10.6 - Supplement Not Supplant Policy
Supplanting is prohibited under federal guidelines. Supplanting occurs when a state, local, or tribal government reduces previously allocated or appropriated funds by an agency for an activity, specifically because federal funds are available (or expected to be available) to fund the same activity. To ensure that federal funds are used to provide services that are in addition to the regular services normally provided by the University, federal funds must be used to supplement, not supplant regular non‐Federal funds.
Therefore, it is the policy of the University to only use federal funds to provide services which were required to be made available under federal, state, or local law and were also made available by funds subject to a supplement not supplant requirement. Federal funds must be used to supplement existing funds for program activities and cannot replace or supplant funds that have been appropriated for the same purpose. Supplanting may be grounds for suspension or termination of current and future federal funding, recovery of misused federal funds, and/or other remedies available by law.
To avoid potential supplanting issues, the University has the following policy:
- New federal funds should not be used to pay for existing employees unless the existing position is “back-filled” with a new hire, or agency approval is obtained.
- Federal funds cannot be used to pay for items or costs that The University is already obligated to pay with state, local, or tribal funds.
- State, local, or tribal funds previously appropriated, allocated, or budgeted for award purposes cannot be reduced or reallocated to other purposes because of receipt of federal funds.
- The University will ensure that the total level of services provided increases in proportion to the increase in level of federal contribution.
The University will maintain contemporaneous documentation demonstrating that any reductions in non-federal resources budgeted for award purposes is unrelated to the receipt or expected receipt of federal funds. Examples of supporting documentation may include (but are not limited to) budget sheets and/or directives, city council or departmental meeting minutes, agency memoranda, notices, or orders, and any other official documents addressing the reduction in non-federal resources.