Grants and Contracts
An SEA or an LEA may wish to use Title VI funds to award grants or contracts on a competitive basis to LEAs, institutions of higher education, libraries, museums, and other public and private nonprofit agencies, organizations and institutions to carry out activities authorized under Title VI. (See section 6302, 20 USC 7353) It is the Department's interpretation that if an SEA or LEA awards such grants or contracts, the SEA or LEA still maintains overall administrative responsibility for the program under which the activity is being implemented.
|Example: An SEA wishes to conduct a statewide program to improve higher order thinking skills of disadvantaged elementary and secondary school students and to prevent students from dropping out of school. As part of this program, the SEA uses Title VI funds to contract with a group of museums to develop a series of activities for the children enrolled in the program. These activities are to be conducted by museum personnel at the museum, while the SEA will continue to handle administrative responsibilities for the program.|
An SEA or LEA, under the authority in section 6302, may not use Title VI funds to contract with a "for profit" agency, organization or institution to operate programs or conduct programmatic activities. However, the Department does not believe that this precludes an SEA or LEA from contracting with an individual or a for-profit corporation or other organization to purchase specific goods or services to assist the SEA or LEA in carrying out a program.
|It is possible for an SEA or LEA to contract with a for-profit entity or individual for items such as:
SEA or LEA personnel who carry out activities under Title VI may be paid with Title VI funds to the extent that their duties are authorized under Title VI. If an employee works part-time for Title VI or splits time between Title VI administration and technical assistance, the SEA must maintain time and effort records showing the actual time spent on each program or activity. Similarly, if an LEA employee splits time among Title VI and other local, State or Federal programs, such records must be kept.