Current fair market value of 5,000 or less, can
  keep or dispose of with no strings attached
• Current fair market value of more than 5,000
  may retain or sell the equipment as long as the
  Federal agency is provided compensation
• Project Monitor must be notified when equipment
  is being sold, traded or transferred from one
  program to another

30
What are the rules on using VTEA funds for
travel?

• Current Federal per diem allowances
• Varies by location. Per diem current rates
• http//policyworks.gov/org/main/mt/homepage/mtt/pe
  rdiem/travel.htm
• Current California per diem allowances
• Lodging costs with receipt
• Meals breakfast - 6.00 lunch - 10.00 dinner
  - 18.00 incidentals - 6.00/day
• Reimbursement governed by college governing board

31
Where can I find The Rules?

• State Budget and Accounting Manual (BAM)
• http//www.cccco.edu/divisions/
• cffp/fiscal/standards/budget_and_accounting_page.h
  tm
• EDGAR - Education Department General
  Administrative Regulations
• http//www.ed.gov/policy/fund/reg/edgarReg/edlite-
  table.html
• OMB Circulars
• www.whitehouse.gov/omb/circulars
• Federal Register
• http//www.gpoaccess.gov/fr/index.html

32

• Federal Legislation
• http//thomas.loc.gov
• US Department of Education
• www.ed.gov
• Presidents proposal for Secondary and
  Postsecondary Education Reform
• http//www.ed.gov/
• about/offices/list/ovae/pi/reauth/perkins.html

33
Scenario 1

• Our college started a welding program at a
  satellite site two years ago. Funds used for
  this program were not VTEA. This year the
  satellite site program is being considered for
  elimination due to budget cuts. May we use VTEA
  funds to fund the program?

34
Why might this be an audit exception?

• Supplanting using VTEA funds to off set other
  college funding sources.
• The decrease in use of state funds and the
  subsequent increase in VTEA dollars for a
  particular program would trigger a presumption of
  supplanting.

35
Scenario 1 Answer

• Depends.
• Supplanting presumption is rebuttable if the
  college can demonstrate that the services in
  question would not have been provided if federal
  dollars were not available. In other words,
  document that there were no other sources of
  funds to sustain the program. (OMB A-133
  Compliance Supplement G,2.2)
• Documentation budget meeting minutes where
  decisions were made to eliminate program.

36
Ask yourself this question when you are unsure
about an activity that you want to fund with VTEA

• What would happen if I did not have any VTEA
  funds?
• Would the activity disappear?
• Yes, may consider using VTEA funds.
• Would the program be discontinued?
• Yes, may consider using VTEA funds.
• Could I fund the activity/program with other
  funds?
• If yes, then do not use VTEA funds.

37
Scenario 2

• The college is upgrading computers across the
  campus on a three year cycle. May we fund
  computer upgrades for the vocational programs
  using VTEA funds?

38
Scenario 2 Answer

• No
• Three year funding cycle implies ongoing use of
  VTEA funds to accomplish something that other
  funds should be used to do.
• VTEA funds should be used for program improvement
  or enhancement.
• Vocational programs should benefit from use of
  other college fund sources same as other
  programs.
• Use of VTEA funds only could be considered
  supplanting.

39
Scenario 3

• We would like to pay for an economically
  disadvantaged students uniform and nurse
  assistant certification examination. Would it be
  appropriate to use VTEA funds for this purpose?

40
Scenario 3 Answer

• Yes, Perkins funds may be used under the four
  very narrow conditions spelled out in May 27,
  1999 OVAE program memorandum 99-13
• Specifically, for this example, assistance only
  being provided to an individual to the extent
  that it is needed to address barriers to the
  individuals successful participation in
  vocational and technical education

41
Scenario 3 Answer

• Sec 135 Local Uses of funds - Permissive (c)(13)
  to provide assistance to students who have
  participated in services and activities under
  this title in finding an appropriate job and
  continuing their education.
• Ensure that the supplement/not supplant
  requirements contained in General Provisions -
  section 311(a) of Perkins are not being violated.

42
Scenario 4

• May we use VTEA funds to pay for a CCCAOE
  membership for our Occupational Dean?

43
Scenario 4 Answer

• No, individual memberships are considered gifts
  of public funds.
• You may pay for an institutional membership for
  an organization.

44
Scenario 5

• Our Horticultural program needs a new greenhouse.
  
• May we use VTEA funds to build the greenhouse?

45
Scenario 5 Answer

• No, capital expenditures for improvements to
  land, buildings, or equipment which materially
  increase their value or useful life are
  unallowable.

46
Questions?
47
discussion of common barriers to funding
improvement