Egrants Targeting Step 4 Supplement, Not Supplant Response

A new question has been added to Targeting Step 4 under the ESEA/ESSA Consolidated Application for Federal Funds in the E-grants System. This response is required for all districts that accept Title I funds beginning in the 2018-19 school year.

Under the ESSA, the supplement, not supplant rules have changed, adding increased flexibility to use Title I dollars. However, these funds must still be used for the intended purposes of Title I for legal expenditures. Listed below is a sample response for the new supplement, not supplant question. Note that your district’s response should closely follow this format. If you have questions, contact the Title I Unit at 406-444-5660 or

State the methodology the district uses to ensure that each school receives all the state and local funds that it would otherwise receive if no federal funds were available:

The district’s current internal controls over Supplement vs. Supplant were in compliance with NCLB regulations. As ESSA regulations are less restrictive in regard to Supplement vs. Supplant, the district attests that its current internal controls and methodology is in compliance with the stated regulations. Upon receipt of additional Department of Education guidance related to supplement vs supplant, the district will make adjustments to internal controls as deemed necessary to ensure compliance.