But you may supplement. If you’ve ever read through a NOFA from the Department of Education, chances are you’ve come across the clause stating that federal funding may “supplement, but not supplant,” state/local funding. But what exactly does that mean? (This post was updated on May 1, 2018)
Defining "Supplant" and "Supplement"
Let’s start with the definitions. “Supplement” means to “build upon” or “add to”; “supplant” means to “replace” or “take the place of.” Federal law prohibits recipients of federal funds from replacing state, local, or agency funds with federal funds. Existing funds for a project and its activities may not be displaced by federal funds and reallocated for other organizational expenses. This is illegal. On the other hand, federal agencies encourage supplementing—that is, adding federal funds to what is available in state, local, or agency funds.
The Texas Educational Agency provides the following example of illegal supplanting of federal grant funds:
A program coordinator, working with the parent involvement component of a campus, is paid from local sources. The local school district receives new grant funds to provide literacy services to parents within the campus and transfers the coordinator’s salary to the new grant, since the population that is being served [comprises] the same parents that are participating in the parent involvement center.
The program coordinator was already paid by local sources, so it's not legitimate to transfer that position's salary under the funding of the new grant.
Now an example of a proposal to legally supplement existing programs with federal funds. The Board of Education for Clarke County, Alabama, was awarded a Title I “Improving Literacy Through School Libraries” grant from the Department of Education for a program focused on updating its print materials to improve the quality of education. Addressing the requirement for “broad-based involvement and coordination,” the successful applicant clearly bulleted how federal funding would "build upon" programs and detailed the funds already available in the county system, including state library enhancement funds and technology funds. (eCivis Grants Network subscribers should refer to page 15 of this previously funded application for more details.)
Critics of the Rule
“Supplement, not supplant” is not without its detractors. Critics have pointed out that compliance with this rule can be an enormous administration burden for Title I recipients and can prevent effective spending of funds for comprehensive and innovative programs, because spending must be accounted for on a cost-by-cost basis. This issue will be taken up in a future eCivis blog post.
What's your take on this topic? Leave us a comment below.
To learn more about supplanting, check out our article on the subject from a Department of Justice perspective.
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