To Buy or Not To Buy

Guiding Questions

  • Does the purchase support a goal/objective in our grant?
  • Does it support an activity specified in our grant?
  • Is it consistent with special conditions imposed on the grant by USDE (such as no purchases of food, furniture, incentives, etc.)
  • Is it consistent with Title IV, Part B and other statutes and regulations governing 21CCLC?

Non Regulatory Guidance and Legislation

Regulations

U.S. Education Department’s 21CCLC Non-Regulatory Guidance

  • Provides clarification for statutes
  • Does not carry the weight of laws or regulations

Basic Guidelines

All Costs Must Be:

  1. Necessary
  2. Reasonable
  3. Allocable
  4. Legal under state and local law
  5. Conform with federal law & grant terms
  6. Consistently treated
  7. In accordance with GAAP
  8. Not included as match
  9. Net of applicable credits
  10. Adequately documented

Before submitting request - ask yourself the following:

  1. Does the program really need this?
  2. Is this a reasonable amount and can it be demonstrated?
  3. Can I justify the need with the terms of our grant?
  4. Do the program have the capacity to make the best use of this purchase?
  5. Will program participants benefit from this purchase?
    • Example: Purchasing materials & supplies or equipment at the end of the project year is not allocable. Purchases need to benefit the students of that program year.
  6. Did you charge 21st CCLC in proportion to the value received by the program?
    • Example: Site purchases printers to use 50% in the 21st CCLC program and 50% in another federal program – can only charge half the cost to 21st CCLC
  7. Is it Legal under State and Local Law?
    • If you can’t do it under state law, you can’t pay for it with federal funds i.e., purchasing food
  8. Does it conform with applicable laws, regulations, & the terms of our grant

You must answer “Yes” to all of the questions.

Adequately Documented - No documentation means it didn’t happen.

  • Some Examples
    • Aligned to approved application and budget
    • Expenditure Plan
    • Purchase Orders
    • Paid Invoices
    • Receipts (complete with totals)
    • Payroll records (timesheets, payroll certification, payroll registers)
    • Other records to facilitate an effective audit

Supplement Not Supplant

Cannot use federal funds to supplant federal, state, and local resources. Examples of supplanting:

  • Using federal funds to pay for a service required by federal, state, or local laws
  • Using federal funds to pay for a service paid with other funds the previous year
  • Purchasing textbooks required for regular school day curricula
  • Paying for teacher training program with 21st CCLC funds when program was paid with state funds the previous year

Burden of Proof

  • Monitors presume wrong doing until proven otherwise
  • Burden of proof is on sites
  • No documentation=it didn’t happen

Items that Require Excellent Documentation to Support Allowability

  • Food (unless have approved cooking classes & purchase “raw” food items)
  • Field Trips to Amusement Facilities (unless following park’s educational component)
  • Attending Movies (unless attending educational film tied to unit of study & cost is reasonable)
  • Furniture (unless purchasing locking cabinets to safeguard equipment and supplies)

Things to Not Do

When in doubt, contact the Project Director or Complex Business Manager

  • Capital improvements & permanent renovations & construction
  • Costs associated with attending sporting events
  • Purchasing video systems and video games
  • Incentives (plaques, trophies, bumper stickers)
  • Purchases of vehicles

Approved Plan and Budget

Purchases without approval in the budget or amendment may result in questionable costs.

  • Contracting for services
  • The purchase of equipment (capital outlay)
  • Purchases outside of the approved budget period
  • Paying salaries/wages for type of personnel without authorization (i.e., hiring a paraprofessional not in approved budget)