Perkins V Section 135 Allowable Uses: What You Can (and Cannot) Fund With Local CTE Dollars
Section 135 defines both required and permissible uses of the nearly $1.4 billion in annual federal CTE funding that flows to local eligible recipients. Plain-language breakdown with specific examples for every major expenditure category.
Overview
"Perkins V Section 135 authorizes eligible recipients to use local funds to develop, coordinate, implement, or improve CTE programs to meet needs identified in the Comprehensive Local Needs Assessment. Allowable expenditures include CTE assessment tools and certification prep platforms, industry certification exam fees, instructional equipment, professional development, curriculum development, work-based learning coordination, and special populations support. All expenditures must supplement and not supplant non-federal funds, meet 2 CFR 200 cost principles for reasonableness and necessity, and be tied to approved CTE programs of study. No more than 5% of local funds may be used for administration."
Wayground CTE Research Brief, 2026
Section 135(a): The Foundational Authority
Every dollar you spend must meet three core tests established by the foundational authorization language.
Develop, Coordinate, Implement, or Improve
The expenditure must make your CTE program better, not simply maintain it. A new certification prep platform that expands student access to credential preparation clearly meets this test. A routine supply purchase that does not change program outcomes does not.
Meet a Need Identified in the CLNA
If the need is not in your CLNA, the expenditure is not defensible. This is the most frequently cited compliance issue during state monitoring reviews. Every purchase must trace back to a documented CLNA finding — not a general statement about CTE improvement.
Sufficient Size, Scope, and Quality
Token purchases that do not meaningfully impact the program may be questioned. A single-seat license for one teacher that serves a handful of students is harder to defend than a school- or district-wide platform that reaches all CTE concentrators in multiple programs of study.
Section 135(b): Required Uses
Section 135(b) specifies that funds must support CTE programs that accomplish four required purposes. These are not optional — your local application must demonstrate support for all four.
1. Career Exploration and Development — Section 135(b)(1)
Provide career exploration and career development activities through an organized, systematic framework that helps students make informed decisions about education and career opportunities before and during CTE enrollment.
Allowable examples:
- Career interest inventories and assessments
- Career pathway advising tools and software licenses
- Industry guest speaker coordination and employer engagement activities
2. Professional Development — Section 135(b)(2)
Provide professional development for CTE teachers, faculty, administrators, counselors, and paraprofessionals. This is a required use — not just permissible — and covers a wide range of training types.
Allowable examples:
- Conference registration for CTE teachers and administrators
- Industry externship programs for CTE educators
- Training on new assessment platforms (including Wayground)
- Curriculum development workshops
- Technology integration and distance learning training
- Training on serving special populations in CTE programs
3. High-Skill, High-Wage, In-Demand Skills — Section 135(b)(3)
Provide the skills necessary to pursue careers in high-skill, high-wage, and in-demand industry sectors or occupations. This is one of the strongest bases for purchasing certification prep tools — they directly develop the in-demand skills this section requires.
Allowable examples:
- Certification prep platforms aligned to in-demand credentials (CompTIA, OSHA, NCCER, ServSafe, W!SE)
- Industry-standard software and simulation tools
- Lab equipment for high-demand career pathways
4. Academic Integration — Section 135(b)(4)
Integrate academic skills (ELA, math, science) with technical education to meet secondary or postsecondary standards. Purchases that bridge academic and technical learning qualify here.
Allowable examples:
- Integrated CTE-academic curriculum development
- Cross-disciplinary project materials
- Assessment tools that measure both technical and academic skill proficiency
Section 135(b)(5): Permissible Uses
Section 135(b)(5) provides an extensive list of specific permissible expenditure categories. These are the uses most relevant to CTE directors purchasing technology and assessment tools.
Assessment Tools and Certification Prep
Funds may be used to develop and implement evaluations of CTE programs, including assessments of how needs are being met.
- CTE assessment platforms — formative and summative assessment aligned to CTE standards
- Certification prep tools — platforms that prepare students for industry-recognized exams
- Technical skill assessments — tools that measure student proficiency on technical competencies
- Certification exam fees — third-party exam costs, when part of an approved program of study
Instructional Technology
Funds may be used for CTE-specific instructional technology. Key requirement: technology must be used by students in approved CTE programs.
- Software subscriptions for CTE classroom use
- Assessment and practice platforms
- Simulation and virtual lab tools
- Learning management system features for CTE courses
Industry-Recognized Certifications
Funds may support students in earning industry-recognized certifications. Certifications must be part of an approved CTE program of study and available to all eligible participants.
- Certification exam vouchers
- Certification prep materials and practice tests
- Proctoring fees for certification exams
- Costs associated with maintaining testing center status
Equipment
CTE instructional equipment may be purchased with Perkins V funds. Equipment must be tagged, inventoried, and prioritize student use over teacher use.
- Equipment used by students (not primarily by teachers)
- Installation costs (when necessary and reasonable per 2 CFR 200)
- Equipment supporting an approved CTE program of study
Special Populations
Funds may provide direct assistance to special populations students to reduce barriers to CTE participation and success.
- Reducing or eliminating out-of-pocket expenses
- Providing accommodations and supports
- Transportation assistance
- Supplemental materials and tutoring
Work-Based Learning
Funds may support work-based learning experiences, connecting CTE classroom learning to real-world industry environments.
- WBL coordinator positions
- Employer engagement activities
- Student transportation to WBL sites
- Assessment tools for WBL competencies
What You Cannot Fund With Perkins V
Understanding non-allowable expenditures is as important as knowing what is allowed. These are the categories that draw the most scrutiny during monitoring.
| Non-Allowable Expense | Why It Is Not Allowable |
|---|---|
| Capital improvements (building construction, structural changes) | Perkins V explicitly excludes capital outlay expenditures |
| Equipment repair and maintenance | Maintenance sustains rather than develops, improves, or expands programs |
| Consumable supplies (unless they directly improve the program) | Consumables maintain programs rather than innovate or improve them |
| Entertainment and social activities | Not tied to CTE program improvement under 2 CFR 200 |
| International travel | Restricted by federal travel rules |
| General-purpose technology (laptops for non-CTE use) | Must be CTE-specific and used by students in approved programs of study |
| Purchases benefiting select individuals rather than programs | Perkins V funds support programs, not individual students or teachers |
| Administrative costs exceeding 5% of allocation | Statutory cap — administrative costs are strictly limited |
| Supplanting existing non-federal expenditures | Supplement-not-supplant rule — cannot shift local costs to federal funding |
The Supplement-Not-Supplant Rule
This is the most common compliance pitfall. Perkins V funds must supplement, not supplant, non-federal funds expended to carry out CTE activities.
In practice: if you funded a CTE tool with local money last year, you cannot shift that cost to Perkins V this year. The purchase must represent a new, expanded, or improved CTE capability, and you should document what existed before the purchase and what changed.
- Purchasing a CTE certification prep platform your district has never had (new capability)
- Adding AI-powered assessment generation to existing CTE courses (expanded capability)
- Upgrading from a basic quiz tool to a standards-aligned CTE assessment platform with readiness reporting (improved capability)
- Replacing a locally funded CTE textbook subscription with a Perkins V-funded equivalent
- Using Perkins V for a tool your district already budgets for with general education funds
2 CFR 200 Cost Principles
Every Perkins V expenditure must satisfy all four uniform guidance cost principles. An expenditure that fails any one of these tests is not allowable.
Reasonable
A prudent person would agree the cost is necessary and the price is comparable to market rates. For assessment tools, this means the subscription cost is in line with similar CTE platforms. Obtaining vendor quotes and documenting market comparisons strengthens your position.
Necessary
The expenditure is essential for the CTE program's operation or improvement. Assessment tools that directly address CLNA-identified skill gaps in technical attainment and credential readiness are clearly necessary — especially when teachers report having no comparable resource.
Allocable
The cost can be directly attributed to the CTE program. A platform used exclusively by CTE students and teachers is fully allocable. A tool shared across CTE and non-CTE programs must be prorated — only the CTE portion is chargeable to Perkins V.
Documented
Proper records exist to support the expenditure. This includes invoices, contracts, subscription agreements, user access logs, and evidence of use by CTE students. Documentation must be retained for the period required by your state's grant agreement.
Consistently Treated
Costs incurred for the same purpose in like circumstances must be treated consistently. If your district capitalizes equipment purchases above a certain threshold under local policy, that same threshold applies to Perkins V-funded equipment regardless of the funding source.
Not Otherwise Excluded
The expenditure is not otherwise restricted by statute, regulation, or the award terms. Always confirm that a purchase type is not explicitly excluded under Perkins V before committing funds — capital expenditures and entertainment are the most common statutory exclusions.
How Wayground Fits Section 135
CTE assessment and certification prep platforms represent one of the strongest Section 135 use cases — and Wayground addresses every justification basis.
| Section 135 Basis | How Wayground Qualifies |
|---|---|
| 135(a) — Directly improves CTE programs | Provides data-driven assessment and targeted certification prep that measurably improves technical skill attainment and credential outcomes |
| 135(b)(3) — High-skill, high-wage, in-demand skills | Prepares students for CompTIA Tech+, CompTIA A+, OSHA 10-Hour, NCCER Core, ServSafe, W!SE Financial Literacy, and Certiport E&SB — all in-demand credentials |
| 135(b)(5)(A) — Technology that improves CTE programs | AI-powered formative assessment generation aligned to state CTE standards across 8 states |
| 135(b)(5)(C) — Supports credential attainment | Directly increases certification pass rates through standards-aligned preparation and readiness scoring |
| 135(b)(5)(S) — Serves special populations | 25+ built-in accommodations (dyslexia font, read-aloud, extended time, translated directions) supporting equitable access for all CTE students |
| 135(b)(5) — Program evaluation | Readiness reporting generates the data that measures and documents program effectiveness for CLNA and Perkins V reporting |
Perkins V Resource Library
Deep-dive guides for every aspect of CTE funding compliance.
Frequently Asked Questions
Yes. CTE assessment tools that support technical skill attainment and credential attainment are allowable under Section 135(b)(5). The tool must be tied to an approved program of study, address a CLNA-identified need, and supplement existing non-federal funding. Assessment tools are program expenditures — they do not count toward the 5% administrative cap.
Yes. Third-party certification exam fees are allowable under Section 135(b)(5)(C) when the certification is part of an approved CTE program of study and is available to all eligible participants. This includes exam vouchers, proctoring fees, and materials directly associated with the certification attempt.
No more than 5% of your local Perkins V allocation may be used for administration. Assessment tools and instructional technology are program expenditures, not administrative costs — they do not count toward this cap. The cap applies to grant management, fiscal reporting, and similar administrative overhead, not to tools used by students in CTE classrooms.
Document that the purchase represents a new, expanded, or improved CTE capability that was not previously funded with non-federal dollars. Maintain records showing what existed before and what changed. Many districts attach a supplement-not-supplant certification form signed by the CTE director or fiscal officer. Specific written statements about prior-year funding status are the strongest documentation.
Yes, but you must prorate the cost. Only the portion used by CTE students in approved programs of study is chargeable to Perkins V. For a platform like Wayground, where the CTE certification prep module is CTE-specific, the CTE module cost is fully allocable without proration. Document your methodology for calculating the CTE-attributable share.
If your CLNA does not identify a need for assessment or certification prep tools, the expenditure may not be defensible during a monitoring review. The CLNA can be updated at any time — you are not limited to a biannual revision window. Gather credential pass rate data, survey CTE teachers about assessment tool gaps, and add the documented need to your CLNA before including the purchase in your application.
Fund CTE Assessment That Meets Every Section 135 Test
Wayground is Perkins V allowable, ESSA Tier III evidence-based, and maps to state CTE standards across 8 states. See how it fits your Section 135 application.