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									                                                        Idaho Charter School Program
                                                             Federal Grant Guidelines

The purpose of the Charter School Program (CSP) is to increase understanding of the charter
school model and to expand the number of high-quality charter schools available to students
across the Nation by providing financial assistance for the planning, program design, and initial
implementation of charter schools, and to evaluate the effects of charter schools, including their
effects on students, student academic achievement, staff and parents.

The specific grant goals for the Idaho Charter School Program are to:
   1) Promote the development of high quality school petitions to increase the number of
      quality charter schools focused on high achievement for all students.
   2) Evaluate and communicate the effects of Idaho charter schools on students, student
      achievement and parents.
   3) Increase the number of new charter schools focusing student achievement efforts on
      underserved populations of students (as defined by the State), particularly those high
      school students who are at greatest risk of not meeting challenging state achievement.
   4) Share best practices of high performing charter schools with demonstrated success at
      promoting student achievement.
Sec. 5204 (f)(3)(A)(B) of the CSP Federal statute outlines what an eligible applicant receiving
CSP subgrant funds may use the funds for. Throughout the grant period, expenditures must
also conform to three criteria—Allowable, Reasonable, and Allocable. From OMB Circular No.
A-21, here are the definitions of the three criteria.

Factors affecting allowability of costs. The tests of allowability of costs under these principles
are: (a) they must be reasonable; (b) they must be allocable to sponsored agreements under
the principles and methods provided herein; (c) they must be given consistent treatment through
application of those generally accepted accounting principles appropriate to the circumstances;
and (d) they must conform to any limitations or exclusions set forth in these principles or in the
sponsored agreement as to types or amounts of cost items.

Reasonable costs. A cost may be considered reasonable if the nature of the goods or services
acquired or applied and the amount involved therefore, reflect the action that a prudent person
would have taken under the circumstances prevailing at the time the decision to incur the cost
was made. Major considerations involved in the determination of the reasonableness of a cost
are: (a) whether or not the cost is of a type generally recognized as necessary for the operation
of the institution or the performance of the sponsored agreement; (b) the restraints or
requirements imposed by such factors as arm's-length bargaining, Federal and State laws and
regulations, and sponsored agreement terms and conditions; (c) whether or not the individuals
concerned acted with due prudence in the circumstances, considering their responsibilities to
the institution, its employees, its students, the Federal Government, and the public at large; and,
(d) the extent to which the actions taken with respect to the incurrence of the cost are consistent
with established institutional policies and practices applicable to the work of the institution
generally, including sponsored agreements.
Allocable costs. A cost is allocable to a particular cost objective (i.e., a specific function, project,
sponsored agreement, department, or the like) if the goods or services involved are chargeable
or assignable to such cost objective in accordance with relative benefits received or other
equitable relationship. Subject to the foregoing, a cost is allocable to a sponsored agreement if:
1) it is incurred solely to advance the work under the sponsored agreement; 2) it benefits both
the sponsored agreement and other work of the institution, in proportions that can be
approximated through use of reasonable methods, or 3) it is necessary to the overall operation
of the institution and, in light of the principles provided in this Circular, is deemed to be
assignable in part to sponsored projects. Where the purchase of equipment or other capital
items is specifically authorized under a sponsored agreement, the amounts thus authorized for
such purchases are assignable to the sponsored agreement regardless of the use that may
subsequently be made of the equipment or other capital items involved.


Ongoing operational costs of a charter school are not intended to be paid for with Federal CSP
funds. Planning & Program Design and Implementation Grant funds are to be used only for new
charter school costs. They may not be used to provide funds for continuing operational costs or
as a contingency fund for unforeseen or unplanned expenses. Awarded schools are allowed a
maximum of three years (36 months) with a maximum of 18 months allowed for Planning &
Program Design and a maximum of 24 months allowed for Implementation.

The Implementation Period begins 3 months before the school opens. The Planning & Program
Design Period begins up to 18 months before Implementation Period begins. The entire grant
period is 36 months, but the Implementation Period cannot exceed 24 months.

Below is an example of a new school and the funding periods:

ABC Charter School to open August 1, 2011

                                           Grant Year One

                                   Planning & Program Design
                             Awarded grant funds on October 1, 2010
                                Initial Planning ends April 30, 2011
                              Planning & Program Design: 6 months

                             Initial Implementation begins May 1, 2011
                               Funds are expended by July 30, 2011
                                           Grant year ends
                                       Implementation: 3 months

                                           Grant Year Two

                                Funding available October 1, 2011;
                               Funds are expended by July 30, 2012
                                         Grant year ends
                                    Implementation: 9 months

                                       Grant Year Three

                              Funding available October 1, 2012;
                             Funds are expended by July 30, 2013
                                       Grant year ends
                                  Implementation: 9 months

                         Total: Planning & Program Design – 6 months
                                  Implementation – 21 months
                                Entire Grant Period – 27 months


Funding is awarded on a competitive basis and no applicant is guaranteed funding or funding
amounts. Final funding decisions are made by the office of School Choice at the State
Department of Education (SDE).

Grantees must expend federal funds expeditiously to accomplish the purposes of the grant. The
SDE maintains grant funds records. Schools that have not used their grant funds in a timely
manner or in accordance to their budget will be contacted to determine the reasons why funds
are not being used within a reasonable time. Failure to use grant funds expeditiously can result
in a cancellation of the grant by the SDE.

Requests for Payment of Grant Funds

The Charter School grant is operated on a Federal fiscal cycle, which is different from the
state’s fiscal cycle. Each year of award availability begins on October 1 and ends September
30. For state accounting purposes, CSP funds must be encumbered by June 30. For example, if
a teacher training session will be taking place in July, the funds for that training would be
encumbered or “spoken for” by June 30.

The SDE has a Grant Reimbursement accounting program specifically designed for schools to
request their grant funds. The CSP grant is for reimbursements only. The SDE School Choice
personnel will review your grant reimbursement requests and determine if it meets the
budgetary guidelines and allowable expenditures.

Inventory and Equipment Records

Proper inventory records must be maintained for any equipment or non-consumable materials
purchased with Federal grant funds.

According to Federal guidelines all equipment acquired with Federal funds must be properly
maintained and included in equipment/inventory records. The records shall include the following
information: 1) description of the equipment; 2) manufacturer’s serial number, model number or
other identification number; 3) source of the equipment, including the grant award information; 4
acquisition date; 5) location and condition of the equipment.

Disposition of Grant property

When property purchased with Federal grant funds is no longer needed or a charter school that
has received CSP funds closes the following policy applies:
1) Closing/closed schools: All non-consumable items of value purchased with CSP grant funds
must be distributed to other public charter schools; the authorizer must work with the SDE to
determine the priorities and method for distribution. A statement of how the assets were
distributed must be submitted to the SDE. Items purchased with the CSP funds can not be sold
to satisfy creditors’ claims.
2) Operational charter schools: Schools wishing to sell, give-away or dispose of non-
consumables purchased with CSP grant funds must follow Federal Guidelines and maintain
appropriate documentation. Any proceeds from the sale of property must go back into the
funded program (i.e., money from the sale of computers goes into the technology fund). Grant
records should reflect depreciation, disposition and an updated inventory record for six years
after completion of grant funding.

                  Planning & Program Design (maximum 18 months)

Grant funds are intended to be used to supplement, not supplant, state or local funds. Allowable
expenditures for Planning & Program Design are those that are necessary for the initial costs of
planning and designing of the school’s program. Funds are to be used for one time expenses;
not for on going costs.

The planning period ends April 30 the year the school opens.

Examples of Planning & Program Design Allowable Expenditures:

   •   Personnel salaries and benefits BEFORE the school opens (see time line). The school
       must demonstrate that an individual was hired solely to implement the school’s program
       and not to satisfy an ongoing operational need. Request for personnel salaries and
       benefits requires prior approval from the SDE’s Office of School Choice.
           o Example: School leader and business manager salaries.
   •   Development of the educational program.
           o Example: Hiring a consultant or staff member to ensure that the curriculum is
               aligned to state academic standards.
   •   Hiring consultants to help develop curriculum, assessments, policies, safety manuals,
       student handbooks, etc.
   •   Development of awareness and/or recruitment materials.
           o Example: Advertisements for staff positions, development of recruitment
               brochures, etc.
   •   Costs associated with staff training and/or orientation.
   •   Conference attendance.
   •   Student data and/or administrative software.
   •   Advertising costs to recruit students.
   •   Minor renovations to bring building into ADA compliance.

Examples of Non-allowable Expenditures:

   •   Rent
   •   Indirect Costs
   •   Large equipment purchases (furnaces, playgrounds, etc.)
   •   Capital construction, including the construction of new facilities
   •   Capital expenditures such as the purchase of land or buildings
   •   Installation of elevators
   •   Purchase or lease of motor vehicles or modular classrooms
   •   Routine student transportation
   •   Student materials
   •   Furniture and equipment
   •   Support for salaries, benefits or costs of any employee of an educational management
       organization or any institutional partner of the schools.

                          Implementation (maximum 24 months)

Implementation grant funds are intended to be used for continuing development of the school
and other initial operational costs that cannot be met with state or local sources. CSP funds
cannot be used for ongoing operational costs, capital expenses, salaries or benefits, or utilities.

The implementation period begins May 1 the year the school opens and ends after 24 months.

Examples of Implementation Allowable Expenditures:

   •   Professional development of teachers and other staff.
   •   Refinement of educational goals and measurable objectives.
           o Example: Contracting to evaluate state testing to inform and direct instruction
   •   Acquiring educational equipment and curriculum materials.
           o Example: Textbooks, workbooks, library materials, student/staff computers and
               peripheral equipment.
   •   Purchase of classroom furniture.
           o Example: Student and staff desks, chairs, bookshelves, maps, globes, etc.
   •   Development of program for school evaluation strategies and materials.
   •   Payment of consultants performing work directly related to the program and operation of
       the charter school.
   •   Installation of purchased equipment.
   •   One-time costs associated with program startup: equipment and supplies, instructional
   •   Library books and textbooks.

Examples of Non-allowable Expenditures:

   •   Salaries and fringe benefits (unless it is utilized before the school opens)
   •   Rent
   •   Indirect Costs
   •   Large equipment purchases (furnaces, air conditioners, playgrounds, etc.)
   •   Non-instructional equipment purchases
   •   Capital construction, including the construction of new facilities
   •   Capital expenditures such as the purchase of land or buildings
   •   Installation of elevators
   •   Costs for student expeditions
   •   Purchase or lease of motor vehicles or modular classrooms
   •   Routine student transportation
   •   Support for salaries, benefits or costs of any employee of an educational management
       organization or any institutional partner of the schools.
   •   Permanent/built in improvements to the building
   •   On going costs
           o Example: utilities, software support, upgrades
   •   Consulting and stipends
   •   Regular or normal cost of doing business
           o Legal, accounting, virtual school site testing

                          Dissemination (maximum 24 months)

An eligible charter school may use Charter Support Program dissemination sub grant funds to
assist other schools in adapting the school’s program or aspects of the charter school through
activities such as:

   1. Assisting other individuals with the planning and start-up of one or more new public
      schools, including charter schools, that are independent of the assisting charter school
      and the assisting charter school’s developers, and that agree to be held to at least as
      high a level of accountability as the assisting charter school;
   2. Developing partnerships with other public schools, including charter schools, designed to
      improve student academic achievement in each of the schools participating in the
   3. Developing curriculum materials, assessments, and other materials that promote
      increased student achievement and are based on successful practices within the
      assisting charter school; and
   4. Conducting evaluations and developing materials that document the successful
      practices of the assisting charter school and that are designed to improve student
      performance in other schools.

A charter school may not use dissemination grant funds, either directly or through a contractor,
for marketing or recruitment activities designed to promote it or the programs offered by it or by
a contractor to parents or the community. Grant funds may be used to develop materials
documenting successful practices of the charter school for the educational purpose of assisting
other schools in improving student academic achievement. Any charter school receiving a
dissemination grant must provide thorough and high-quality information that meets the needs of
other schools trying to learn from the charter school’s experience. Funds should be directed
toward activities directly related to articulated objectives. Dissemination grants are not to be
used towards the operation of the applicant charter school. Funds are to be used exclusively for
the preparation and dissemination of a product or service.

Examples of approvable expenses include, but are not limited to:

   •   Project director salary and benefits
   •   Teacher stipends
   •   Substitute costs
   •   Hiring consultants to help implement curriculum, assessments, policies, etc.
   •   Designing and conducting training activities
   •   Expenses associated with the implement of project program
           o Example: copying, mailing, travel costs, etc.
   •   Development of awareness activities

Examples of non-allowable expenditures include, but are not limited to:

   •   Advertising and/or recruitment for the school
   •   Salaries and fringe benefits not directly related to project goals
   •   Facilities expenses
   •   Indirect costs
   •   Personal expenses
   •   Website development and maintenance

                                Explanation of Expenditures

Important: In reviewing this listing, please keep in mind the Federal requirement is:
expenditures must be “reasonable and necessary” to accomplish the approved activities of the
grant. This requirement is an overriding qualification for any and all expenditures listed below
that may be charged to the federal grant. The majority of these examples apply to Planning and
Implementation grants. Costs for Dissemination grants are more limited and are explained
separately. No listing can account for all the variations of expenses that may occur in the
planning and implementation of a charter school. Please contact the SDE School Choice office
for additional clarification.

Accounting and Software Training may be purchased on a one-time basis in order to allow the
school to effectively manage its budget. Additional upgrades and/or training after the initial
purchase are continuing operational costs and may not be paid from Federal funds.

Advertising costs to promote charter school enrollment and to inform the community of the
charter school program are generally allowable.

Architects may be paid from grant funds in certain limited circumstances. CSP funds may not
be used for the purpose of remodeling a potential school facility with the exception of making
minor improvements to meet ADA requirements, which are items such as restroom
accommodations, ramps and sidewalks for wheelchairs and similar required modifications.

As part of making the allowable ADA modifications, the services of an architect may be required
for evaluation, planning and design of these items, and payment to the architect using CSP
funds would be allowable since it is directly related to making those required ADA

CSP funds may be used for payment to an architect for an initial inspection of the facility and
recommendations for needed remodeling that is required to meet occupancy standards, but not
for the actual design of plans and specifications for the remodeling work to be accomplished or
the direction of that work. Those design and specification services by the architect would fall
into the remodeling category just as would the actual purchase of remodeling materials and

Attorney costs may be payable for certain legal services that are necessary and usual in order
to allow the school to begin operations and the use of CSP funds will be allowed for the services
of an attorney to review contracts and other legal issues directly related to preparing the school
for opening. However, this does not include lawsuits, legal defense or advice and meetings
related to such actions or potential actions or issues that are not directly related to “start-up”

Contracts for Purchased (Professional) Services from consultants or outside firms and
individuals are allowable when it can be shown that the services are necessary for the planning
and implementation of the school program, including professional development of school staff
and when the cost is reasonable. Keep in mind that salaries may not be paid from these grant
funds. A contract or payment that provides payment on an hourly or other regular basis may
appear to be providing a salary. Professional Services Contracts should be based on
“deliverables”, i.e., products and services to be provided to the school by certain dates at a
reasonable, agreed-upon cost, rather than an hourly rate for a period of time.

Services that may have been contracted out during the Planning phase, such as a business
manager, administrative assistant or secretarial services are generally considered as normal
school operating costs regardless of whether the persons performing these services are still
contracted as “purchased services” or are now permanent employees of the school. Since these
types of operational costs are continuing costs, they may mot be paid from the federal grant.
These costs should be paid from state funding.

Contracts for Potential School Employees prior to an employment contract must be limited to
services performed for the school that are directly related to Planning and Implementation of the
charter school. Again, such contracts and payments must be based on specified and
documented “deliverables” rather than appearing to be salaries.

Equipment is defined as an item of property that has a unit cost of $5,000 or more. We
encourage the reasonable use of federal funds to purchase high-cost items that are necessary
for the start-up and operation of the school program and that might not normally be affordable
with only state operational funding. Schools are encouraged to use federal funds to purchase
equipment that will be needed to implement the school program in its first or subsequent years
of operation so that students can receive the maximum benefit of charter school enrollment as
early as possible.

Expendable Supplies and Materials may not become a permanent part of the federal grant
budget. Request only the amounts needed to allow the school program to begin with all
necessary materials present in classrooms. Subsequent purchases of expendables are
considered to be operational expenses and should be purchased with state or other funds.

Food costs are allowable only if they are necessary to carry out the agenda for meetings,
conferences, and workshops. If the lunch hour is going to be used to continue with the
morning’s activities or to provide information to participants (a working lunch) it is also allowable.

Furniture is allowable in order to meet classroom needs such as student and teacher desks and
chairs, bookcases, computer work stations and other items necessary to implement the
curriculum in the manner set forth in the approved charter. Administrative furniture is allowable
on a one-time basis within reasonable cost limits. The amount of furniture purchased should
also bear a reasonable relationship to the number of classrooms and offices to be utilized in the
proposed facility.

Janitorial and Cleaning Supplies are allowable on a one-time basis for immediate use during the
first few months of school operation, but will not be approved in large quantities or over an
extended period of time.

Land, Buildings and Vehicle purchases are not allowable expenses.

Office expenses may be allowable on a one-time basis in order to allow the school to be
implemented, e.g., the purchase of a copier, computer or fax machines, basic office supplies,
necessary administrative software, contracted business services, etc. However, regular and
continuing administrative costs are not allowable. These should be charged to state funding.

Operational expenses are limited to the initial operating expenses that cannot be met from state
or local sources and that are necessary to start-up the school. Continuing operational expenses
cannot be covered by the federal grant.

Playground Equipment is allowed only if it is not a permanent fixture. For further clarification,
please contact the SDE School Choice office.

Post-award Costs for the Planning and Implementation of the school that are incurred on or
after the date of the grant award letter are the only costs allowable under this federal grant.
Obligations made prior to the date of the award letter may not be charged to the federal

Pre-award Costs such as writing the charter or federal grant application, consulting, planning,
travel, etc., that occurred prior to the date of the grant award letter may not be paid from the
federal grant.

Professional Development for school staff and faculty is classified as a Planning activity in the
federal law for purposes of the Planning and Implementation Grant. Only Professional
Development activities that are related to and necessary for the Planning and Implementation of
the school and its program are allowable costs for this type of grant. These may include
reasonable and necessary travel and per diem costs.

Remodeling of the school facility or its grounds, such as carpeting, tile, painting, electrical
and/or plumbing upgrades, sidewalks, etc., is not allowable except for minor adaptations
required to meet ADA requirements. (See Architect)

Salaries are not allowable under this grant. The only exception is the salary of the school leader
or office staff which may be paid from grant funds prior to the opening date of the school (see
Planning & Program Design). Once the state funding becomes available, the principal or head
teacher’s salary must be paid for from state funds rather than from federal funds.

When the services of others must be utilized and paid for to perform necessary functions prior to
the availability of state funding (business manager services, curriculum and policy development,
clerical or administrative services) a professional services contract should be used. (See
Contracts for purchases services)

If an individual is contracted to perform “principal duties” prior to the opening of school and is
not hired as the actual principal using an employment contract, these funds must be listed as
purchased services.

Software Upgrades and Training may be purchased on a one-time basis. Additional upgrades
and/or training after the initial purchase are continuing operational costs and may not be paid
from Federal funds.

Stipends are for employee participation in required program-related activities outside of normal
work hours that are necessary for the Planning and Implementation of the school and paid at
contracted hourly or daily rates. If the individuals are not yet contracted school employees, their
services should be acquired through a professional services contract and listed as a Purchased
Service on the budget.

Student Data Systems and Training may be purchased on a one-time basis in order to allow the
school to effectively manage student data. Additional upgrades and/or training after the initial
purchase are continuing operational costs and may not be paid from Federal funds.

Technology items that are necessary to support the school’s instructional program such as
student and teacher computers, software, audio-visual equipment and media production items
are generally allowed but the application and budget must identify the specific program and how
the program is supported by these items. Technology items for administrative use are generally
allowable if necessary for the operation of a modern school and if they do not appear to be
conveniences for staff. For example, administrative computers and software are necessary for
school management, but blackberries for staff are not.

Telephone, Public Address and Security Systems are not allowable expenses if they require
permanent remodeling or modifications to the facility. Systems that are fully portable so that
they could be moved to a different facility if necessary may be allowable. Cell phones and
walkie-talkies are not allowable.

Travel for professional development, local, state or national charter school conferences or other
activities that will directly support the charter school’s program is generally allowable. The
expenses may include registration, per diem, lodging and transportation costs. All travel costs
must be reasonable and must comply with federal and state government requirements and
limitations. Per diem is based on the state reimbursement rate.

For additional information, please contact:
           Michele Clement-Taylor, School Choice Coordinator
           Division of Innovation and Choice
           Idaho State Department of Education
           Lori Howard, Administrative Assistant
           Division of Innovation and Choice
           Idaho State Department of Education


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