Forms for Prior Approval, Disclosure, and Justification

EDGAR requires subgrantees to take specific steps to seek approval or document intent before expending federal funds on certain activities. TEA has developed different forms to help LEAs meet these requirements. Refer to each section below for guidance on how to complete and submit the forms. TEA will provide a formal response for each request submitted. 

Most of the forms are now maintained, or will be in the future, in a secure, automated, online system called EDGAR Connect WorkApp System. This new automated system will track the submission, review, and approval of forms and should expedite the entire process.

The EDGAR Forms system is the same as recently used in the ESSER Annual Reporting data collection. While not all forms have been moved to the new system, the remainder will be programmed over the coming months. Selecting the form name below will access the EDGAR forms either in the new system or the original PDF forms until such time they are migrated into the new system.

Currently, the superintendent, chief financial officer, and federal program director listed in AskTED have been given access to the EDGAR Forms system. To add or change the individuals with access to the system, someone with existing access must request access for the new individual via the Help Form in the EDGAR Forms WorkApp. The additional staff to be added to the system must agree to certain security requirements.

NOTE: Each subgrantee organization, e.g., LEA or ESC, is only guaranteed three (3) access accounts at this time, with a potential maximum of five (5) access accounts in the system per subgrantee.

Prior Approval Requests for Participant Support Costs

Under (2 CFR) 200.456, participant support costs are allowable with prior approval from TEA. Participant support costs include direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects. Approvals are retroactive to the beginning date of the grant period as noted on the grant recipient’s Notice of Grant Award (NOGA) for programs in which the activity is required and allowable. Forms maintained locally must be provided to auditors or monitors upon request.

• Equitable services to private nonprofit schools may include registration and travel costs for PNP staff participating in allowable professional development activities. Complete this pre-approved form and maintain locally for documentation.
• Parental involvement activities may include registration and travel costs for participating in allowable parent trainings or conferences and required parent involvement/advisory committees. Complete this pre-approved form and maintain locally for documentation.
• Other participant support costs must have prior written approval from TEA before grant funds may be expended on the activities. 

Email any questions on these prior approval forms to GrantSupport@tea.texas.gov.

Prior Approval Requests for Other Expenditures

Before expending grant funds on the following activities, subgrantees must complete the applicable form and submit it to TEA for approval. The subgrantee must receive prior written approval in writing from TEA before grant funds may be expended on the activities.

• Special or Unusual Costs: You may use this form to request prior approval for types of costs that do not normally align with the subgrantee's normal procurement processes.
• Inventory Disposition: You will use this form anytime equipment or supplies are no longer needed by the federal program from which it was purchased or the equipment is no longer usable.
• Adding Program Income to Federal Grant Award and Expanding Delivery of Programmatic Services: Unless this form is submitted to TEA requesting otherwise, any program income generated by the federal program will offset your grant award and reduce your NOGA. Note that generating program income is different than making a profit from a federal grant. Making a profit is unallowable.
• Noncompetitive Procurement (Sole Source): You may use this form when requesting prior approval from TEA for a sole source procurement. Note that TEA prior approval is not required for the subgrantee to conduct a sole source procurement. The subgrantee may choose to justify a sole source procurement for its auditor without TEA prior approval.
• Other Noncompetitive Procurement (Not Sole Source): You may use this form when requesting prior approval from TEA for a noncompetitive procurement that is not a sole source procurement. Since the procurement is not sole source, you must be able to justify and document why TEA should approve the noncompetitive procurement.

Email any questions on these prior approval forms to GrantSupport@tea.texas.gov.

Self-Certification of Micro-Purchase Threshold

2 CFR §200.320 officially sets the micro-purchase threshold at $10,000 in the aggregate across all federal grant programs for the fiscal or grant year. It also allows the LEA to annually self-certify a higher micro-purchase threshold of up to $50,000.00 (Note: Due to state Financial Accountability System Resource Guide (FASRG) rules, the LEA may only self-certify a threshold up to $49,999.99) if the LEA:

•    is a low-risk auditee for their most recent federal audit; or

•    conducts an annual internal risk assessment to identify, mitigate, and manage financial risk.

The LEA must determine the local threshold based on internal controls, risk, and documented procedures.

LEAs may certify by grant year (July 1-June 30) or by the LEA’s fiscal year. The self-certification must be submitted to TEA through the online system by October 1 to be retroactive back to the start of the grant/fiscal year. Self-certifications submitted to TEA after October 1 of the current grant/fiscal year will not go into effect until the date it is submitted to TEA and any procurements started prior to the submission date must adhere to the standard $10,000.00 micro-purchase threshold. LEAs can submit their requests to self-certify a higher micro-purchase threshold via the EDGAR Connect WorkApp.

Email any questions on these requests to GrantSupport@tea.texas.gov.

Disclosure

Federal grant regulations require subgrantees to disclose the following items that may impact the federal grant award or expenditure of federal funds. 

• Potential Conflict of Interest Disclosure: You must file this form anytime there is a potential conflict of interest within the staffing of your federal program or within the chain of command related to the approval of budget or activities within the federal program. Common examples are family members working within the organization where at least one person’s work is related to a federal program.
• Mandatory Disclosure: Violation of Federal Criminal Law: This form must be submitted anytime there is a potential violation of any federal criminal law for any employee who works in any relation to a federal program. Complete the form and submit to GrantSupport@tea.texas.gov for approval.
• Disclosure of Lobbying Activities: You must submit this form when applicable. Download the form and open it with a PDF reader or system viewer. Visit the form instructions for additional guidance. Complete the form and submit it with your grant application (for eGrants, upload the file as an attachment to your application).

Email any questions on these prior approval forms to GrantSupport@tea.texas.gov.

Justification of Expenditures

TEA requires subgrantees to justify, and document, their intent to expend grant funds on certain activities. These activities must be allowable per Program Guidelines. Before undertaking the following activities, complete the applicable justification form and maintain locally. The completed forms must be submitted to TEA upon request. Auditors will make the final determination as to whether the specified activity is properly documented to show allowability.

• Justification for Out-of-State Travel
• Justification for Educational Field Trips
• Justification for Hosting or Sponsoring of Conference (allowable in limited circumstances only)
• Consolidation of ESSA Administrative Funds

Email any questions on these justification approval forms to Grants@tea.texas.gov.