ESEA Title I Supplement, Not Supplant, and American Reinvestment and Recover Act (ARRA) funds. Supplement, Not Supplant. General rule: A district may not use Title I, Part A funds for activities that it would have carried out in the absence of Title I, Part A funds.
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ESEA Title I
Supplement, Not Supplant, and American Reinvestment and Recover Act (ARRA) funds
A district may not use Title I, Part A
funds for activities that it would
have carried out in the absence of
Title I, Part A funds.
Ask the following questions:
If you answer ‘yes’ to any of these
questions, your district is at risk of
If the district has documentation that it would
not have been able to provide the services with
state or local funds had the federal funds been
unavailable, a district can overcome a
presumption of supplanting.
A district can demonstrate that there was a reduction in the amount of state and local funds available to pay for the activity.
Possible evidence: budgetary documents, accounting ledgers, payroll documentation (including sources of salary funds), legislation and statutes showing reduced funding allocations from year to year.
A district makes the decision to eliminate the activity without taking into consideration the availability of Title I, Part A funds.
Possible evidence: minutes from board meetings, internal memoranda, board resolutions and proposals, as well as other documentation explaining the LEA’s reasons for eliminating the position if it was to be supported with state and local funds
Condition #3 (REQUIRED):
The activity that is now paid with Title I, Part A funds is allowable under Title I, Part A, and consistent with all Title I fiscal and programmatic requirements.
Possible evidence: program statutes detailing allowable uses of funds, descriptions of employee responsibilities, time distribution records, contracts, purchase orders and invoices, and other documentation detailing the procurement process
The district has an official memo that states that the position is about to be cut at the end of the school year. The teacher is re-assigned using ARRA funds to provide supplemental services in a targeted assistance school.
For more information on supplement, not supplant and the ARRA funds: