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ELOP Allowable Expenditures Checklist (2026-27): The 14 Line Items Auditors Actually Approve

Aug 4, 2026 · 9 min read

ELOP Allowable Expenditures Checklist (2026-27)

The 14 line items auditors actually approve — mapped to the CDE Fiscal Responsibilities Instrument so your business services office can code every invoice audit-safe.

Every June, California business services officers close out their Expanded Learning Opportunities Program (ELOP) fiscal year and open a spreadsheet. Roughly a third of them ask the same question: “Wait — is this actually allowable?” Categorical ambiguity is where audit findings hide, and there is no single CDE-issued “here is the master list” document. Instead, the audit-side authority lives in the CDE Fiscal Monitoring Unit’s Fiscal Responsibilities of Expanded Learning Opportunities Program Instrument — updated annually, five procedure blocks (ELOP 01 through ELOP 05), and cited to specific subsections of Education Code §46120. This post pulls all of it together into the working checklist your CFO wants on their desk. Every claim below is cited to primary source.

01 / How the CDE audit is actually structured

The CDE Fiscal Monitoring Unit runs the ELOP fiscal audit; the Expanded Learning Division separately runs the programmatic audit. When your K-12 audit team asks for ELOP documentation, they are working from the annual Fiscal Responsibilities of ELOP Program Instrument (the 2025-26 version was released May 2025 and covers fiscal years currently under audit). It contains five test procedures, each with its own evidence request list.

  • ELOP 01 — Time and Effort Requirements. Payroll, position control, and duty statements must reflect actual work performed. Budget estimates do not qualify as time-and-effort support. Authority: California School Accounting Manual (CSAM) Procedure 905; Ed Code §§14500-14509 and §§41010-41024; California Government Code §§13401-13407.
  • ELOP 02 — Policies, Procedures, Internal Controls. Written policies for allowability, procurement, travel, equipment, and conflict-of-interest must exist and be LEA-specific.
  • ELOP 03 — Allowable Costs. Every expenditure must be reasonable, necessary, and allowable under Ed Code §46120(b)(8), §46120(d)(3), and §46120(d)(8)(A)-(B), and consistent with the LEA’s board-approved ELOP program plan.
  • ELOP 04 — Procurement. Contracts must follow California Public Contract Code §§20110-20118 procedures. Cost or price analysis required for any procurement over the simplified acquisition threshold. Arm’s-length bargaining required per Government Code §1090.
  • ELOP 05 — Equipment / Inventory Management. Any equipment item with an acquisition cost of $500 or more per unit must be tracked with description, ID number, acquisition date and cost, funding source, location, and ultimate disposition. Authority: Ed Code §35168, CSAM Procedure 410, 5 CCR §3946.

Everything in this post maps back to one of those five tests. Get the paperwork right for all five and audit season is boring. Get any one wrong and the finding lands on the CBO’s desk.

02 / The 14 line items auditors actually approve

Below is the working checklist. Each item is a category of expenditure the CDE fiscal instrument confirms is allowable when properly documented and mapped to the LEA’s board-approved ELOP program plan.

Staffing (the 80% of most ELOP budgets)

  1. Certificated program staff — credentialed teachers providing academic support, enrichment leads, and site directors employed by the LEA.
  2. Classified program staff — instructional aides, program coordinators, activity leaders, and support staff paid via LEA payroll.
  3. Contracted third-party program providers — qualified vendors delivering STEM, arts, physical activity, social-emotional learning, or other enrichment programming under a written subcontractor agreement, procured through the LEA’s documented procurement process.

Program delivery costs

  1. Instructional materials and supplies — art supplies, science materials, books, curriculum resources, and consumables used exclusively during the ELOP block.
  2. Technology and program equipment — tablets, computers, cameras, and instructional tech dedicated to ELOP use. Any single item at $500 or more must be logged on the LEA equipment inventory (per ELOP 05).
  3. Nutritious snacks and meals — food service consistent with the National School Lunch and Breakfast Program guidelines. Recess and meals also count toward the 9-hour combined ELOP day (per §46120(b)(4)(A)).
  4. Transportation — costs for transporting students to and from ELOP sites, including bus service, contracted transportation, or reimbursement per LEA policy.
  5. Facility use — rent, utilities, and maintenance for facilities used to deliver ELOP programming.

Enrichment programming and family engagement

  1. Field trips — educational, aligned to the ELOP program plan, and documented in the plan’s activities list.
  2. Guest speakers and specialty instructors — brought in for specific enrichment tracks, invoiced against ELOP funds.
  3. Family engagement events — parent nights, showcase events, and community-facing ELOP programming.

Compliance and infrastructure

  1. Staff training and professional development — training for ELOP staff on program requirements, safety, mandated reporting, first aid, or CPR.
  2. Administrative overhead — indirect costs supporting ELOP administration. Commonly guided by CDE published administrative rates and generally kept under 15% of the total allocation. LEAs should verify their approved indirect cost rate against the current CDE-published rate for their agency type before coding.
  3. Insurance and compliance costs — liability insurance, background checks (Live Scan, TB, mandated reporter certifications), and other compliance-driven costs tied directly to ELOP operations.

03 / What is not allowable

Some expenditures look ELOP-adjacent but fail the reasonableness or allowability test under ELOP 03. Route these elsewhere.

  • Regular instructional day activities. ELOP funds are for expanded learning — before school, after school, or non-school days. Classroom instruction during the regular bell schedule is not ELOP-eligible. Push to LCFF, Title I, or general fund.
  • Adult education. ELOP serves TK-6 pupils. Adult programs are outside the statutory purpose.
  • Costs that supplant existing general-fund arts, enrichment, or afterschool spending. ELOP must supplement — not replace — services already provided. This mirrors the supplement-not-supplant discipline in Prop 28 and is separately enforced under ELOP 03 allowability.
  • Capital construction and major facility renovation. Minor upgrades directly tied to ELOP operations may be allowable; large capital projects are not.
  • Equipment items over the $500 threshold not logged on the LEA inventory. Failure to inventory is itself a finding under ELOP 05.
  • Contracts issued without cost-or-price analysis over the simplified acquisition threshold. Straight ELOP 04 finding.
  • Payroll charged to ELOP without duty statements or time-and-effort records. Budget estimates do not qualify. Straight ELOP 01 finding.

04 / The paperwork the auditor will actually request

When your annual K-12 audit team runs ELOP procedures, they will ask for a specific document set. Have these organized and current before the audit begins.

  • Chart of Accounts — with account numbers and descriptions covering ELOP fund, resource, object, and site codes.
  • General Ledger for ELOP resource code(s) — with date, description, vendor name, and total amount per line item.
  • Payroll Records — district-wide, showing employees paid in whole or in part from ELOP funds, with hours, gross pay, net pay, deductions, and payroll period.
  • Position Control Report — showing employees planned to be paid with ELOP funds by resource code.
  • Duty Statements — for a sample of employees the auditor selects.
  • Time-and-Effort Records — personnel activity reports, semiannual certifications, or equivalent for two quarters the auditor selects.
  • ELOP Program Plan — current, board-approved, posted to the LEA website, updated at least once every 3 years. Content must include program goals, program content, outcome measures, and elements pertaining to Ed Code §8482.3(g)(1). CDE publishes an ELOP Program Plan Template.
  • Written LEA Policies — for allowability, procurement, travel, equipment, and conflict of interest. All must be specific to your LEA, not generic templates.
  • Subcontractor Agreements — for a sample of contracted vendors the auditor selects.
  • Vendor Invoices — itemized, showing exactly what was purchased and how the expenditure benefited the program.
  • Cost or Price Analysis — for every procurement over the simplified acquisition threshold, documented before receiving bids.
  • Requests for Proposals — with clear technical requirements and evaluation factors identified.
  • Equipment Inventory Records — historical inventory of every item at $500+ acquisition cost.

05 / The three most common ELOP allowability findings

  1. Time-and-effort records missing or generated from budget estimates. ELOP 01 explicitly states budget estimates do not qualify as time-and-effort support. Districts commonly rely on planned allocations rather than actual PARs or semiannual certifications. Fix: adopt a written time-and-effort policy and run PARs or semiannual certs for every ELOP-funded employee.
  2. Subcontractor agreements without procurement documentation. ELOP 04 requires cost-or-price analysis and arm’s-length bargaining for procurements over the simplified acquisition threshold. Districts commonly extend a vendor contract informally without re-running competitive procurement. Fix: keep the RFP file, the price analysis, and the evaluation matrix for every vendor over threshold.
  3. Equipment not inventoried. ELOP 05 requires inventory of every $500+ item. Districts commonly buy tablets, projectors, or cameras and never enter them on the equipment log. Fix: run inventory quarterly and log ELOP-purchased equipment against the resource code.

06 / What to look for in a vendor that will not create ELOP 04 findings

Contracted third-party providers are a major line item for most ELOP budgets. The vendors that survive audit share four traits.

1. They provide an MOU template consistent with California Public Contract Code procurement requirements. A vendor with prior CA district experience will hand you the template. A vendor without will look confused.

2. They invoice at the itemized level. Line-item invoicing showing discipline, site, and dates — not lump-sum billing.

3. They will provide staff credentials on request. Background checks, TB, Live Scan, mandated reporter certification available for every instructor.

4. They can produce an allowability memo mapping their programming to Ed Code §46120 allowable categories. Because your auditor will ask.

07 / This post is for you if

You are a business services officer or CBO responsible for coding ELOP expenditures and worried about the year-end audit.

You are an ELOP coordinator or expanded learning director putting together the annual program plan and want the paperwork list in one place.

You are a superintendent preparing to sign off on ELOP invoices and want confidence the coding is defensible.

You are a district compliance officer preparing for a Fiscal Monitoring Unit visit and want the audit-instrument document set organized in advance.

You are a board member being asked to approve the ELOP plan or budget and want to know what the auditor actually tests.

08 / What we’d love to do next

If you are a 2026-27 ELOP coordinator or business services officer and want a second read on your specific expenditure coding and paperwork readiness, here is the specific ask.

Give us 20 minutes. On a call. That is it.

In that 20 minutes we will walk your ELOP resource code activity year-to-date, flag any coding that looks exposed under ELOP 01 through 05, and share honestly how we would structure the paperwork if we were running the program. You leave the call with a one-page ELOP audit-readiness note in your inbox, yours to keep, use, or share with your board — regardless of whether we ever work together.

Book the 20-Minute ELOP Audit-Readiness Call →

Sources and further reading

This piece was published by The Kodely Blog. Kodely is a MWBE-certified K-8 enrichment provider serving 40+ California districts across ELO-P, Prop 28, CCSPP, and LRBG funding lanes. We deliver STEM, arts, and coding programming with itemized invoicing coded to your ELOP resource lines, credentialed staff, and an allowability memo included in every scope of work. If you are preparing for 2026-27 ELOP audit season and want a second read on your paperwork readiness, we are happy to have a conversation. This post is field-guide reference material, not legal or accounting advice.

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