Supplanting Guide
The supplanting rules aren't in one place. The Uniform Guidance gives you a general cost principle — but the real tests live in your program's authorizing statute. This guide explains where to look and how to document your compliance.
"We almost moved three positions to our DOJ grant without realizing it was presumed supplanting. This guide saved us from a six-figure finding."
— Grants Manager, County Government
Download Your Free Guide
Get instant access to the supplanting guide
What's Inside the Guide
Everything you need to understand and document supplanting compliance
UG vs. Program Statutes
Learn why the Uniform Guidance alone isn't enough — and where to find the real supplanting tests for your specific programs.
Three Presumptions Test
Understand the three scenarios where auditors presume supplanting has occurred — and how to rebut each one with documentation.
ESSA Methodology Test
Title I changed the rules under ESSA. Learn how the methodology test works — and why it only applies to Title I, Part A.
The #1 Supplanting Trap: Existing Positions
Moving a locally-funded position to a grant is the most common audit finding
Presumed Supplanting
Moving an existing locally-funded position to a grant triggers Presumption 2 — auditors assume you replaced local funds.
7-Item Documentation Checklist
The guide includes a printable checklist for every position change: justification, job descriptions, org charts, budget comparisons, and more.
Program-by-Program Table
Quick reference showing which test applies to Title I, WIOA, IDEA, DOJ, VOCA, and HHS grants — all in one table.
Rebuttal Documentation
Learn exactly what evidence auditors accept to rebut a supplanting presumption — and why contemporaneous records matter most.
Who This Guide Is For
Grant Managers
Program staff managing federal awards across education, justice, workforce, and health programs.
Finance Directors
CFOs and controllers making budget decisions about which positions and costs are charged to grants.
Compliance Officers
Internal auditors and compliance staff preparing for Single Audits and program-specific monitoring.