Revision 1 Attachment G- IRSSP RFA 26-28 - Grant Expenditure Guidance 2026-28.pdf

Grant Expenditure Guidance Student Success Plan Grants

Office of Equity, Diversity, and Inclusion

OVERVIEW

This document provides information on whether and to what extent Student Success Plan (SSP) grant funds may be used for various types of expenditures, as well as best practices and guidance for developing a budget. In addition to the detailed guidelines provided below, all grant expenditures (whether proposed as part of a grant application, or submitted for reimbursement after receiving a grant award) will be evaluated by ODE staff alongside the proposed or approved project plan to determine whether the expenses are reasonable and necessary for the performance of the award.

Determining “Reasonable and Necessary” Expenses We recognize that each Grant Project is unique and specifically designed to elicit systems change and meet the specific needs of Plan students through the implementation of Student

Success Plan strategies, and as such, the allowability of many expenditures must be contextualized on a case-by-case basis. In determining what constitutes reasonable and necessary for performance of the grant, ODE staff will examine each budget line item with the following questions in mind. In addition, expenses labeled as “Requires Additional Review” throughout this document may be submitted for consideration by sending an email to your coordinator with responses to the following questions:

1. Will the expense be incurred during the period of performance for project activities that will occur during the performance period?

2. How is this expense necessary to implement the approved Project Plan?

3. Which strategies of the Student Success Plan* are addressed by the expense?

4. How does the expense prioritize direct service to focal groups served by the Plan?

5. Is there any local context that affects what is considered reasonable and necessary?

6. Does the expense reflect sound business practices and rates that a prudent person would pay in similar circumstances?

*African-American/Black SSP | LGBTQ2SIA+ SSP | Latino/a/x and Indigenous SSP | Native

Hawaiian/Pacific Islander SSP | Immigrant/Refugee SSP

ODE Student Success Plan Grant Expenditure Guidance_v11-05-2025 1 https://www.oregon.gov/ode/students-and-family/equity/AfricanAmericanBlackStudentEducation/Pages/HB2016AdvisoryGroup15-16.aspx https://www.oregon.gov/ode/students-and-family/equity/LGBTQ2SIAStudentEducation/Pages/LGBTQ2SIA--Student-Success-Plan-Rules.aspx https://www.oregon.gov/ode/students-and-family/equity/Latinx/Pages/Latinoax-%26-Indigenous-Student-Success-Plan0629-6188.aspx https://www.oregon.gov/ode/students-and-family/equity/NativeHawaiianPacificIslanderEducation/Pages/OARS.aspx https://www.oregon.gov/ode/students-and-family/equity/NativeHawaiianPacificIslanderEducation/Pages/OARS.aspx https://www.oregon.gov/ode/students-and-family/equity/IRSS/Documents/1.10.2025_Final_Interim_I_R%20Student%20Success%20Plan-Accessible%20PDF.pdf

TABLE OF CONTENTS

OVERVIEW

Determining “Reasonable and Necessary” Expenses

BUDGET DEVELOPMENT GUIDELINES

How to Complete Your SSP Budget

Conflicts of Interest

USE OF GRANT FUNDS

1. Personnel

2. Contracted Services

3. Travel & Transportation

4. Supplies & Materials

6. Indirect Costs

7. Miscellaneous

8. Claim Reporting Requirements

9. Food Cost Guidelines

HELP

DEFINITIONS

* To request approval of an expense that requires additional review/approval, send an email to your coordinator responding to the questions listed on page 1 of this document.

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BUDGET DEVELOPMENT GUIDELINES

How to Complete Your SSP Budget When creating your ODE Student Success Plan grant budget, keep in mind that all expenses must be readily allocable to the grant project, and part of a comprehensive plan to implement activities utilizing the Student Success Plan strategies to achieve the statutory objectives. To ensure your budget provides sufficient information for ODE to understand how you will invest grant funds to carry out the project, follow these guidelines:

1. Each line item must include a description of the expense, including details that illustrate how the expense is calculated/estimated (e.g., the cost per participant and number of participants; the mileage reimbursement rate and how many staff or FTE will be traveling; the number of events and how many participants will attend; the names or types of professional development and cost per participant, etc).

a. For Personnel, include the position title and proportion of FTE allocated to the grant. For seasonal or hourly staff, you may provide anticipated weekly (or monthly, etc.) hours instead of FTE and any other pertinent information, such as time period the staff member will be working on the grant, if not throughout the full budget period.

b. For contracted services over $5k, attach a detailed Statement of Work (SOW), Contract, MOU, or other document detailing services and deliverables to be provided and cost for each service. Note: Detailed invoices showing work completed, dates of service, and cost for each service (aligned to the contract) must be attached when claiming against this line item. In addition, ensure compliance with the Conflicts of Interest guidelines below.

2. Select the expense sub-category that most accurately describes the expense. If a particular activity or event includes costs from more than one expense sub-category, report each sub-category as a separate line item.

3. Provide a brief justification for the expense to describe what purpose or need the expense serves for the project, including activity/ies supported by the expense (identify activities by the Activity Numbers from your Activity Table).

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4. For all direct costs, enter the budgeted amount in the appropriate column/s (direct administrative and/or direct service). Direct administrative costs may not exceed 10% of the total grant amount (i.e., for a $200,000 grant, direct administrative costs may not exceed $20,000).

5. At the bottom of the budget, enter the indirect costs being charged to the grant. Ensure that the indirect cost amount is calculated at or below the maximum allowable rate as a percentage of the direct costs allocated to the grant. (The maximum allowable indirect cost amount will be automatically calculated at the top of the budget based on the total award amount and indirect cost rate. For more information, see how to calculate indirect costs.)

6. If applicable, add budget comments in the space provided at the bottom of the budget to explain any circumstances that impact or explain your budget, such as large expenses for the grant project that are covered by other sources, etcetera.

Conflicts of Interest We understand some projects work in communities with few experts in certain cultural practices, and that in order to offer culturally appropriate and affirming services to youth, a grantee may be in a position to consider contracting with or hiring someone who has a personal or familial relationship to staff or Board members of the grantee organization. This may present a situation which would (actual conflict of interest) or could (potential conflict of interest) result in a financial benefit or detriment for the staff or Board member, a relative of the staff or Board member, or any business with which the staff or Board member or their relative is associated.

In cases where you foresee the potential to hire or contract with an individual (or a company owned by an individual) who is working for the project or related to anyone working for the project, notify your SSP coordinator in advance and provide the following information in writing about the procurement process to ensure you have adequately addressed the perception of conflicts of interest:

1. Describe the work needed, the reasonable associated costs, and method used to determine this figure.

2. Will the opportunity be posted publicly?

3. What is the nature of the actual or potential conflict of interest?

ODE Student Success Plan Grant Expenditure Guidance_v11-05-2025 4 https://docs.google.com/document/d/1q0Kzg5CfaMBTGqGAGn5xiqNv8SBQ26dFGgwZB-Yudrg/edit#heading=h.vez54nxtwze0 https://docs.google.com/document/d/1q0Kzg5CfaMBTGqGAGn5xiqNv8SBQ26dFGgwZB-Yudrg/edit#heading=h.vez54nxtwze0

4. Why is this individual or entity the best candidate for the role or service that you would like to hire them for?

USE OF GRANT FUNDS

1. Personnel

1.1. Allowable: Salary and personnel expenses (benefits) for staff performing work directly related to grant activities, including providing direct service to students, supervision of direct service delivery, and staff time to collect and report progress, outcome, and demographic data required by ODE. Salaries and fringe benefits may be charged as a direct cost only in the proportion of FTE directly allocable to the approved grant program. Note: contracted staff and positions paid under agreements with partners must follow the same guidelines and be included in the Contracted Services section of the budget. See also: relevant claim reporting requirements.

1.2. Unallowable: Salary and personnel expenses for staff performing administrative work that benefits the grantee organization as a whole and is not readily allocable to the approved grant program may not be charged to the grant except through the recovery of indirect costs, according to the guidelines stipulated in this document.

1.3. Unallowable: Please refer to the miscellaneous section.

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2. Contracted Services

2.1. Allowable: Contracted professional services (e.g., mental health counseling) for participants and/or for staff who provide direct service to participants. ODE may request documentation, including but not limited to: the solicitation process used to select the contractor, certificates of insurance (if required), and contracts and/or invoices for services rendered. If youth are contracted to perform work of the grant program (e.g., tutoring services), the following information should be provided: Who are the youth providing the contracted service? How are they recruited? What training/supports do the youth providing tutoring services receive to ensure the tutoring provided is appropriate? How are the tutoring services provided evaluated and tracked? For additional guidance on contracting with youth workers, see Additional definition and guidelines available below.

Note: See guidelines around budgeting requirements for contracted services in section 1a of the Budget Development Guidelines.

2.2. Allowable: Contracted services necessary to conduct grant activities, such as site rental costs, and childcare and translation/interpretation services to reduce barriers to participation. Note: Site rental costs or use fees allocable to the grant for facilities specifically procured for purposes of the approved grant activities may be charged as a direct cost. Facilities costs for the organization in general are considered indirect costs (as noted below).

2.3. Allowable: Speaker fees incurred for events, conferences, seminar series, or any other gathering where the speaker’s participation is reasonable and necessary for successful performance of the goals and activities of the grant program.

Justification for the need for hiring the speaker must be provided. The maximum allowable amount for speaker fees is $5,000 per day (except by special request/approval*); travel costs for speakers are not eligible for reimbursement.

2.4. Allowable: Reasonable, allocable, and necessary professional development and training, including education certifications (such as SIOP, SEL, or QTEL for example) for staff who provide direct service to students for approved project activities, stipends for participants, costs for sub coverage, overtime costs, and in-state travel, in accordance with all applicable collective bargaining contracts.

Professional development for educators may be paid for by the grant only when it is not part of district-mandated professional development. Educators may only

ODE Student Success Plan Grant Expenditure Guidance_v11-05-2025 6 receive compensation for participation in professional development when the training is held outside of contracted work time.

2.5. Requires Additional Review*: Travel costs for out-of-state conferences or events.

2.6. Requires Additional Review*: Tuition and/or other costs related to education endorsements, teacher/admin licensure, and/or licensure fees.

2.7. Requires Additional Review*: Scholarships and tuition assistance.

2.8. Unallowable: Participation incentives, such as gifts, gift cards, cash, check, e-payment (e.g., Venmo, Cash App) to individuals participating in the program, including paying school staff within school hours to attend mandated PD.

2.9. Unallowable: Please refer to the miscellaneous section.

3. Travel & Transportation

3.1. Allowable: Reimbursement for mileage at the state approved rate, vehicle rental, and charter transportation for travel necessary to accomplish grant program activities.

3.2. Allowable: Participant transportation costs (such as bus or metro passes, mileage reimbursement at state per diem rate, or fuel cards) to reduce barriers to participation in grant activities.

3.3. Requires Additional Review*: Costs related to out-of-state travel.

3.4. Unallowable: Please refer to the miscellaneous section.

ODE Student Success Plan Grant Expenditure Guidance_v11-05-2025 7 https://www.gsa.gov/plan-book/transportation-airfare-pov-etc/privately-owned-vehicle-pov-mileage-reimbursemen?gsaredirect=mileage

4. Supplies & Materials

4.1. Allowable: All consumable materials required for program delivery. This may include, but is not limited to: office supplies; postage; printing; course materials and curriculum; limited event supplies such as food and presentation materials;

and other reasonable, allocable, and necessary costs for implementing the approved project. For guidelines/limitations on food costs, see the Food Costs

Guidelines section.

4.2. Allowable: Vouchers (e.g., school supply voucher, fuel cards, and food cards or vouchers that state no alcohol or tobacco may be purchased), emergency clothing or personal hygiene products for participants experiencing hardships.

These vouchers and supplies may be valued at no more than $50/family per fiscal year.

4.3. Allowable: Expenditures related to advertising and outreach costs that are solely for the purposes of: (a) recruiting participants specifically for approved Project activities, or b) recruitment of personnel for Project activity and/or objective.

4.4. Requires Additional Review*: Clothing, shoes, uniforms, or other supplies for participants except as described in section 4.2.

4.5. Unallowable: Supplies for general organization use not clearly allocable to grant program activities.

4.6. Unallowable: All advertising costs other than specified above.

4.7. Unallowable: Please refer to the miscellaneous section.

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5. Equipment

5.1. Allowable: Equipment required to administer the grant Project can be purchased once per grant cycle for the Grant Project. Items purchased with grant funds must be reasonable, allocable, and necessary to implement the grant Project.

Note: Office equipment expenditures charged to the grant are a direct administrative cost.

5.2. Allowable: Electronic devices and equipment for student or participant use that are reasonable, allocable, and necessary to implement the approved grant

Project (e.g., laptops, tablets, headsets for listening to translations, or other electronic devices that are necessary to implement the approved grant program).

5.3. Unallowable: Capital assets such as furniture, playground equipment, renovation costs, vehicles, etc.

5.4. Unallowable: Please refer to the miscellaneous section.

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6. Indirect Costs

6.1. Allowable: Indirect costs are allowed as a percentage of the direct costs of the grant at the following rates:

6.1.1. Up to five percent for school districts, public charter schools, early learning hubs, or post-secondary institutions of education;

6.1.2. Up to fifteen percent for community-based organizations, culturally specific organizations, or providers of early learning services;

6.1.3. Up to fifteen percent or federally approved indirect rate for Tribes.

6.1.4. Indirect costs for partnerships or consortiums will be allowed based on the lead entity’s organization type.

6.2. Unallowable: Indirect costs in excess of the approved rate based on lead/grantee entity type, and as identified in the grant agreement.

6.3. How to calculate indirect costs

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Example 1: Calculate indirect costs based on the total direct costs

$183,260.45 Total Direct Costs (the total of all budget categories before indirect costs) x 0.15 Multiply by your approved rate as a decimal (in this example, 15% becomes 0.15)

$27,489.07 Total Indirect Costs

Example 2: Calculate Indirect costs based on the total grant amount

Step 1: Calculate Total Direct Costs

$ 200,000.00 Total Grant Amount

÷ 1.15 Divide by 1+ your approved indirect rate as a decimal (in this example, 15% becomes 1.15)

$ 173,913.04 Total Direct Costs

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7. Miscellaneous

7.1. Unallowable: Costs to establish or support at-home office spaces.

7.2. Unallowable: Costs related to grant writing or fundraising activities.

7.3. Unallowable: Religious activities or services.

7.4. Requires Additional Review*: Charging rent, utilities, and insurance premiums (or other costs typically considered indirect/overhead/facility and administration costs) as direct costs of the grant. Any request for approval of classification of costs typically considered “indirect” as direct costs must be accompanied by supporting documentation demonstrating the organization’s policies for how direct and indirect costs are allocated.

7.5. Requires Additional Review*: Scholarships and tuition assistance.

7.6. Unallowable: Participation incentives, such as gifts, gift cards, cash, check, e-payment (e.g., Venmo, Cash App) to individuals participating in the program, including paying school staff within school hours to attend mandated PD.

Vouchers and other support to reduce barriers to participation are allowable as described in the Contracted Services, Travel, and Supplies sections. Stipends as payment for services rendered in support of the approved project plan are allowable as described in the Contracted Services section.

7.7. Unallowable: Stipends or honoraria that are not reasonable, necessary, and allocable to the grant program.

7.8. Unallowable: Entertainment, gifts with a monetary value more than $50, and recreational or sport activities that are not directly related to the implementation of plan strategies and/or are not reasonable, allocable, and necessary to accomplish the approved project plan.

8. Claim Reporting Requirements

8.1. Claims must be submitted quarterly. Monthly claim processing may be allowed upon request.

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8.2. Claims are submitted in EGMS and must be supported by an expenditure report in Smartsheet showing claims against the approved budget, and including justification and progress on the approved project plan.

8.3. Grantees may be required to submit additional documentation to support their claim, including but not limited to transaction ledgers and detailed invoices/receipts.

8.4. For Personnel costs, grantees must provide staff member name, job title, percentage FTE, or hourly rate and anticipated total hours.

9. Food Cost Guidelines

9.1. Allowable: SSP grants may be used for providing food for approved project activities, at the rates established for your county by the General Services

Administration (see below for how to determine the per-meal, per-participant food allowances for your location).

9.1.1. All meal costs are limited to the General Services Administration per diem rates for Oregon: Go to the Per Diem Rates | GSA webpage.

9.1.2. Enter the year (it should default to the most current year), the state, city, and ZIP code. Please use the city you are hosting the meeting in.

9.1.3. Click “Find Rate.”

9.1.4. Scroll down to the Meals and Incidental Expenses (M&IE) rates and breakdown section.

9.1.5. Incidentals (for example, delivery fee or tip) need to be included within the amount provided.

9.2. Requires Additional Review*: Food costs over the per-meal, per-participant limits described above.

ODE Student Success Plan Grant Expenditure Guidance_v11-05-2025 13 https://www.gsa.gov/travel/plan-book/per-diem-rates

HELP

If you have questions about any of the information provided in this document, or need to request approval of a grant expenditure, contact your Student Success Plan Coordinator or

Miriam.Neidhardt.Mcphee@ode.oregon.gov.

Student Success Plan Program Coordinator

All Grants miriam.neidhardt.mcphee@ode.oregon.gov

African American / Black Student Success Plan april.negrette@ode.oregon.gov

Latino/a/x Student Success Plan Susan.Mekarski@ode.oregon.gov

LGBTQ2SIA+ Student Success Plan Angie.Foster-Lawson@ode.oregon.gov

Native Hawaiian/ Pacific Islander Student Success Plan

Carol.Matsuzaki@ode.oregon.gov

Immigrant / Refugee Student Success Plan ode.immigrantrefugee.success@ode.oregon.go v

Additional information is available in this video tutorial of how to update your budget and activity table in Smartsheet, including tips on using the Smartsheet platform as well as general best-practices and guidelines for grant budget development.

DEFINITIONS

Allocable: Costs incurred specifically to implement the approved grant activities, or portions of costs shared among other programs which can be reasonably apportioned to the grant program based on proportional benefit. For example, if a full-time staff member is assigned to run two programs (the ODE grant program and another program not related to the ODE grant) and half of their work time is spent on the ODE grant program, that means .5 FTE for that staff member is allocable to the ODE grant.

ODE Student Success Plan Grant Expenditure Guidance_v11-05-2025 14 mailto:miriam.neidhardt.mcphee@ode.oregon.gov mailto:miriam.neidhardt.mcphee@ode.oregon.gov mailto:april.negrette@ode.oregon.gov mailto:Susan.Mekarski@ode.oregon.gov mailto:Angie.Foster-Lawson@ode.oregon.gov mailto:Carol.Matsuzaki@ode.oregon.gov mailto:ode.immigrantrefugee.success@ode.oregon.gov mailto:ode.immigrantrefugee.success@ode.oregon.gov https://drive.google.com/file/d/1nBFwgk8kFQYEdoSAgyv__yP-62Qz0Wvr/view?usp=sharing

Capital Asset: Assets or property (whether tangible or intangible) with a useful life beyond the contracted grant life.

Capital Expenditure: Expenditures to acquire capital assets or to make additions, improvements, modifications, replacements, rearrangements, reinstallations, renovations, or alterations to capital assets that materially increase their value or useful life.

Community Based Organization (CBO): A nonprofit organization that is reflective of a community or significant segments of a community it seeks to serve.

Contracted Services: A service provided to the grantee organization that is fully or partially funded using SSP grant dollars through an agreement between a business, organization, or individual who the grantee agrees to pay for a determined service.

Culturally-Specific Organization (CSO): An organization that serves a particular cultural community and is primarily staffed and led by members of that community; these organizations demonstrate: intimate knowledge of lived experience of the community, including but not limited to the impact of structural and individual racism or discrimination on the community;

knowledge of specific disparities, barriers or challenges documented in the community and how that influences the structure of their program or service; commitment to the community’s strength-based and self-driven thriving and resilience; ability to describe and adapt their services to the community’s cultural practices, health and safety beliefs/practices, positive cultural identity/pride, religious beliefs, etc.

Direct costs: Costs that are directly and readily allocable to the activities of the grant, and which provide measurable, direct benefits to the grant program. Direct service costs are those primarily associated with providing direct service to program participants and otherwise carrying out the approved project plan. These costs will encompass the bulk of grantee’s award expenditures. Direct administrative costs include administrative functions readily allocable to and required for administering the grant program such as oversight, grant expenditure data collection, leadership, management, and supervision. Direct administrative costs may not exceed 10% of the overall grant amount. See also: indirect costs.

Equipment: Any asset that has a useful life beyond the grant period.

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Grant cycle: The full life cycle of a grant that spans from when an applicant is awarded, to when the performance period, as identified in the grant agreement, is completed.

Grant partner: A separate organization that the primary grant recipient has entered into an agreement with for the purpose of implementing certain grant program activities and objectives. There are clear roles and expectations for the grant partner and a clear understanding of their contribution in implementing grant program activities and objectives.

Honorarium: A payment given for professional services that are rendered nominally without charge.

Incentive: Financial compensation, public recognition, or other benefits used to reward higher levels of performance and/or ideas or contributions.

Incurred/incurred costs: Costs borne by the grantee for grant activities. Costs are incurred when the transaction takes place, even if the expenses have not yet been paid. For example, if an entity issues a purchase order or pays via credit card for an expense, the expense has been incurred, even though they haven’t yet paid the order invoice or credit card statement. SSP grant expenses are eligible for reimbursement once the expense has been incurred, provided the expense is for grant activities that occur within the period of performance. If an expense is paid in advance for an event/activity that doesn’t end up taking place, the grantee must notify their coordinator.

Indirect costs: Costs not readily identifiable with the activities of the grant but incurred for the joint benefit of those activities and other activities of the organization. Examples include, but are not limited to: depreciation on buildings and equipment; the costs of operating and maintaining facilities; and general administration and general expenses, such as the salaries and expenses of executive officers, personnel administration, and accounting.

Necessary: Costs and expenses required for the successful implementation of grant activities.

Partnership: A relationship among the lead Applicant and one or more other organizations who are directly and continuously involved in the development and implementation of the proposed

Project plan. All partners are actively engaged in or play a significant role in the partnership’s decision-making and engagement with communities.

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Reasonable: Clearly aligned with the Student Success Plan and the approved project plan (see

Determining “Reasonable and Necessary” Expenses for more).

Stipend: A fixed sum of money paid to individuals in exchange for performing otherwise unpaid work or while they receive training.

Work-Based Learning: Structured learning in the workplace or simulated environment that provides opportunities for sustained interactions with industry or community professionals that foster in-depth, firsthand experience of the expectations and application of knowledge and skills required in a given career field (definition from Perkins V Work-Based Learning Handbook).

Must be focused on one of the six career clusters outlined in Oregon’s CTE Programs of Study, including: Agriculture, Food, and Natural Resources Systems; Arts, Information, and

Communications; Business and Management; Health Sciences; Human Resources; and Industrial and Engineering Systems. For details on specific skill sets by career, see CTE Oregon Skill Sets.

Wraparound Services: Services (including but not limited to mental health, addiction, child welfare, intellectual/developmental disabilities, juvenile justice, and education) coordinated in a youth- and family-driven, strengths-based process to achieve a positive set of outcomes.

ODE Student Success Plan Grant Expenditure Guidance_v11-05-2025 17 https://www.oregon.gov/ode/learning-options/CTE/careerareas/Documents/FINAL_WBLHandbook_MASTER%207-30-21_Accessible.pdf https://www.oregon.gov/ode/learning-options/CTE/resources/Pages/CTE-Oregon-Skill-Sets.aspx