Do recipients of federal funds have to maintain documentation that demonstrates the supplementary nature of the funds and activities?
Yes. In most cases, both the funding and the activities must be supplemental. The exception is Title I schoolwide projects where only the level of funding must be supplemental. If supplement and not supplant cannot be properly documented, the maximum penalty would be the return of 100% of the grant dollars to TEA, depending upon the activities and expenditures associated with the supplant.
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