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4320 Allowable Training Expenses Under Title IV-E

4321 Conditions for Allowable Training Expenses Under Title IV-E

Title IV-E Training Contracts Financial Handbook August 2009

In regard to DFPS training grants with educational institutions, 45 CFR §235.64(d) allows the following types of costs to be claimed:

  •  Salaries

  •  Fringe benefits

  •  Travel of instructors

  •  Clerical assistance

  •  Teaching materials

  •  Equipment

Federal financial participation (FFP) is available for payments to educational institutions, if the following conditions in 45 CFR §235.63(c) are met:

  •  The grants are intended to develop, expand, or improve training for DFPS employees or potential employees administering the program;

  •  The grants are intended for an educational program (curriculum development, classroom instruction, field instruction, or any combination of these) that is directly related to a DFPS program;

  •  The grants are made for not more than three years, but may be renewed, subject to the conditions of 45 CFR §235.63(c);

  •  The grants awarded to educational institutions and programs that are accredited by the appropriate institutional accrediting body recognized by the U.S. Commissioner of Education. When a specialized program within the institution for which there is a specialized accrediting body is used, that program must be accredited by or have pre-accreditation status from that body. Lists of currently recognized accrediting bodies are published periodically in the Federal Register. See also Nationally Recognized Accrediting Agencies and Associations published by the Office of Education;

  •  DFPS has written policies establishing conditions and procedures for such grants;

  •  Each grant describes the objectives in terms of how the educational program is related to the financial assistance programs and how it is designed to meet the state or local agency's workforce needs; and

  •  An evaluation of the educational program funded by each grant is made no later than the close of the second year of the grant. The evaluation must be conducted by representatives from the educational institution and DFPS to determine whether conditions and objectives described in the grant are being met. If the educational program does not meet these conditions and objectives, payment is terminated no later than the close of the second year of the grant.

See 45 CFR §235.63(c).

4322 Salaries and Fringe Benefits Allowed Under Title IV-E

Title IV-E Training Contracts Financial Handbook August 2009

The salaries and fringe benefits paid to university employees for time spent providing IV-E training activities are reimbursable.

Fringe benefits include, but are not limited to the following:

  •  FICA

  •  Insurance

  •  Retirement

  •  Workers’ compensation

The allocation methodology must be detailed in the contractual agreement (Form 2282univ Contract for Title IV-E Training Costs).

Salary and fringe benefits costs allocated to Title IV-E training activities must comply with OMB Circular A-21, (J )(10)(c)(1-3), Examples of Acceptable Methods for Payroll Distribution.

The methods specified are:

Plan Confirmation

The distribution of salaries and wages of professorial and professional staff applicable to sponsored agreements is based on budgeted, planned, or assigned work activity, updated to reflect any significant changes in work distribution. A plan-confirmation system used for salaries and wages charged directly or indirectly to sponsored agreements must meet the standards set forth in OMB Circular A-21, (J)(10)(c)(1)(a-g).

After the Fact Activity Records

The distribution of salaries and wages by the university is supported by activity reports, as prescribed in OMB Circular A-21, (J )(10)(c)(2)(a-f).

Multiple Confirmation Records

The distribution of the salaries and wages for professorial and professional staff is supported by records that certify separately for direct costs and the costs for facilities and administration (F&A), as prescribed in OMB Circular A-21,(J)(10)(c)(3)(a-g).

4323 Travel-Related Training Costs Allowable Under Title IV-E

Title IV-E Training Contracts Financial Handbook August 2009

Travel expenses incurred by university employees in the course of attending or participating in Title IV-E training are reimbursable.

Reimbursement of travel costs is subject to the information published on the Textravel Web site. Reimbursement is limited to actual travel costs and the maximum state reimbursement rates.

Allowable Travel Costs

Travel costs incurred by university employees while performing Title IV-E duties may include:

  •  Meals

  •  Lodging

  •  Auto rental

  •  Gasoline

  •  Airfare

  •  Mileage

  •  Registration fees

  •  Parking

  •  Other incidental expenses, such as taxi fees and tolls

See also 4310 Administrative Expenditures.

Unallowable Travel Costs

Travel costs that may not be incurred by university employees include the following:

  •  Gratuities

  •  Alcoholic beverages

  •  Personal phone calls

  •  Any other items not allowed by federal regulations or not directly connected to the Title IV-E program

4324 Supply Costs Allowable Under Title IV-E

Title IV-E Training Contracts Financial Handbook August 2009

The costs of supplies that are reasonable and necessary to administer the Title IV-E program are reimbursable.

Purchases are charged at their actual cost, after deducting all cash discounts, rebates, and allowances received. Supply costs may include items not capitalized under the university policy. (For procedures related to capitalization thresholds, see Equipment, below.)

4325 Equipment Costs Allowable Under Title IV-E

Title IV-E Training Contracts Financial Handbook August 2009

The cost of equipment purchases, which are reasonable and necessary to administer the Title IV-E program, are reimbursable only if purchased for employees who are 100 percent Title IV-E. To be considered 100 percent Title IV-E, an employee’s work assignment must be exclusive to Title IV-E related duties.

For the purpose of reimbursement through the Title IV-E program, the university’s capitalization policy will prevail when determining if an item will be considered equipment. However, for those universities for which the capitalization threshold exceeds the $5,000 state threshold, the item purchased will be considered equipment for Title IV-E purposes if the cost is less than the university dollar threshold but more than the state dollar threshold. Universities without a capitalization policy will apply the State of Texas Capitalization Policy.

The State of Texas capitalization policy states that any item purchased will be considered equipment and, therefore capitalized, if the two following conditions exist:

  •  The unit cost is $5,000 or more, and

  •  The item has an estimated useful life of more than one year.

4326 Other Operating Expenses Allowable Under Title IV-E

Title IV-E Training Contracts Financial Handbook August 2009

Certain other costs that are directly related to the administration of the Title IV-E program are reimbursable.

Other reimbursable costs may include, but are not limited to, the following:

  •  Telephones (purchase and service costs)

  •  Reference materials

  •  Costs related to collecting and reporting data

All costs must be based on actual expenses.

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