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Title IV, Part A - Capacity Building Initiative

Use of Funds

Use of Funds

Smart Spending, Meaningful Impact

 

Every dollar allocated through Title IV, Part A is an opportunity to make a measurable difference in students' lives. To ensure maximum accountability and positive student outcomes, every proposed expenditure must tell a clear story—linking a identified local need directly to an intentional, evidence-aligned strategy.

Key Focus Areas

Before approving or submitting any T4PA expenditure, your district must be prepared to answer and document four essential questions: 

Is it Reasonable & Necessary?

Reasonable: Is the cost consistent with standard market value and prudent business practices? Necessary: Is the purchase essential to carrying out the core goals of your Title IV, Part A project?

Does it map directly to your CCNA?

Which specific student or school need—identified in your Comprehensive Needs Assessment—does this purchase solve?

How will you measure impact?

What metrics or process will you use to evaluate whether this spending positively influenced student achievement and well-being?

Is it Supplemental?

Does this expenditure add to, rather than replace, state or local funding your district would otherwise provide for non-federal programs?

Resources

TEA T4PA Use of Funds One-Pager

Concise guidance provided by TEA on the use of funds for Title IV, Part A

Download

CBI Use of Funds Tool

TBD

Download

TEA T4PA Frequently Asked Questions v.6.0

Answers to commonly asked program-related questions received by the Division

View Resource

Implementing Effective T4PA Program Activities

Guides LEAs on grant allocations, needs assessments, evidence-based activities, and compliance reporting

Download

Frequently Asked Questions

Have additional questions? Contact us and we’ll be happy to help!

  • Purpose
     

    Supplement, Not Supplant (SNS) aims to ensure that federal grant funds are used for their intended purpose and don't replace state or local funding. This helps guarantee that the program benefits the targeted population as intended by the federal government. 

    • Funds must supplement existing programs and services, meaning they should add to, enhance, or expand what is already funded by state and local resources. LEAs will need to know the base state requirements in the 3 T4PA content areas of Well-Rounded Education, Safe and Healthy Schools, and Effective Use of Technology to determine what can be added to, enhanced, or expanded. 

    • LEAs cannot supplant state and local funds, meaning they cannot replace or take the place of state and local funds that were used in the previous year.

    TEA SNS Handbook TEA SNS Voiceover Presentation TEA SNS Presentation

    Supplement, Not Supplant graphic using cupcake to illustrate the difference between local/state requirements and supplemental activities

     

  • Questions to Ask Before Spending Funds

     

    • Is the program or activity required by state or local law? 

      • Using the cupcake analogy, the cake base is state and local requirements for the Title IV, Part A content areas of Well-Rounded Education, Safe and Healthy Schools, and Effective Use of Technology. The content areas heavily overlap with state mandates and could easily create a supplanting issue if T4PA funds were used to meet a state requirement. Although federal T4PA grant guidance may say an activity is allowable for the intent and purpose of the T4PA grant, it is not allowable to use federal funds to meet a state/local requirement. Texas has many legal statutes that require activities that align with T4PA content areas. 

    • Did the LEA provide this activity/service in the prior year using state or local funds? If the answer is yes, LEAs must wait one year before using federal funds to fund the same activity.  

    • Is the activity/service provided to some recipients with federal funds and state or local funds to other recipients? If yes, the expense is not allowable.

  • Educator Training/Professional Development Requirements

     

    Charter School Requirements

    Charter schools must provide many of the public schools' safety and mental health requirements. 

  • TEA has the final say on the allowability of funds. The following resources can help LEAs determine the allowability of a purchase. 

     

    • T4PA programs, activities, and services, which are also mandated by state law, rule, and regulation, State Board of Education (SBOE) rule, or local board policy cannot be funded with T4PA grant funds. LEAs should be aware of the mismatch between what is federally allowable with the grant and the overlap of state mandates to avoid supplanting. 

    • No federal funds may be used to provide a dangerous weapon or training in the use of a dangerous weapon. ESSA Section 8526. 

    • Medical services or drug treatment or rehabilitation are unallowable, except for integrated student supports, specialized instructional support services, or referral to treatment for impacted students, which may include students who are victims of, or witnesses to, crime or who illegally use drugs. 

    • T4PA funds cannot be used for the construction, renovation, or repair of any school facility. ESSA section 8526(1) USDE Response 12/20.

      • These funds may be used for minor remodeling and repair. Minor remodeling refers to minor alterations in a previously completed building. The term also includes extending utility lines, such as water or electricity, from points beyond the confines of the space where the minor remodeling is undertaken but within the confines of the previously completed building. The term does not include building construction, structural alteration to buildings, building maintenance, or repairs.

Title IV, Part A Content Areas

The Title IV, Part A, Subpart 1 statute specifically authorizes activities in each of the three program content areas.

Important Note: LEAs must remember that although an activity may fall in one of the 3 content areas, it may not be allowable because of Traditional Supplement, Not Supplant (SNS) rules. An auditor will always presume a supplant; therefore, districts must be sure to document that the expense is supplemental before it is incurred.

College and career guidance and counseling programs

Music and arts education

Science, technology, engineering, and mathematics (STEM)

Accelerated learning programs

American history, civis, economics, geography, and government education

Foreign language

Environmental education

Volunteerism and community involvement

Multidisciplinary programs

Suicide prevention

Trauma-informed practices in classroom management

Crisis management and conflict resolution

Human trafficking

School-based voilence prevention strategies

Drug abuse prevention

Bullying and harassment prevention

Child sexual abuse awareness and prevention

Positive Behavioral Interventions and Support (PBIS)

 

NOTE: Activities to support SNS may be conducted in partnership with an institution of higher education, business, nonprofit organization, or other public or private entity with a demonstrated record of success in implementing activities described in the statute.

Promoting professional learning for educators

Building technological capacity and infrastructure

Developing or using effective or innovative strategies for the delivery of academic content through the use of technology

Providing students in rural, remote, or underserved areas expanded access to educational opportunities through the use of technology

  • College and career guidance and counseling programs

    Music and arts education

    Science, technology, engineering, and mathematics (STEM)

    Accelerated learning programs

    American history, civis, economics, geography, and government education

    Foreign language

    Environmental education

    Volunteerism and community involvement

    Multidisciplinary programs

  • Suicide prevention

    Trauma-informed practices in classroom management

    Crisis management and conflict resolution

    Human trafficking

    School-based voilence prevention strategies

    Drug abuse prevention

    Bullying and harassment prevention

    Child sexual abuse awareness and prevention

    Positive Behavioral Interventions and Support (PBIS)

     

    NOTE: Activities to support SNS may be conducted in partnership with an institution of higher education, business, nonprofit organization, or other public or private entity with a demonstrated record of success in implementing activities described in the statute.

  • Promoting professional learning for educators

    Building technological capacity and infrastructure

    Developing or using effective or innovative strategies for the delivery of academic content through the use of technology

    Providing students in rural, remote, or underserved areas expanded access to educational opportunities through the use of technology

Timeline

For district planning purposes, suggested operative phases are provided below outlining a multi-month lead time.

May – August

Phase 1: Planning and Pre-Application Districts verify campus data in May and submit programmatic waivers by June 1. Strategic planning requires a Comprehensive Needs Assessment (for allocations ≥ $30,000) to identify allowable activities. Districts must conduct "timely and meaningful" consultation with private nonprofit schools to determine equitable services before making funding decisions. If transferring funds, a 30-day prior notification to the state is required.

September

Phase 2: Application and Obligation Districts submit the ESSA application in September, budgeting according to the 20/20/some portion rules. Financial obligations (placing orders or signing contracts) can only begin on or after the Notice of Grant Award (NOGA) start date. Critical spending caps include a 2% limit on direct administrative costs and a 15% limit on technology infrastructure. All expenditures must be reasonable, necessary, and allocable.

Ongoing throughout Grant Period

Phase 3: Implementation and Reporting Districts manage funds via the ER system, with monthly drawdowns recommended and quarterly submissions required. Spending must follow the approved budget; significant shifts or scope changes require an approved amendment. LEAs engage in ongoing stakeholder consultation to coordinate activities and must submit an annual performance report detailing how funds addressed well-rounded education, safe and healthy students, and technology.

Post-Grant Period

Phase 4: Closeout and Long-term Frequency Within 30 days of the project end, districts must submit a final evaluation report. All financial obligations must be liquidated and reported in final expenditure reports within 90 days. Records must be retained for seven years. Long-term, LEAs receiving ≥ $30,000 must conduct a new Comprehensive Needs Assessment every three years to re-evaluate priorities and ensure continued compliance with allowable use requirements.

Utilize Title IV, Part A funds as a catalyst for innovation, empowering your district to champion well-rounded education, foster safe and healthy school climates, and harness transformative technology that unlocks the full potential of every student.