Making Sense of Federal Rules | Origin: LC160
Did it surprise you to learn how many different rules apply to the Perkins program? How do you think the challenges of navigating multiple sets of rules might affect program implementation?
The number of rules did not surprise me. What genuinely surprised me, within my role, was how rarely the people closest to actual implementation can name the rules themselves. I've been writing federal grants and managing CTE programs long enough to expect the layering: statute, EDGAR, UGG, state plan, then district policy on top. The structure makes sense once you see it. What's harder is that most of the friction I encounter day-to-day -- slow approvals, denied requests, "we can't do that with Perkins" responses -- traces back to 'compliance anxiety' somewhere in the chain, and the person delivering the "no" often cannot cite which rule the "no" derives from. From my observation, that is a lot of decisions getting made on conservative pattern-matching rather than on actual regulation.
The practical effect on implementation is then twofold.
First, conservative interpretation is a good-program-killer. If a fiscal officer isn't sure whether a cost is allowable, the safe move is to deny it. That decision is functionally invisible -- but with it leaves behind a wake of consequence --> that teacher doesn't get the equipment they need, the program quietly underperforms, and nobody traces the failure back to a rule that may not have actually prohibited the purchase....(the same story many of us encounter) and of course nobody catches it until it's time to assign blame.
Second, the obligation timeline creates a serious strategic problem. Funds that aren't legally committed on-time disappear, which pushes spending toward whatever's easiest to obligate (consumables, known vendors, recurring contracts) rather than what would most advance the program (diversifying vendors, proactive equipment spending, updating and upgrading current equipment, or pursuing new certifications without requiring an army to validate the change). The work I'm doing right now to document allowable costs under EDGAR and UGG -- and to be able to point to the specific authority -- is essentially about shifting the burden of proof back where it belongs, so that program decisions are made on what's actually permitted rather than what 'feels' safest to approve.
The other piece I'd flag is state authority. This adds a layer that's easy to miss. Illinois, for example, can deny an otherwise-allowable activity if it determines the size/scope/quality (etc) or necessary-and-reasonable standards aren't met, and those state-level determinations vary year to year. So even mastering federal rules doesn't fully de-risk a request or a situation -- you also have to know how your state is currently interpreting them. Digging into how IL is currently interpreting these is my next move!
I was not surprised by the rules and regulations. However, I do find it overwhelming the process and details involved in the spending of perkins funding.
Not really, I have some familiarity with Perkins funding.
Yes. I was surprised at the rules. This is the first time that I have worked with Perkins funding. I was aware of UGG but not the other rules and regulations.
No, as the Director for CTE, I'm well aware of the requirements for Perkins
No, I was not surprised at the laws and regulations set in place to navigate Perkins V.
No, it did not surprise me. Federal funding usually does require lots of regulations.
I was not surprised. The Perkins program, which funds career and technical education initiatives, is subject to a complex web of rules stemming from federal legislation, state regulations, and individual school district policies, meaning there can be multiple layers of guidelines to follow depending on the specific context, potentially leading to challenges in program implementation due to the need to navigate and comply with various sets of rules across different levels.
I did not find it surprising, but when I work on the application, I find it overwhelming. Navigating the ins and outs of the federal regulations and the state's regulations can be burdensome, and I believe the state must update its plan in 2024, so changes will probably be coming.
No, I was not surprised by the distribution rules relating to Perkins funding.
No, I would be shocked if there were not guidelines when spending grant funding.
No, I wasn't surprised at the rules. However, after seeing the links to the statutes and regs, I am surprised there isn't more ongoing PD. I also am intrigued to learn more about how we can blend together industry funding, school budgets, and the Perkins grant to maximize programs.
I was not surprised at all. With a program of this size, there must be checks and balances. However, it can be very challenging on the local level to understand the regulations without proper training.
I am not surprised by the regulations of Perkins fund spending. However, it does seem difficult to navigate all of the information.
No, it did not surprise me. These are taxpayer dollars. You must document and follow strict guidelines.
I wasn't surprised. It's important that regulations be set forth to ensure the funds are being used appropriately.
It is not surprising. Any time you receive funding from the government there will be regulations that need to be followed.
No surprise of the rules and regulations related to spending the grant. Federal and state money always seem to have regulations. However, this information was informative as I am fairly new to the grant.
There is no surprise for the many regulations for the Perkins funding. Due to the multiple layers of Perkins fund distribution and the management is not the same as other Federal programs that are given directly to the institution instead of through the state's department of education, many in leadership roles that are not directly involved in the Perkins processes do not realize the volume of regulations that must be followed.
