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VE-35 Equipment Disposal Determination Guide

A guide to help LEAs quickly determine whether disposal of Perkins-funded equipment requires a VE-35 form and the required steps either way.

Step 1: Determine the Equipment's Current Fair Market Value

  • Identify the item's current per-unit fair market value, not its original purchase price.
  • Document how the value was determined (e.g., appraisal, comparable sale price, depreciation schedule).

Step 2: Apply the EDGAR 200.313 (e) Threshold

Use the current per-unit fair market value from Step 1 to determine your filing requirement:

Current Per-Unit Fair Market Value VE-35 Form Required? Action
Less than $10,000
No

LEA may retain, sell, or dispose of the item with no further obligation to the awarding agency. Follow the recordkeeping and disposal rules in Steps 3 and 4.

$10,000 or more
Yes
LEA must file a VE-35 form in the Program Grant Management System (PGMS).

Reference: EDGAR 34 CFR 200.313.

Step 3: Follow Required Recordkeeping (Applies Regardless of Value)

  • Retain records of any item sold: including date of sale and amount received; for three (3) years after final disposition (34 CFR 200.333).
  • Reflect the disposition of every item in the sub-grantee's equipment inventory.
  • Reinvest the full amount of proceeds from sold items into career and technical education programs.

Step 4: Follow the Rules for Your Disposal Method

If Selling or Auctioning an Item:
  • Publicly post the item for sale at least ten (10) working days before the sale or auction date.
  • Confirm the item is not given to instructors, other institutional personnel, students, or parents at any time.
If Discarding an Item:
  • Dispose of the item properly through an approved disposal method.
  • Confirm the item is not in the possession of institutional personnel or students after disposition.
If the Item Is Electronic:
  • Discard and/or recycle the item through an appropriate electronics recycling channel.

Quick Reference Checklist

  • Fair market value confirmed and documented
  • VE-35 filing requirement determined using the $10,000 threshold
  • VE-35 form filed with awarding agency, if required, before disposal
  • Inventory updated to reflect disposition
  • Sale records retained for 3 years (if sold)
  • 10-day public posting completed (if sold/auctioned)
  • Proceeds reinvested in Career Technical Education (CTE) programs (if sold)
  • Item not given to staff, students, or parents
  • Electronics properly recycled (if applicable)
Questions:   Program and Administrative Support Office | perkins@cde.ca.gov
Last Reviewed: Thursday, September 10, 2026
Recently Posted in Career Technical Education