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Mandatory Disclosure (2 CFR 200.113)

• Applicant, recipient, or subrecipient must promptly disclose whenever it has credible evidence of the commission of a violation of federal criminal law involving fraud, conflicts of interest, bribery, or gratuity violations under the False Claims Act (Title 18 – Criminal and Title 31 – Civil).
• Disclosure must be made in writing to the Federal agency, the agency’s Office of Inspector General, and the pass-through entity (if applicable).
• Failure to report can result in remedies for noncompliance (2 CFR 200.339).

Report a violation of Federal criminal law to the State Director for Career and Technical Education at ÑÇÖÞÎÞÂë, the Sole State Agency (pass-through entity) authorized to receive and disburse federal Perkins V funds and to supervise the administration of the state career and technical education programs in the state of Minnesota.

To report to the U.S. Department of Education Office of Inspector General, follow the instructions on the to submit an online form to file your complaint.

Whistleblower Protections (2 CFR 200.217)

An employee of a recipient or subrecipient must not be discharged, demoted, or otherwise discriminated against as a reprisal for disclosing information that the employee reasonably believes is:

• Evidence of gross mismanagement,
• Gross waste,
• An abuse of authority,
• A substantial and specific danger to public health or safety, or
• A violation of law, rule, or regulation.

The recipient and subrecipient must inform their employees in writing of employee whistleblower rights and protections under 41 U.S.C. 4712.

State Agency Enforcement of Federal Requirements (GEPA Chapter 31 Sec. 440; 20 USC 1232c(b))

To enforce federal requirements under applicable programs, the State may:

1. Withhold approval, in whole or part, of the application, except that State shall not finally disapprove unless it provides hearing rights
2. Suspend payments, in whole or in part, except that shall not suspend until 15 days after show-cause; and suspension cannot exceed 60 days without providing hearing rights
3. Withhold payments, in whole or in part, after notice and hearing before an impartial hearing officer

Remedies for Noncompliance (2 CFR 200.339)

When noncompliance cannot be remedied by specific conditions, ÑÇÖÞÎÞÂë (pass-through entity) may take one or more of the following actions:

• Temporarily withhold payments until the recipient or subrecipient takes corrective action
• Disallow costs for all or part of the activity associated with the noncompliance of the recipient or subrecipient
• Suspend or terminate the federal award – in part or in its entirety
• Initiate suspension or debarment proceedings
• Withhold further federal funds (new awards or continuation funding) for the project or program
• Pursue other legally available remedies

Processing Objections, Hearings, and Appeals (2 CFR 200.342)

ÑÇÖÞÎÞÂë (pass-through entity) must comply with any requirements for hearings, appeals, or other administrative proceedings to which the recipient or subrecipient is entitled under any statute or regulation applicable to the action involved.

ÑÇÖÞÎÞÂë System Office Policies

• ÑÇÖÞÎÞÂë Procurement – Contracts and procurement policy.
• ÑÇÖÞÎÞÂë Travel – Travel management guidelines.
• Conflict of Interest – See Subpart A.
• ÑÇÖÞÎÞÂë Gratuity - Gifts and Grants
• ÑÇÖÞÎÞÂë Inventory Controls
  • Purchasing Cards
  • Capital Assets
• ÑÇÖÞÎÞÂë Code of Conduct
• ÑÇÖÞÎÞÂë Cash Management – General finance provisions.
• ÑÇÖÞÎÞÂë Advisory Committees

Minnesota Department of Education Policies

MDE Cash Management

MDE processes program expenditures and then submits an invoice(s) for each separate federal year to ÑÇÖÞÎÞÂë, either monthly or more often if necessary, for reimbursement of the expenditures.

MDE uses program-specific project codes to facilitate the tracking of expenditures, obligations, and deposits of federal programs.

MDE Allowable Cost

The program manager determines whether costs are reasonable and necessary following the federal guidelines and the state of Minnesota travel, purchasing, human resources, payroll, and accounting guidelines.

Allowable expenditures are approved at the program level and submitted to the accounts payable/payroll unit for processing. Expenditures are supported by documentation and reports from the state of Minnesota data warehouse.

The program manager runs expenditure and encumbrance reports, reviews them for accuracy and requests corrections as needed.

The federal program accountant updates the federal reconciliation for each grant award showing budgeted, expended, obligated, and unobligated balances. The federal reconciliation are saved to a shared drive for management and program use. The federal program accountant meets with the program manager to review the federal reconciliation, expenditure, encumbrance, and payroll questions as needed. Statewide Financial Policies can be found on the .

Commissioner's Plan (travel reimbursement)

Perkins federal funds may be used to reimburse necessary travel expenses that directly support eligible career and technical education activities. While the IRS publishes annual federal per diem rates for substantiating allowable business travel expenses, Perkins programs in Minnesota must follow the meal reimbursement limits established in the Minnesota Commissioner’s Plan. Under this plan, standard meal reimbursement rates are $11 for breakfast, $13 for lunch, and $19 for dinner. (At specified dates in the year some major metropolitan area rates may be as high as $12 for breakfast, $15 for lunch, and $23 for dinner.) Refer to for additional information. These reimbursement limits must be followed by all individuals traveling with federal grant funds, even when a district’s local reimbursement rate is higher; the most restrictive rate must always be applied when using federal funds. These amounts include tax and gratuity and ensure consistent, compliant, and auditable use of Perkins funds.

State Match Requirements

The state match is the non-federal share of costs MDE contributes to accomplish the purposes of the grant.

The matching funds are not used as a match for any other federal program. The match comes from a non-federal source. The Perkins Grant match largely consists of direct and indirect costs such as personnel salary, fringe, indirect costs, and rent. MDE documents the value of the contributed resource and submits a total contributed amount to ÑÇÖÞÎÞÂë at the end of each calendar year.