Significant Perkins Changes for FY08 thru FY12

What MUST ALL CTE teachers do?

a.      Identify "Occupational/Technical proficiency" 

a.       (Personally, I would recommend recording "occupational proficiency" for each student in each course in the sequential program.  Each CTE course MUST include competencies. If a student is proficient in 1.5 units of courses, they ARE occupationally proficient.

b. Virtually ALL other student data is collected through Project EASIER via student files submitted to the state (ie., JMC reports, etc.).

DEFINITIONS:

COMPLETER is NO longer a key measurement tool.  It is still used for some special populations indicators, but it is NOT a key measurement tool for ALL students.

CONCENTRATOR - Concentrator replaces Completer as a key measurement tool. 

At the Secondary level, a concentrator is any student that has completed1.5 units in a single specific CTE program. (ie., ag business, bus, fcs, etc.)

At the Postsecondary level, a concentrator is any student that has 1.) been accepted into a CTE program; 2) completes 12 credits of technical core in a specific CTE program; or 3.) completes a short-term CTE program of less than 12 credits, that terminates with an award of an industry-recognized credential, or a certificate.

Occupational Proficiency must be reported on any student that qualifies as a concentrator.  Therefore, it may be wise to quantify occupational proficiency at the completion of each course.

Personal "Gruis" recommendation: At the end of each course, record whether students did or did not complete an acceptable level of course's COMPENTENCIES.  (Remember, according to state code, CTE programs MUST be competency-based.)

The old...90% level of competencies attained... IS GONE.  In its place, a level of successful ATTAINMENT must be a level identified by a third party or your local advisory committee as ACCEPTABLE. 

Gruis Editorial:  The law uses the word "test"; however, "test" could be a  checklist of competencies or skills that students successfully acquired.  I define "successfully acquired" as ... "Students learned enough to perform the competency at the next level (college or work)."

Academic Proficiency (no change):  ITED data is automatically collected via Project EASIER.

Career/Technical Program – At the Secondary (high school) level, students must be enrolled in at least one Career and Technical Education (CTE) program that is comprised of three or more sequential units.  (“Sequential” does NOT infer that the courses must be taken in a specific order.  “Sequential” implies that the CTE courses must build upon the competencies required for occupational success within a specific pathway.)  Local school districts determine which CTE courses make up the program sequence.  Arts & sciences or liberal arts courses (ie., math, English, etc.) are NOT allowed as part of the 3 unit CTE course sequence.  Because Iowa has comprehensive high schools, it is assumed that ALL students will complete enough math, science, social studies, and language arts to graduate; however, these courses are NOT allowed to be identified as part of the 3 CTE unit minimum for a CTE program. 

Federal Perkins Law interpretations- - Welcome to the world of “gray”. Very few expenditures are identified as “black-and-white” (legal or illegal) in Federal code.  ALL legal expenditures do need to meet the INTENT of Federal law; and therefore, a simple list of legal/ not-legal expenditures is impossible to generate. 

Title III, Part A, Section 311(a) of the Perkins Act: 

The section states that "Funds made available under this Act for career and technical education activities shall supplement, not supplant, non-federal funds expended to carry out career and technical education activities and tech prep program activities."

Section 135(c)(7)

Clearly states that funds made available to an eligible recipient may be used for "leasing, purchasing, upgrading or adapting equipment, including instructional aids and publications(including support for library resources) designed to strengthen and support academic and technical skill achievement."

Textbooks, probably would meet the definition for instructional aids
and publications, but the recipient may be supplanting local funds with
federal funds.  Thus the expenditure may not be an allowable use of
funds under that section of the Act.   However, this would only be a
‘supplant’ violation, if the district is providing similar support for other programs while withdrawing the support of local funds from the program in question.

Supplement vs. Supplant

The underlying intent of Federal Perkins law is to improve the achievement of students in career and technical programs.  Using Federal dollars to ‘supplement’ existing programs is a legal use of Federal funds; using Federal dollars to ‘supplant’ local dollars is NOT legal. (CTE programs are composed of CTE courses. Academic courses, such as math, English or science, are NOT part of a CTE program.)

Text books are one of the "gray" areas in the Federal Perkins law; there are no "black-and-white" rules on texts.  So, here is our (Iowa DE) interpretation of Federal Perkins law with regard to textbookss.  (Just joking…but, if you don’t like our interpretation, please move your school to another state; although, I can’t think of states that do not follow these same interpretations.)

1. Consumable items are NOT legal expenditures. One-time-use items such as student workbooks, welding rods, feed, etc. are NOT legal expenditures.

2. "Supplant" is NOT legal. If a district purchases text books, with Perkins $, that have normally (in the past) been purchased with other school dollars; this would be considered "supplanting" and is NOT legal. 

Example:  It is NOT LEGAL to purchase a course's ‘regular/standard’ textbook with Federal dollars.  This is a tough call, because some/many CTE courses do not have a specific ‘course’ textbook.  Courses such as math often have a designated ‘course’ text book.  Any texts that could be defined as a ‘course’ textbook are NOT legal expenditures.

Crude Example:  Standard Operating Procedures (SOP) -- Providing toilet paper is standard practice for operating a school, and would NOT be an allowable expenditure utilizing Federal dollars.  Purchasing any materials or items of this type would be considered as standard-operating-procedures, and would NOT be allowable.  Other examples of Standard-Operating-Procedures:  a. providing desks, b. providing chalk, c. providing a teacher, d. providing a classroom, etc.

3. “Supplement” is LEGAL.  Using Federal Dollars to purchase a set of texts which serve as supplemental resources or additional resources beyond the regular course textbook is legal.  If a specific textbook is the ONLY books used in a course, and the textbook id used daily/frequently throughout the course; these would probably NOT be legal uses of Federal dollars.

Example:  If a school purchases GPS units, with Federal Perkins $, a set of texts or materials purchased to assist students in using the GPS units would be allowable. If these texts or printed materials are the only texts used in the course, they would NOT be allowable. Essentially, texts that function as a “course’s” primary text would NOT be allowable.  Supplemental materials or texts are allowable.  (Consumable items are NEVER allowable.)

4. Equipment is a legal expentiture, IF it incorporates NEW or ENHANCED technology.

Examples:

        Hammers -No: …New hammer technology… I don’t buy it.  Unless the purchase would be for a few hammers which are designed to meet the needs of students with physical disabilities.

        Computers -Yes: Computers are typically out-of-date as soon as they arrive; therefore computers are almost always allowable.

        Table Saw -Yes: Table saws typically have new and improved features, such as safety features.

     Table Saw Blades -No: One table saw blade to aid in the training of the new equipment is an acceptable Perkins expenditure.  A pack of 10 extra table-saw blades would not be allowable because saw blades, drill bits, etc. are consumables.