Q. Several school districts have purchased Kindles and loaded them with e-books for migratory children to check out. Because only six Kindles can be linked to a single user account, districts would like to purchase additional Kindles for migratory children to keep indefinitely, at a cost of approximately $129 per device. May Migrant Education Program (MEP) funds be used to purchase Kindles (a specific brand of electronic book/e-book reader) for migratory children to keep indefinitely?
The Office of Migrant Education (OME) stands by its previously issued policy that MEP funds may not be used to purchase electronic devices for migratory children to keep indefinitely. In accordance with the cost principles that guide Title I, Part C grants to State educational agencies (SEAs), in order to be considered allowable, costs must be allocable or chargeable to the MEP, relative to the benefit received (see 2 Code of Federal Regulations (CFR) §200.405)). In addition, 2 CFR § 200.302 (b)(4) requires grantees and subgrantees to have financial management systems that maintain effective control and accountability for all funds, property, and other assets. This same provision requires grantees and subgrantees to adequately safeguard all such property and must assure that it is used solely for authorized purposes. Although the previously issued response did not specifically list Kindles as an example of electronic devices, the rationale is the same. We do not believe the purchase of Kindles for migratory children to keep indefinitely is an allowable use of MEP funds because the MEP would not be able to assure that the devices are used solely for authorized purposes, nor would the MEP be able to maintain effective control over the devices once the students’ MEP eligibility ends.
If the goal is to expand access to electronic books for migratory children, we offer the following suggestions to add to the number of e-readers that may be loaned to migratory children in need of such devices:
- Inquire as to Amazon’s (company that owns Kindle) policy for allowing additional accounts and/or devices per user— particularly in school-based/educational settings.
- Encourage districts to identify additional staff willing to create accounts.
- Explore other brands of e-readers that are comparable in cost and allow more devices per account.