Partnership Grants

APPENDIX C: Supplement vs. Supplant

Supplement vs. Supplant

The Constitutional Amendment (Article XI, section 15) of the Minnesota Constitution that appropriates funding to this grant program, dictates that grant money must supplement traditional sources of funding and may not be used as a substitute for other sources of funding.

 

Supplement vs. Supplant Examples

Supplement: To add funds to a current part-time position for the purposes of completing a grant-funded project.
 
Supplant: Using grant funds to replace existing staff wages.
 
When staff at the applicant organization want to get paid by grant funds to work on a grant-funded project, they need to determine whether the funds are supplemental or would supplant usual sources of funding. The Minnesota Legislature allows grant funds to supplement existing wages in cases where applicant staff is part-time.
 
Using grant dollars to pay personnel
 
General—hourly
An eligible applicant has two “full time” employees who are both paid an hourly rate. One is paid for 32 hours per week and the other is paid for 40 hours per week. The applicant could ask for up to 8 hours per week to be added to the one “full time” employee who is only paid for 32 hours per week. This is clearly supplemental to the existing position paid through traditional means. The applicant may not ask for compensation from the grant for the employee who works 40 hours per week. Doing so would clearly supplant a traditional source. Applications must plainly show the supplemental nature of any pay to any staff member. Note: Best practice is to pay existing staff the same rate for grant work as for their regular appointment.
 
General—salaried
An eligible applicant has a full time salaried employee that it wishes to compensate with grant funds in recognition of work on the grant. This clearly supplants a traditional source of funding used to pay the employee, and therefore is not an eligible grant expense.
 
General—overtime
An eligible applicant wishes to supplement the salary of a full time employee by paying for overtime with grant funds. The Heritage Partnership Program cannot pay for work beyond the full 40 hours per week.
 
College/University Faculty
For most of Minnesota’s colleges and universities, faculty are paid on a 3/5 schedule. In other words, faculty members are paid for the three semesters they teach out of the five possible semesters each year. If a college or university wishes to pay faculty from a legacy grant, the application must plainly show that the faculty member will not be teaching or being paid during that term when grant work occurs. Grants cannot pay faculty during semesters of regular work. Grants may not be used to pay replacement faculty to teach for a faculty member on leave to work on a grant project.
 
Project/Program-Based Staff
An eligible applicant has one or more staff on a project/program basis. This means that employment is contingent on securing funding. Grant dollars can only be used to pay such staff if 1) the project/program can be truly demonstrated to be supplemental to the work of the applicant, 2) the staff is qualified to work on the supplemental project/program, and 3) the applicant can demonstrate how it satisfies the open procurement statute in hiring project/program staff.
 
Additional year of programming
An eligible applicant seeks funding from legacy dollars for an additional year of a program. In general, this is not an eligible grant because the program has been funded in the past from another source, and thus may violate the constitutional prohibition on supplanting traditional sources of funding. If the applicant can demonstrate that new and clearly supplemental elements not done in the past will be added to the program, the program may be eligible. Reviewers have discretion to determine whether the program truly is supplemental or really is more likely to supplant funding. As always, proposed programs must also show how the public will access the program well into the future. Access must meet professional standards.
 
Required mitigation
An eligible applicant seeks funding to pay for an action required due to Section 106 review. This is not an eligible project because the responsible federal or state agency would be required to fund this action whether or not there were a Legacy grant program, and therefore the project would supplant traditional sources of funding.
 

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