Allocations and Operations

Expenditure Information Page


General Spending Requirements

Necessary and Reasonable 

All costs charged to federal education grants must be necessary and reasonable considering the amount of money being spent and the needs of the program. This requirement comes from a set of federal regulations known as the Uniform Grant Guidance (UGG), which applies to all federal grants, including U.S. Department of Education grants.

Included in LEA Application

Activities supported by the individual grants must be consistent with the LEA’s application for funds approved by the Ohio Department of Education, as required by federal law. 

District applications are developed and submitted through the CCIP. The CCIP is a consolidated grants application and verification system that consists of two parts: the Planning Tool and the Funding Application. The Planning Tool contains the comprehensive needs assessment, goals, strategies, action steps and district funding levels for all grants in the CCIP.  The Funding Application contains the budget, budget details, nonpublic services and other related pages.


Some ESSA programs require LEAs to spend on activities that are supported by evidence, are demonstrated to be effective or that are consistent with a formal needs assessment. Even where this is not required, U.S. Department of Education grant spending has the most impact when LEAs spend federal funds on effective activities designed to meet program goals. To do this, LEAs are encouraged to:

  •  Carefully consider the needs of students, educators and other relevant stakeholders;
  •  Determine which activities are most likely to effectively address those needs; and
  •  Prioritize those activities when deciding what costs to support with ESSA funds (unless     those activities are being paid for by other funding sources).


Uniform Grant Guidance (UGG) 

  • Lists of costs that may never be paid for with federal funds. For example, federal funds can never pay for alcohol and typically cannot pay for lobbying.
  • Lists of general criteria all costs supported with federal funds must satisfy. For example, federal funds can only pay for costs that are allocable to the relevant grant.
  • Sets additional requirements for certain costs supported with federal funds. For example, LEAs that use federal funds for employee salaries and benefits must keep records documenting how much time the employees spent on grant activities.
  • Sets rules for how LEAs procure goods and services with federal funds, how they track items paid for with federal funds and the kinds of records they must keep about their grant spending.
  • USDE Uniform Grants Guidance for Federal Funds

Maintenance of Effort

Maintenance of Effort is an Elementary and Secondary Education Act (ESEA) fiscal requirement under Section 9521, that requires districts to demonstrate that the level of state and local funding remains relatively constant from year to year in order to receive the district’s full allocations of the grants under ESEA. A district’s education expenditures from general fund must be at least 90 percent of the prior year amounts. It is the State’s responsibility to determine annually whether a district has maintained effort. 

Access Maintenance of Effort and login with your OH|ID credentials. 


Comparability is a Title I fiscal requirement [ESEA, 1120A(c)] that is intended to demonstrate that a local school district is using Title I funds to supplement, and not supplant, non-Federal funds that would otherwise be used for authorized activities under Title I-A. To be eligible to receive Title I funds, a Local Educational Agency (LEA) must use state and local funds to provide services in Title I schools that are at least comparable to services provided in non-Title I schools. If the LEA serves all of its schools with Title I funds within a particular grade span, the LEA must use state and local funds to provide services that are substantially comparable in each school.

Demonstrating comparability is a prerequisite for receiving Title I funds. Because Title I allocations are made annually, comparability is an annual requirement. The Comparability Web-based system enables districts to perform the necessary calculations annually to demonstrate that all of its Title I schools are in fact comparable.

Access Comparability and login with your OH|ID credentials.

Supplement, Not Supplant

Federal funds shall be used to supplement, and not supplant, non-Federal funds that would otherwise be used for authorized activities under certain ESEA programs including, but not limited to, Title I-A, Title I-C, Title II-A, Title II-D, Title IV-A and Title V-B.  In general, federal funds must enhance, add to and supplement services and programs that are offered with state and local funds; federal funds may not be used to replace any services and programs that were offered using state and local funds. Click for a PowerPoint presentation of ODE Guidance on Understanding Title IA – Supplement, Not Supplant


Last Modified: 3/25/2024 8:54:09 AM