Memorandum
TO: SCTG Project Directors and Leadership Teams
FROM: SCTG Program Officers
RE: Use of SCTG Funds for Incentives and Communications Products
DATE: December 2014
The purpose of this memo is to provide federal staff, contracted staff from the PBIS Technical Assistance Center, and grantees with clarification on the inclusion of incentives in SCTG budgets. Questions about a specific grantee’s budget should be addressed to the assigned federal program officer (FPO) for that grant.
Incentivizing students is a normal part of implementing a multi-tiered behavioral framework. We encourage school districts to use no-cost incentives like school privileges and/or to build incentives into the regular school budget rather than using grant funds. Some examples of no-cost incentives include homework passes, sit-where-you-want passes, cut-in-line passes, or earning points for positive behavior that can be traded in for items like stickers and school supplies. Grantees are encouraged to work with local businesses and their PTA to get donations to include items like snacks and gift cards which should not be purchased with federal funds.
OMB Circular A-87
SCT grantees are local educational agencies and are considered local governments. As such, the applicable OMB Circular regarding allowable expenditures and costs is A-87. OMB Circular A-87 “establishes principles and standards to provide a uniform approach for determining costs to promote effective program delivery, efficiency, and better relationships between governmental units and the Federal government.”
Incentives
Incentives are not specifically addressed in OMB Circular A-87; however, costs associated with Federal grants must “be necessary and reasonable for proper and efficient performance and administration of Federal awards; be allocable to Federal awards…[and] be authorized or not prohibited under State or local laws or regulations” (A-87, Section C). Grant funds may not be used for entertainment. A-87, Attachment B, Section 18 states: “Costs of entertainment, including amusement, diversion, and social activities and any costs directly associated with such costs (such as tickets to shows or sports events, meals, lodging, rentals, transportation, and gratuities) are unallowable.”
Federal staff does not encourage the use of incentives for participation in grant activities unless the use of incentives is a component of an evidence-based program. When barriers to participation in grant activities are identified, appropriate measures to eliminate those barriers should be taken (with approval from your FPO).
In requesting to use grant funds for incentives, grantees should describe the barrier that exists and how the incentive will assist in removing that barrier. When necessary, grant-funded incentives for students should promote healthy child development and/or be educational in nature. Use of grant funds for cash awards is unallowable. As mentioned, grantees may also pursue donations or contributions from non-grant resources, such as community or business partners. When donated from a non-grant source, incentives are not required to be educational or health-promoting in nature.
Communications Materials and Products
In accordance with OMB Circular A-87, Attachment B, Section 2, grant funds may be used to communicate with the public about specific activities or accomplishments pertaining to the grant.
Some SCT grantees use communications campaigns to increase community awareness of their program. Social marketing campaigns are aimed at behavior change and should support the goals and objectives of the grant. With communications or social marketing campaigns, products should provide information that the community does not already have, such as the contact information for the project or its messages. When developed as part of an approved social marketing campaign, education-related products, such as brochures, pencils, calendars or backpacks, may be approved.