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REAP outlines allowable SRSA uses, supplement-not-supplant rules and Alternative Fund Use Authority
Summary
Presenters reviewed that SRSA funds may be used for activities allowable under ESEA titles I, II, III, IV and IV-B, emphasized the supplement-not-supplant presumptions and documentation expectations, and explained the Alternative Fund Use Authority allowing flexibility for Title II-A and IV-A funds for eligible LEAs.
Jordan Haydel reviewed allowable SRSA expenditures and compliance obligations, stressing that SRSA funds must be reasonable, necessary, allowable and allocable and must comply with the supplement-not-supplant requirement.
“You are free to use your awarded SRSA grant funds for any allowable activity, and you are free to change how you wish to spend your grant monies at any point during the 27 month grant performance period,” Jordan said, while reminding grantees it remains their responsibility to ensure each use meets supplement-not-supplant requirements.
Jordan listed three common presumptions that trigger a presumption of supplanting: when an activity ordinarily would be paid with other federal/state/local funds (for example, routine textbook purchases), when the LEA previously funded the activity with other funds, or when an activity is state- or federally-mandated. In those cases, Jordan said, grantees must demonstrate the activity is supplemental.
On the Alternative Fund Use Authority (AFUA/FUA), Jordan explained that SRSA-eligible LEAs may elect to use Title II-A and Title IV-A funds with the same spending flexibilities as SRSA funds; AFUA does not authorize transferring funds between statutory programs but provides spending flexibility. Jordan noted LEAs must notify their SEA if they intend to exercise this authority and encouraged LEAs to consult their state coordinators for SEAs’ notification deadlines.
Why it matters: These rules determine whether SRSA funds can lawfully pay for a given activity and whether documentation will be needed to defend that choice in an audit or monitoring review.
Next steps: LEAs should consult the REAP use-of-funds guide and the REAP informational document linked on the REAP resources webpage and retain clear records showing why SRSA funds were used rather than other funding sources.
