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Permissible Uses of Perkins Funds Webinar and Guidance

This webinar will served as a refresher on guidance and requirements related to the uses of funds for the Carl D. Perkins Career and Technical Education and Improvement Act of 2006. The webinar discussed required use of funds, permissible use of funds, explanations of basic cost principles, and provided an opportunity to ask questions. Additionally, further guidance has been provided since the webinar has been recorded.  Changes in guidance are further explained below.


An archived version of the webinar and the webinar slideshow can be found below:

Permissible Uses of Perkins Funds Archived Webinar

Permissible Uses of Funds Webinar Slideshow


ICCB has also provided the following memo to clarify guidance:


Perkins Administrators,

In light of recent fiscal findings and subsequent questions, I am writing to clarify guidance on Perkins expenditures specifically for advertising, marketing, and promotional activities.

The Education Department General Administrative Regulations (EDGAR), 2 CFR 200.421 states the following:

  • 200.421 (a-b)- Allowable
  • The term advertising costs means the costs of advertising media and corollary administrative costs. Advertising media include magazines, newspapers, radio and television, direct mail, exhibits, electronic or computer transmittals, and the like.
  • The only allowable advertising costs are those which are solely for:
    (1) The recruitment of personnel required by the non-Federal entity for performance of a Federal award (See also §200.463 Recruiting costs);
    (2) The procurement of goods and services for the performance of a Federal award;
    (3) The disposal of scrap or surplus materials acquired in the performance of a Federal award except when non-Federal entities are reimbursed for disposal costs at a predetermined amount; or
    (4) Program outreach and other specific purposes necessary to meet the requirements of the Federal award.
  • 200.421 (e)- Unallowable

(e) Unallowable advertising and public relations costs include the following:

(1) All advertising and public relations costs other than as specified in paragraphs (b) and (d) of this section;
(2) Costs of meetings, conventions, convocations, or other events related to other activities of the entity (see also §200.432 Conferences), including:

(i) Costs of displays, demonstrations, and exhibits;
(ii) Costs of meeting rooms, hospitality suites, and other special facilities used in conjunction with shows and other special events; and
(iii) Salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, and providing briefings;

(3) Costs of promotional items and memorabilia, including models, gifts, and souvenirs;
(4) Costs of advertising and public relations designed solely to promote the non-Federal entity.

As interpreted, marketing and advertising in the form of tangible items such as t-shirts, pens, notepads, lanyards, cups, etc. are not allowable expenditures of federal grant funds. Although we have maintained that promotional items for “give-aways” at marketing and recruiting events were not allowable, we have historically allowed using tangible items for advertising purposes when specific and justifiable criteria were met. This is no longer the case.

Federal guidance, such as EDGAR, is not always prescriptive, allowing states and its cognizant agencies a certain level of flexibility. However, from this point forward, only advertising as described verbatim in 2 CFR 200.421 will be allowable. In all circumstances, grant recipients should continue to prioritize funding appropriately and ensure that all grant expenditures are necessary, reasonable, and allocable.

We are working to revise the Carl D. Perkins Postsecondary Grant Manual and other resources to reflect this specific language in addition to other minor modifications. If your FY2018 Perkins planning efforts include such expenditures, please plan to reallocate accordingly. Since these expenses would have been limited and likely not explicit in the budget, it is likely that a budget modification will not be applicable; however, please follow current budget modification processes when appropriate.  If you have specific questions, please reach out to me or your CTE Perkins liaison.


Whitney Thompson
Director for Career and Technical Education
Illinois Community College Board

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