ESSA CSI LEA Capital Outlay Expenditures

Guidance and information to local educational agencies (LEAs) pertaining to capital outlay expenditures (CapEx) when using Every Student Succeeds Act (ESSA), Section 1003 school improvement funds for comprehensive support and improvement (CSI).

Federal requirements located in the Office of Management and Budget (OMB) guidance pursuant to Title 2, Code of Federal Regulations (CFR), Part 200.439(b)(2) (Cost Principles for Equipment and other capital expenditures) require a subgrantee to obtain approval from the Federal awarding agency or from its awarding agency prior to incurring the cost of a CapEx. As a result, an LEA must obtain prior written approval from the California Department of Education (CDE) before using ESSA, Section 1003 funds to support CSI activities involving a capital expenditure with a per-unit cost of $10,000 or more. CDE approval is not required for items with a per-unit cost of $9,999.99 or less, excluding taxes and other applicable fees. However, all ESSA, Section 1003 expenditures must be allowable under the subgrant and comply with applicable federal and state requirements.

Capital Outlay Expenditures

CapEx for CSI

For the purpose and intent of the ESSA CSI LEA subgrant, the LEA shall use the Title I CSI Capital Outlay Expenditures Request Form to request prior written approval from the CDE for proposed CapEx purchases with a unit cost per item of $10,000 or more. All proposed CapEx expenditures must:

Be an allowable use of federal funds that aligns with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards within the CFR and any other applicable federal requirements.
Be aligned with evidence-based interventions/strategies/activities directly related to the following CSI plan development and implementation efforts:
- Building capacity
- Collaborating with educational partners
- Conducting needs assessments and root cause analyses
- Selecting and implementing evidence-based interventions/strategies/activities
- Using data and outcomes to monitor and evaluate improvement efforts
- Reviewing/identifying and addressing, through the implementation of the CSI plan, resource inequities, which may include a review of LEA-and school-level budgeting.
Target the school’s reason for CSI eligibility.

Regardless of the amount, expenditures in the 6000 Capital Outlay object code series must be reasonable, necessary, and directly support approved ESSA, Section 1003 school improvement interventions/strategies/activities designed to increase student achievement. General capital improvements and purchases that are not clearly tied to approved school improvement activities are not allowable.

A Title I CSI CapEx Form is not required to request approval for Object Code 6700-Subscription Assets, which was developed in Standardized Accounting Structure, in accordance with the new Governmental Accounting Standards Board (GASB) Statement No. 96 (PDF), Subscription-Based Information Technology Arrangements, as capital outlays for financial reporting purpose.

Object Code 6700 is for intangible right-to-use assets, and for federal grant expenditure reporting purposes, it is not considered a capital asset. Per CFR Section 200 , subscription payments may be allowable where the LEAs are required to recognize an intangible right-to-use subscription asset. Information about GASB 96 can be found in the November 8, 2022, Standardized Accounting Code Structure Forum Meeting Minutes.

LEAs must comply with the Public Contract Code Section 20111(a) that requires school district governing boards to competitively bid and award any contracts involving an expenditure of more than $50,000, adjusted for inflation, to the lowest responsible bidder. Please visit the Correspondence web page for more information about Bid Thresholds for Contracts Awarded by School Districts.

In addition, please reference the Federal Grants Fiscal Guidance document to learn more about requirements for using federal funds.

More information about Capital Outlay guidelines, (Procedure 330) is located in the California School Accounting Manual (CSAM) (PDF).

Form and Instructions

Completing the Form

Title I CSI Capital Outlay Expenditures Request Form (PDF)
Use this form to request prior written approval for a CapEx purchase with a per unit cost of $10,000 or more before taxes and other fees.

Note: The CDE Title I CSI CapEx form is separate from the form that is used for the Title I, Part A program. Please visit the Title I Capital Expenditures web page for more information about that program and form.

The LEA will provide the following information.

Form Field	Description
Date of Request	Provide the date the form will be submitted.
LEA Name	Provide the name of the LEA.
County/District School (CDS) Code	Provide the LEA’s 14-digit CDS code.
School Name	Provide the name of the school for which these costs will be incurred.
CSI School Support Status (i.e., Low Graduation, Low Performance, or Not Exiting Additional Targeted Support and Improvement)	Provide the CSI status of the school for which these costs will be incurred.
Fiscal Year (FY) ESSA CSI LEA Subgrant	Provide the FY of the ESSA CSI LEA subgrant that will be utilized.
Name of Primary Contact	Provide the name of the contact person who will be responsible for any required follow-up.
Title	Provide the title of the primary contact person.
Email Address	Provide the email address of the primary contact person.
Phone Number	Provide the phone number of the primary contact person.
Split Funded: Yes or No	Select Yes or No from the drop-down to indicate if the proposed purchase will be split funded.
Source of Split Funding (Name or California School Accounting Manual [CSAM] Resource code)	Provide the name or CSAM resource code of split funding source, if applicable.
Per Unit Cost of Item ($10,000 or more before taxes/fees)	Provide the per unit cost of the items.
Total Cost of Item(s) (including taxes, shipping, and/or installation)	Provide the total cost of purchase, including any taxes, shipping, or other fees.
Name of Class/Program/Course or Career Technical Education (CTE) Pathway (if applicable) to be supported with the proposed CapEx item(s)	Provide the name of the course or CTE Pathway, if purchasing for CTE program.
Where will equipment be used or installed at school site listed (i.e., Room, Building, or Class Name)	Provide the location the purchase will be used or installed at the school site listed.

Required Prompts

The following prompts require the LEA to provide detailed information as to how the proposed Capital Outlay expenditure will support the implementation of the CSI plan and CSI program as a whole.

Provide a description of the item to be purchased with ESSA, Section 1003 funds for CSI.
Briefly describe how the item supports a need identified in the school-level needs assessment (ESSA, Section 1111[d][1][B][iii]).
Explain how the item will support the implementation of evidence-based interventions as required in the CSI plan (ESSA, Section 1111[d][1][B][ii]).
Explain how the item relates to the following CSI plan development and implementation activities:
- Building capacity
- Collaborating with educational partners
- Conducting needs assessments and root cause analysis
- Selecting and implementing evidence-based interventions/strategies/activities
- Using data and outcomes to monitor and evaluate improvement efforts
- Reviewing/identifying and addressing, through implementation of the CSI plan, resource inequities, which may include a review of LEA- and school-level budgeting
Briefly describe how the item is reasonable, necessary, and allocable cost to the ESSA CSI LEA program (2 CFR 200.404–200.405).
Explain how the purchase aligns with the assurance the LEA made in its CSI LEA Application for Funding that each school served will receive all of the State and local funds it would have received in the absence of ESSA, Section 1003 funds for CSI (ESSA, Section 1003[e][2]).

Submitting the Form

The LEA must email the following documents to CSICapEx@cde.ca.gov:

Fully completed Title I CSI Capital Outlay Expenditures Request Form (PDF)
Detailed quote of the item
CSI Plan
- Hyperlink or attach the School Plan for Student Achievement or the Local Control and Accountability Plan that serves as the CSI plan.
- Identify the goal and action/strategy in the CSI plan that is associated with the proposed Capital Outlay expenditure(s).

CDE Review and Approval

If the request is approved, the CDE will email the LEA and attach the approved form for confirmation. The form should be retained by the LEA for record-keeping purposes.
If the request is not approved, the CDE will email the LEA and return the form with relevant remarks/comments. Depending on the reason(s) provided, the LEA may be able to resubmit for reconsideration.

Reporting Capital Outlay Expenditures in the Grant Management and Reporting Tool (GMART)

Like other expenditures that LEAs claim, LEAs will report approved CapEx forms in the GMART.

Only CapEx forms that have a per unit cost of $10,000 or more will require the date the CSI CapEx Form was approved.

Additional information about reporting these expenditures can be found on the GMART CSI LEA Reporting Instructions web page.

FAQs

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Must a CSI CapEx form be submitted for items with a per unit cost of less than $10,000?
No. The CSI CapEx form is only required for proposed Capital Outlay expenditures that have a per unit cost of $10,000 or more before taxes and other fees..

Regardless of per unit cost, all capital outlay expenditures must:
- Be an allowable use of federal funds that aligns with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards within the CFR and any other applicable federal requirements.
- Be aligned with evidence-based interventions/strategies/activities directly related to the following CSI plan development and implementation efforts:
  - Building capacity
  - Collaborating with educational partners
  - Conducting needs assessments and root cause analyses
  - Selecting and implementing evidence-based interventions/strategies/activities
  - Using data and outcomes to monitor and evaluate improvement efforts
  - Reviewing/identifying and addressing, through the implementation of the CSI plan, resource inequities, which may include a review of LEA-and school-level budgeting.
- Target the school’s reason for CSI eligibility.
More information can be found on the ESSA CSI LEA Authorized Use of Funds web page.
Can a CSI CapEx form be retroactively submitted for expenditures that have already occurred?

No. Retroactive approval of a CSI CapEx form is not allowed as 2 CFR Part 200.439(b)(2) requires prior written approval.
What documents must be submitted to request approval of a proposed CapEx that has a per unit cost of $10,000 or more?
The following documents are required:
1. Fully completed Title I CSI Capital Outlay Expenditures Request Form (PDF)
2. Detailed quote of the item
3. CSI Plan
  - Hyperlink or attach the School Plan for Student Achievement or the Local Control and Accountability Plan that serves as the CSI plan.
  - Identify the goal and action/strategy in the CSI plan that is associated with the proposed Capital Outlay expenditure(s).
If one of the required documents is not submitted, the CDE will ask the LEA to submit all required documents so the request can be reviewed.

All required documents must be emailed to CSICapEx@cde.ca.gov.

Resources

Contact Information

For additional questions about Capital Outlay expenditures for CSI please submit a GMART Request or email CSICapEx@cde.ca.gov.

Questions: School Improvement and Support Office | SISO@cde.ca.gov | 916-319-0833

Last Reviewed: Tuesday, October 06, 2026

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