CTE

Career & Technical Education

Questions & Answers on the 2019-20 Perkins Application for Secondary Programs

Note on missing action steps table for State Priority 3
Note on missing field in section 3.9

1) Can we use the 2019-2020 Perkins funding for new programs?

2) On page 12, the instructions say to select 8 approved programs with the earliest expiration dates. Does this mean I select programs (expiring 6/30/19) already submitted for reapproval?

3) Do you prefer that we pursue two+ additional state priorities if we’re allocated more than $100,000?

4) On pages 36-37, should we be answering the “guiding questions” in our narrative response? Or are those questions for us to consider when working on creating the CLNA after the grant period begins?

5) When must the completed comprehensive local needs assessment be submitted?

6) Do we have to plan projects for all state priorities?

7) What if I only have one action step that will be connected to a Perkins cost item?

8) Can 2019-20 Perkins funds be used to develop the Comprehensive Local Needs Assessment? 

9) In the past, supplies and staff could only support new CTE programs; can 2019-20 transition funds be used to provide support staff and purchase supplies for existing CTE programs? 

10) Can Perkins V transition funds be used to support a classroom assistant who would provide support to all CTE students and classrooms?  

11) Can Perkins V transition funds be used to purchase supplies which will support State Priority #2, developing and improving work-based learning programs and activities, even if these are existing CTE programs? 

12) Do you see any mechanism in new guidelines to be able to purchase large ticket items for new programming?   I am creating an AG mechanics program, a Drone tech program, and would like to develop a new WBL opportunities for all of our students by purchasing a food truck that can be used by most of our programs. 

13) In the local compliance question, do we need to provide a response that relates to “all approved programs” and then another response related to each individual program? Or, is answering the question overall enough?

14) Would you please verify whether or not the following are allowable:
Administrator salaries (regular and overtime)
Equipment
Supplies and materials
Consultants

15)Our high schools have 10 programs with approval, 6 expire 6/30/19. This means there are only 5 programs there for which we can do the mandatory Program Evaluation (State Priority 1). Therefore, is it mandatory to complete 8 program evaluations, or will the 5 suffice?

16)In addition to the mandatory program evaluations, the District will also be submitting the Auto Program at high school A for Priority 4, “First-Time Approval of a CTE Program,” as this has been in process all year. Does high school A also have to complete a second State Priority, or is the project being done by high school B sufficient? In other words, do we have to complete a second State Priority for both schools, or just one? If high school A also has to complete a second State Priority, does it have to complete that project for every NYSED-approved program?

17)I would like to give you an example of a possible expenditure. Your response will help direct us in developing the rest of the projects. Thanks to the long-term employment projections you provided with the grant, we know that HVAC technicians are projected to have a 34.9% increase in employment through 2024. The HVAC Program would like to increase the academic performance of ELLs and SWDs. In order to achieve this, they would like to purchase a new module-based curriculum. This curriculum would include more “hands-on” and project-based learning, which would improve the ELLs and SWDs comprehension of the material. Would the curriculum, as well as the supplies and equipment to support it, be an allowable use of funds?

18)What is meant by indirect administrative costs (question 14 in the Q&As)? Would this include overtime, PD and travel/lodging for PD for administrators?

19)In section 3.1 of the fillable application, the applicant is asked to confirm that it provides programs of study approved by the State. There are 3 fields available in that section that autopopulate the rest of the application where in most cases up to 8 approved programs are required. Should the applicant carry the list to the fields below the two question paragraphs and only list 8 approved programs?

20)Question regarding the Perkins V “Required Use of Funds” (page 34): Do all six (6) required uses need to be addressed either through one or more State Priority projects?

21)I am currently on page 22 of the Perkins file and it is not letting me continue to type. It keeps stopping. I am writing in I A-C all programs. We are unsure of what to do on our end as it may be a file format issue.

22)In priority #1 of the grant application there is a section for main action steps with an explanation of costs for each step. We were wondering if those costs have to include all budget lines from that priority? For example, fringe benefits would be included as an action step?

23)I am working specifically on Priority 1 of our Grant for next year. I will the in house needs assessment person, while we are also utilizing a third party needs assessment company. Additionally I will take the lead on developing a new program, which we plan to use some Perkins money to fund. We had planned that .3 of my salary come out of Perkins, is that ok? In the application it states that administrators salaries can’t be paid out of this Grant.

Also, there is a section in the grant that speaks about indirect costs and administrative costs and there being a 5% cap on the use of Perkins money for this payment. We have always had indirect costs and direct administrative costs as separated out on our grant, is that still ok to do?

24)In priority #1 of the grant application there is a section for main action steps with an explanation of costs for each step. We were wondering if those costs have to include all budget lines from that priority? For example, fringe benefits would be included as an action step?

1) Can we use the 2019-2020 Perkins funding for new programs?

The startup of new programs cannot be funded in the transition year. Districts/BOCES that began development of programs to be submitted for program approval in the 2018-19 program year may use Perkins funds to complete thie process. Verification of the development start date should be submitted with the application.

Any program that started development in the last program year, but did not complete the process can use Perkins funds in the 2019-20 year to do so. As indicated on page 55,


“Perkins funds may be applied to programs in the process of completing an initial application for SED CTE program approval. Funds can be applied to complete required components of the process (see the New York State Implementation Guide for CTE Program Approval .”

2) On page 12, the instructions say to select 8 approved programs with the earliest expiration dates. Does this mean I select programs (expiring 6/30/19) already submitted for reapproval?

Not necessarily. Although all approved programs will need to be evaluated in the coming year, it might be more helpful to prioritize those programs you need to submit in June 2020. The activities in the evaluation project can inform and direct the approval process.

 

3) Do you prefer that we pursue two+ additional state priorities if we’re allocated more than $100,000?

It is up to the applicant to determine how many additional state priorities to fund.

4) On pages 36-37, should we be answering the “guiding questions” in our narrative response? Or are those questions for us to consider when working on creating the CLNA after the grant period begins? 

The guiding questions located on pages 36-37 are intended to be considered to frame the Comprehensive Local Needs Assessment (CLNA) which will be due in April of 2020, in anticipation of the 2020-2021 Perkins V grant.  Therefore, the guiding questions will not be required to be answered in this year’s grant.

5) When must the completed comprehensive local needs assessment be submitted?

Perkins applicants will be completing the comprehensive local needs assessment during the 2019-20 transition year and submitting the results with the 2020-21 application. For the 2019-20 program year, applicants will focus a funded project on one or more of the CLNA components.

6) Do we have to plan projects for all state priorities?

No, all applicants must plan a minimum of 2 projects. State Priority 1: Program Evaluation, is required of all applicants. A minimum of one additional project must be developed. Applicants can select one or two (i.e., a maximum of 3 funded projects) of State Priorities 2-4 as the focus of their Perkins funded projects.

7) What if I only have one action step that will be connected to a Perkins cost item?

It is advisable to include several related no-cost action steps to provide context.

 

8) Can 2019-20 Perkins funds be used to develop the Comprehensive Local Needs Assessment? 

Yes, in fact for the 2019-2020 school year, Perkins funds must be used for a program evaluation activity detailed in the “State Priority 1” section of the application. This mandated activity will help lay the foundation for next year’s Comprehensive Local Needs Assessment. 

9) In the past, supplies and staff could only support new CTE programs; can 2019-20 transition funds be used to provide support staff and purchase supplies for existing CTE programs?  

 Yes, as long as fund use is for existing SED-approved programs and is a necessary part of a project developed to address one of the four State Priorities. For example, if a local agency chose state priority 2--Developing and improving work-based learning programs and activities--that agency could use Perkins funds to purchase software, simulators, or other products allowing students in approved programs to participate in school-based WBL. Care must be taken when using Perkins funds for staff salaries because any salary that was paid in the past using non-federal funds cannot be supported with Perkins as that would constitute supplanting. 

The only State Priority selection that would allow funds to support CTE programs that aren’t yet state approved is option 4-A, where Perkins funds can be used for the programs that are completing program development and approval process activities that were initiated during 2018-19 program year. 

10) Can Perkins V transition funds be used to support a classroom assistant who would provide support to all CTE students and classrooms?  

 Transition funds must focus on one of the State Priorities. The goals of the project developed to address one of the four State Priorities, will determine if this expenditure is reasonable and necessary. Additionally,  support would need to be directed to the needs of approved programs only and to serve the aims of a state priority selected by the local agency. 

11) Can Perkins V transition funds be used to purchase supplies which will support State Priority #2, developing and improving work-based learning programs and activities, even if these are existing CTE programs?  

 Yes, if it is the work-based learning that is a component of an SED-approved CTE program.  The supplies must not be those that are needed for normal operation of the program. If non-federal funds have purchased these supplies in the past, Perkins funds cannot be used to purchase these items as that would constitute supplanting. 

Please note: if an agency’s allocation is less than $100,000 then it may only select one State Priority from options 2-4 to accompany State Priority 1. (Those with allocations over $100,000 may choose two). Spending in one area might preclude spending in another. 

 

12) Do you see any mechanism in new guidelines to be able to purchase large ticket items for new programming?   I am creating an AG mechanics program, a Drone tech program, and would like to develop a new WBL opportunities for all of our students by purchasing a food truck that can be used by most of our programs.

 The focus of Perkins V transition year application is to evaluate SED-approved CTE programs in preparation of the Comprehensive Local Needs Assessment (CLNA) which includes activities to improve student performance. The purchase of equipment must be a necessary component of the project you develop to address a State Priority. The purchase of a food truck would not be an acceptable use of funds.  Transition year funding can only be used for existing SED-approved programs or those that began development and/or program approval process in the 2018-2019 program year.  Verification of the development start date should be submitted with the application.

updated: 6/19/19
The purchase of a food truck might be approvable if the WBL experiences are a part of existing approved programs or those that began development in the 18-19 school year (verification required).

13) In the local compliance question, do we need to provide a response that relates to “all approved programs” and then another response related to each individual program? Or, is answering the question overall enough?

Answering the question overall will rarely suffice because of the content-area specific nature of many activities discussed in the compliance sections.
cid:image002.png@01D5229A.A40A3CE0

Responses need to be fine-grained enough to allow evaluation at the program level. For example, it would be unlikely that each program would have the same percentage of students participating in at least 54 hours of work-based learning [134(b)(6)I.A]. An “All programs” response with a combined average would not be appropriate.

In an instance where all program activities are handled in the same way-for example if the industry data in 134(b)(3)II.C. is always shared via the same channel regardless of the program of study- the “All programs” reply box would be preferable.

14) Would you please verify whether or not the following are allowable:

Administrator salaries (regular and overtime)
Equipment
Supplies and materials
Consultants

Administrator salaries: only indirect administrative costs are allowable; salaries for administrators are a direct administrative cost, so they are not allowable.
Equipment, supplies & materials, and consultants: please see the answer to question 10.

15)Our high schools have 10 programs with approval, 6 expire 6/30/19. This means there are only 5 programs there for which we can do the mandatory Program Evaluation (State Priority 1).  Therefore, is it mandatory to complete 8 program evaluations, or will the 5 suffice?

The 5 programs with expiration dates 6/30/20 and beyond should be the focus of the questions in Section 3.0, compliance with Perkins requirements and State Priority 1, Program Evaluation.  For recipients with 8 or more CTE-approved programs, identify the programs with expiration dates 6/30/20 and beyond then select those that expire first. Programs expiring 6/30/19 do not meet this definition.

16)In addition to the mandatory program evaluations, the District will also be submitting the Auto Program at high school A for Priority 4, “First-Time Approval of a CTE Program,” as this has been in process all year. Does high school A also have to complete a second State Priority, or is the project being done by high school B sufficient? In other words, do we have to complete a second State Priority for both schools, or just one?

If high school A also has to complete a second State Priority, does it have to complete that project for every NYSED-approved program?

The Perkins grant applies at the district level not school building level. A district that is choosing State Priority 4 may apply those funds across multiple high schools in the district without submitting a separate State Priority 4. Should a district have multiple CTE Program Approvals that began development in the 2018-19 program year, to be submitted for approval by 6/30/2020, they may elect to use Perkins funds to support the development activities of each of the soon to be approved programs. This would all be one State Priority. As mentioned in question 1, Verification of the program development start date should be submitted with the application.

17)I would like to give you an example of a possible expenditure. Your response will help direct us in developing the rest of the projects. Thanks to the long-term employment projections you provided with the grant, we know that HVAC technicians are projected to have a 34.9% increase in employment through 2024. The HVAC Program would like to increase the academic performance of ELLs and SWDs. In order to achieve this, they would like to purchase a new module-based curriculum. This curriculum would include more “hands-on” and project-based learning, which would improve the ELLs and SWDs comprehension of the material. Would the curriculum, as well as the supplies and equipment to support it, be an allowable use of funds?

Perkins V emphasizes data-driven decision making. The question above makes assumptions that must be supported. While new curricula might address the needs of certain students, the evidence that there is a need, and that the proposed cost will meet the need must be established. Beginning with the idea that new curriculum which is based on project-based learning will improve ELL’s and SWD’s should be a starting place in your evaluation activies. The results of the program evaluation might support this cost. State Priority 3 must target these two underserved populations. Costs proposed should first identify the needs of ELL’s and SWD’s in the district through data and evidence. If it is determined that ELL’s and SWD’s would benefit from project based learning as a mechanism to engage in more rigorous content, then a plan to bring project based learning to the program would be justified. A plan is not simply purchasing curriculum and supplies and materials. A plan would involve researching available materials (including no-cost curricular materials available) teacher training, continuous evaluation of student growth relative to previous cohorts’ data, collection of student feedback through surveys or other means of evaluation to gauge areas of improvement because of the new approach to Work Based Learning.

18)What is meant by indirect administrative costs (question 14 in the Q&As)? Would this include overtime, PD and travel/lodging for PD for administrators?

Indirect Costs (code 90 on the FS-10) include things like heating, electricity, maintenance, administration that apply to school-wide operations. If grant activities are housed in a building, some portion of that grant is benefiting from these expenses. In addition to the above-mentioned overhead items, indirect administrative costs include the time and effort of district administrators who oversee an entire building and/or district. Direct Administrative Costs include time and effort (salary, code 15 on the FS-10) of administrators directly working to administer the grant—reporting on grant performance to the state, developing procedures for data collection, ensuring conditions and terms of grant are followed, etc. During Perkins IV, grant recipients direct costs, like a portion of an administrator’s salary, were allowed as long as the programs administrative costs did not exceed 5%. New York has discontinued allowing direct administrative costs to be charged to Perkins.

It must be emphasized that all costs must be tied to needs identified through the evaluation of performance and other data. Questions about a cost item’s allowability cannot be answered in isolation. An evidence-based determination of need must first be established.

19)In section 3.1 of the fillable application, the applicant is asked to confirm that it provides programs of study approved by the State. There are 3 fields available in that section that autopopulate the rest of the application where in most cases up to 8 approved programs are required. Should the applicant carry the list to the fields below the two question paragraphs and only list 8 approved programs?

To qualify for Perkins, NYSED requires a minimum of 3 approved programs in 3 separate career clusters.   If the applicant has more than 3 programs, they should use the additional fields that follow to list up to 5 more. These 5 fields have the same autofill properties as the first 3.  If the applicant has more than 8 approved programs, a subset must be selected.  (See question 2 for more information.)  The evaluation of these 8 programs will begin the activities that will be required to complete the Comprehensive Local Needs Assessment (CLNA).  During the 2019-20 program year (7/1/19-6/30/20), applicants will complete a  Comprehensive Local Needs Assessment which will evaluate all programs and determine how Perkins funds will be directed in the 2020-2021 program year.

Applicants who have not completed a CLNA will not be eligible to apply for 2020-2021 Perkins funds.

20)Question regarding the Perkins V “Required Use of Funds” (page 34):  Do all six (6) required uses need to be addressed either through one or more State Priority projects?

While the application states that recipients do not need to address all six required uses of funds in the 2019-20 Perkins V Transition application through the state priority projects, pending federal guidance may require changes to next year’s application.

21)I am currently on page 22 of the Perkins file and it is not letting me continue to type.  It keeps stopping.  I am writing in I A-C all programs.  We are unsure of what to do on our end as it may be a file format issue.

The fillable boxes on the application have character limits.  Responses can be provided in short narratives, outlines indicating main actions, or a combination of both using a dash (-) as bullets cannot be used in the fillable form.

22)In priority #1 of the grant application there is a section for main action steps with an explanation of costs for each step.  We were wondering if those costs have to include all budget lines from that priority?  For example, fringe benefits would be included as an action step? 

In the application, a maximum of five action steps are allowed. Applicants are not required to use all five.  Each action step may incorporate one or more budget lines.  Each budget line does not need to be a separate action step.

23)I am working specifically on Priority 1 of our Grant for next year. I will the in house needs assessment person, while we are also utilizing a third party needs assessment company.  Additionally I will take the lead on developing a new program, which we plan to use some Perkins money to fund. We had planned that .3 of my salary come out of Perkins, is that ok?  In the application it states that administrators salaries can’t be paid out of this Grant.

Also, there is a section in the grant that speaks about indirect costs and administrative costs and there being a 5% cap on the use of Perkins money for this payment.  We have always had indirect costs and direct administrative costs as separated out on our grant, is that still ok to do?

In Perkins IV, New York allowed  Perkins funds to support direct administrative costs. In order to focus funds on the changes required by Perkins V, direct administrative costs will not be allowed in the transition year. As mentioned on page 61 of the application, “All staff positions and activities not directly related to a specific State Priority project will be considered as administrative costs.”

This question is identifying an administrator’s efforts to address State Priority 1, Program Evaluation.  If an individual who happens to be an administrator is performing the work that needs to be done to complete the program evaluation then Perkins funds may be used to pay for a portion of that individual’s salary.  This does not include administrative duties regarding the work of others who are performing the work.   Administration and oversight are not supported, but tasks such as data collection, and research could be.   Applications must clearly describe the types of work and efforts that will be performed by staff whose salaries are attributable to grant administration.

24)In priority #1 of the grant application there is a section for main action steps with an explanation of costs for each step.  We were wondering if those costs have to include all budget lines from that priority?  For example, fringe benefits would be included as an action step? 

In the application, a maximum of five action steps are allowed. Applicants are not required to use all five.  Each action step may incorporate one or more budget lines.  Each budget line does not need to be a separate action step.

 

Resources

 

6/3/19

New York State's Perkins Transition Plan 2019-20

Reading the law:

 Brief summary and analysis. You can read the entire bill here or at congress.gov.

Advance CTE has a side-by-side comparison with Perkins IV. There is also a redline version.

 

Big topics:

How the law allows State allocations to be distributed.

This timeline from Advance CTE (a portion is shown above) shows the schedule for transition to the four-year plan.

Required accountablilty data will be different under Perkins V as this comparison shows.

Some frequently asked questions as compiled by ACTE.

Contact us with questions or comments.

 

More:

Last Updated: June 27, 2019