Supplement not Supplant

Funds made available under this part shall be used to supplement, and not supplant, any other federal, state, or local education funds. An LEA may use Title I funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of Title I funds, be made available from non-federal sources for the education of students participating in Title I programs. In no case may Title I funds be used to supplant i.e., take the place of funds from non-federal sources.
PL 107-110 sec. 1120A(b)(1); 20 USC 6320A(b)(1)

Does the LEA have written procedures in place to ensure Title I-A funds are used to supplement and not supplant funds from non-federal sources include the following:
(1) how an employee requests the purchase of personnel/supplies/services;
(2) who is responsible for reviewing requests for expenditures to verify that they are appropriate and that they are for additional personnel/supplies/services that have not been paid out of local district funds in the past;
(3) who is responsible for reviewing requests to ensure that they are approved expenditures in the grant and to verify there is enough money to pay for the expenditures;
(4) who ensures that purchased items are appropriate to be paid out of grant; and
(5) what is the method and remedy to make resource adjustments if the LEA has supplanted?

NOTE:
There are three questions that can be asked of an LEA to determine if federal funds have been used correctly:
1. Did the LEA use Title I funds to provide services that the LEA was required to make available under federal, State, or local law?
2. Did the LEA use Title I funds to provide services that the LEA provided with non-federal funds in the prior year(s)?
3. Did the LEA use Title I funds to provide services for participating children that the LEA provided with non-federal funds for non-participating children?

If the answer to any of these questions is yes, then a presumption of supplanting occurs and the LEA must provide documentation to rebut the presumption of supplanting.Supplemental requirements ensure services provided with Federal funds are in addition to and do not replace or supplant services that students would otherwise receive.

The following bullet points outline the procedures that the (school district) follows in making sure the expenditures of Federal Grant monies are used to supplement the District’s programs rather than supplant expenditures that have been paid by local District funds.

  • Employee submits a request to expend monies from a federal grant to the Grant Administrator.
  • Grant Administrator reviews the request and makes sure the money is being spent on approved expenditures as outlined in the approved Grant Application.
  •  Paperwork is submitted to the grant administrator’s secretary who then enters the requisition into the accounting software. The secretary verifies there is sufficient money in the account to pay for the expenditure and double checks to verify that the expenditure is in line with the approved grant application.
  • Assistant Superintendent for Business reviews the electronically submitted requisition, checks for budget capacity, and verifies that the expenditure is appropriate. He also verifies that the expenditures are for additional services or supplies that have not previously been paid for from local District funding sources. (The Assistant Superintendent for Business reviews all expenditures made by any employee from all schools district funds. He has access to all electronic information and can check for expenditures from any previous year.) The requisition is then turned into a P.O. and returned to the originating employee.
  • The employee makes the purchase, returns a receipt, and signs the receiving report verifying that the items or services have been received. The information is given to the Accounts Payable clerk.
  • Upon receipt of the invoice the Accounts Payable Clerk verifies the charges, processes the invoice for payment and sends the check to the vendor. The information is recorded on our financial system and adjustments are automatically made to the appropriate account code lines in the applicable Grant.
  • The Accounting Specialist submits a cash management report to ADE on a regular basis and reviews the expenditures and status of the grant with the Grant Administrator. Once again expenditures that have been charged against the grant are reviewed and checked for appropriateness.

Title I Fiscal Issues Guide (ED)

Updated October 2014