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 District Application

Activities supported by the individual grants must be consistent with the district's application for funds approved by the Ohio Department of Education, as required by federal law. District applications are developed and submitted in the Comprehensive Continuous Improvement Plan (CCIP). Final approved versions of the district application can be accessed in the CCIP.

Evidence-Based

Some Elementary and Secondary Education Act (ESEA) programs require districts 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 districts spend federal funds on effective activities designed to meet program goals. To do this, districts 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 ESEA funds (unless     those activities are being paid for by other funding sources).

Allocations

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, districts 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 districts 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.
  • U.S. Department of Education Uniform Grants Guidance for Federal Funds

Maintenance of Effort

Maintenance of Effort is an ESEA fiscal requirement. Districts must 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 OHID credentials. 

Comparability

Comparability is another Title I fiscal requirement. To be eligible to receive Title I funds, a district 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 district serves all of its schools with Title I funds within a particular grade span, the district 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 its Title I schools are in fact comparable. It is important to note that some districts are exempt from conducting comparability calculations, for example single-school districts such as community schools or traditional districts that do not have overlapping grade spans.
Access Comparability and login with your OHID credentials.

Supplement, Not Supplant

In general, ESEA Title grant funds must be used to supplement, not supplant state and local, and in some cases, other federal education resources. The federal Title grants that have a supplement, not supplant requirement include, but are not limited to, Title I-A, Title I-C, Title I-D, Title II-A, Title III, Title IV-A and Title V-B.  For Title I-A, districts must demonstrate that the allocation of their state and local resources to schools is neutral of Title I-A funds (i.e. schools recieve the allocation of state and local resources regardless of the amount recieved under Title I-A). Most districts are required to have a supplement, not supplant methodology for Title I-A. For Title I-C, I-D, II-A, and IV-A, federal expenditures must supplement, not supplant state and local education expenditures. For Title III and V-B, grant expenditures must supplement other federal expenditures in addition to state and local expenditures. More information on the Title grant supplement, not supplant requirements can be found in the resources below.

Resources

Last Modified: 2/3/2026 2:07:00 PM