Guidance Regarding Perkins Grant Costs and Programmatic Disruptions During the COVID-19 Pandemic

As with other instruction-related costs, a college use may Perkins funds to support proctoring fees for special populations students enrolled in CTE programs. If funds need to be re-purposed to support this cost, colleges should consult RFA Appendix L Changes to Grant Plan or Budget.

Colleges may loan laptops and other instructional support equipment to students during college closures due to the COVID-19 pandemic. Colleges must ensure that asset control measures are in place to document and track use of equipment for this purpose (RFA 7.5.7 and UGG 200.302 and 200.333).

Equipment loaned to students must be tagged and inventoried. Colleges must have or develop written procedures for students’ home use of instructional technology and should set up loan agreements with students receiving equipment for home use. Colleges must maintain documentation of the process used to assign and track devices. Colleges must demonstrate reasonable efforts to recover devices not returned such as emails, letters, and phone calls.

Yes.

Colleges must observe the requirements of the RFA about non-programmatic use of laptops and other information technology costing under $5,000 per unit (RFA 7.5.7):

• If students are still coming to campus (e.g., labs or simulated clinicals), diversion of technology for home use may not interfere with students’ work.
• Home use of Perkins-funded technology may not add to the cost, wear and tear, or operation of the equipment.
• The college must maintain adequate internal controls to document and track use of the laptops for this purpose.

Child Care: Students may continue to take children to daycare in order to work on an online class. If a student temporarily keeps a child home from daycare due to quarantine of the child following the child’s or a family member’s exposure to or diagnosis of COVID-19, a college may pay a daycare center’s invoice for the time the child would otherwise have been in daycare.

Transportation:A student performing work for an online class may receive reimbursement for documented transportation to and from daycare to allow the student to work on the class. Transportation support may continue for students in program clinicals, coops, and practicums, and for students who continue to commute to campus for program-related activities such as labs. Appropriate records and cost documentation must be maintained to substantiate the charging of student daycare and transportation costs to the grant (UGG 200.302 and 200.333).

A college may continue to charge salaries, hourly wages, and benefits to the grant for employees working from home due to ongoing pandemic conditions, provided such charges are consistent with the college’s approved Perkins budget, RFA requirements, and the college’s local policies and procedures. It is important to note that a college should follow an established local policy that supports paying all employees during emergencies or extraordinary circumstances. A college paying salaries or wages with Perkins funds and lacking such a policy should put one into place to cover the COVID-19 crisis to avoid a potential finding on audit.

Salaries and wages charged to the grant for an employee who works from home must be consistent with the actual time spent on the assigned Perkins/CTE tasks shown on Schedule A. If an employee must be given alternative CTE work during a telecommuting regimen, the college must document the alternative assignment via email notice to the college’s grant advisor. Work on non-CTE tasks must be supported with institutional funds.

Appropriate records and cost documentation must be maintained to substantiate the charging of salaries, wages, and benefits to the grant (UGG 200.302 and 200.333).

Colleges are encouraged to partner with their local hospital and others in their community to help combat the COVID-19 pandemic in a way that ensures public safety. In considering whether to lend equipment to a hospital for its COVID-19 response, a college should coordinate with the hospital to verify that donated equipment is suitable for patient use. Instructional Nursing and Allied Health equipment is designed for instruction purposes and may be not be adaptable to human use. Ventilators, for example, may have been manufactured specifically for instructional use with mannequins.

Such non-instructional use of equipment is a variance from the requirements of UGG 200.313(c)(1) and (2) and is applicable only to the COVID-19 pandemic.

The college must maintain adequate internal controls to document and track use of instructional medical equipment for this purpose (UGG 200.302 and 200.333)

Contracts: Per the RFA, 7.5.5.1, consultants/contractors are required to be paid on a reimbursement basis. However, colleges should review contracts to determine if cancelation fees appear. Where possible, an amendment could be discussed with contracted parties to include cancelation in the event of extraordinary circumstances, so fees are not incurred. If a cancelation fee cannot be avoided, this would be an allowable charge to the grant per OMB guidance related to COVID-19 during this time. Please note that additional funds cannot be made available for these costs. They must be absorbed into your existing Perkins budget.

Vendors:The same principles that apply to cancelations apply to vendors as far as a contract with a vendor is concerned. If the college has purchased services through a vendor and cannot use those any longer because of COVID-19, a discussion between contracted parties should be had if necessary, to amend the contract to cover cancelation in extraordinary circumstances.

In any case, the effort to avoid cancelation fees should be documented in the event an auditor wants to see evidence that a cancelation fee was an allowable cost.

Yes.

Perkins-funded student employees may be paid in accordance with a college’s local policy for continued pay for employees during emergencies or extraordinary circumstances.

Perkins funds may be used to supplement a COVID-19 student emergency fund but should be limited to support directly related to instruction. A CTE student impacted by COVID-19 may receive support for: course-related childcare; certification testing vouchers; instructional texts and study materials, whether hardcopy or online; required supplies, equipment, and uniforms for courses or work-based learning; and mileage reimbursement and other transportation costs such as bus vouchers. Other uses of funds for student support should be discussed with a college’s Perkins grant advisor to confirm allowability.

Appropriate records and cost documentation must be maintained to substantiate the charging of students’ instruction-related emergency costs to the grant (UGG 200.302 and 200.333).

Access codes for online instruction are an allowable cost for special population students. If a student’s personally identifiable information (PII) must be provided to the online provider, an agreement with the provider must be in place to require destruction of the PII at the end of the course.

If funds need to be repurposed for this cost, colleges should consult RFA Appendix L Changes to Grant Plan or Budget.