Determining Supplanting vs Supplementing
The critical question in determining whether there has been a supplanting violation is whether federal funds were used instead of funds from non-federal sources. It will have to be shown that the federally funded activity would not have been funded by state or non-federal sources. When auditors review compliance with non-supplant rules, they often use the following test: What would the recipient have done in the absence of federal funds? If the project could have been completed without non-federal funds, there will be the presumption of supplanting. During the audit appeal process evidence would be required to disprove that presumption.
On the other hand, if the auditor were to find evidence that in the absence of those federal funds, the specific activity or program could not have been carried out, there would be no presumption of supplanting.
Think of it this way – The law is designed to ensure that federal funds pay for something extra! NOT pay for ‘day to day’ operational costs including basic teacher and student supplies.
The Test! You can presume Supplanting if: 1. Perkins funds are used to provide services the recipient is required to make available under other federal, state or local laws. 2. Perkins funds were used to provide services the recipient provided with State or Local funding the prior year.