Grants Management Test for State and Local Educational Agencies

1. Grants Management Test for State and Local Educational Agencies Tiffany Winters, Esq. twinters@bruman.com Brustein & Manasevit, PLLC Fall Forum 2012

2. Brustein & Manasevit, PLLC Grants Management Test Welcome Class! Please put all of your books away. You have 10 minutes to complete your 30 question pop quiz!

3. Brustein & Manasevit, PLLC EDGAR Plus Book Table of Contents, page iii 34 C.F.R. Part 75, page 31 34 C.F.R. Part 76, page 63 Question 1. The same rules apply for direct and state-administered grants since they both come initially from the U.S. Department of Education. • True • False

4. Brustein & Manasevit, PLLC EDGAR Plus Book Table of Contents, page iii OMB Circular A-87, page 287 Question 2. A school district is subject to: • OMB Circular A-21 • OMB Circular A-87 • OMB Circular A-122 • All of the above

5. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 80.20(b)(4), page 107 Question 3. The budgeted amounts are only estimates, what matters are the expenditures. • True • False

6. Brustein & Manasevit, PLLC EDGAR Plus Book Part 80, Table of Contents, page 101 Question 4. The 3 major grants management systems are: • Procurement, Data Reporting, and Contracting. • Inventory Management, Procurement, and Financial Management. • Data Reporting, Financial Management, and Inventory Management. • Inventory Management, Assessment/Evaluation, and Financial Management.

7. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 80.20, page 106 Question 5. LEAs must implement financial management systems that: • Routinely reconciles actual expenditures to budgeted amounts. • Is capable of producing accurate, current and reliable financial reports. • Includes detailed accounting records that show the source and application of Federal funds. • All of the above.

8. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix A, Part C(1)(c), page 291 Question 6. If a local district’s policy is more restrictive than the Federal regulation, an LEA is in compliance as long as it follows the Federal regulation. • True • False

9. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 80.20(b)(6), page 107 Question 7. What forms of source documentation should be maintained as records? • Receipts for actual travel. • Copy of contracts for services performed. • Payroll registries. • Every piece of paper you can think of.

10. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 80.32(d)(1), page 114 Question 8. Grantees and subgrantees must maintain detailed property records for all equipment purchased with Federal funds. • True • False

11. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 80.32(d)(2), page 114 Question 9. Pursuant to EDGAR, a physical inventory of all equipment must be taken: • Yearly. • Once every two years. • Once every six months. • Whenever you feel like it.

12. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-133 § __.210, page 358 Question 10. A contractor and a subgrantee have the same legal responsibilities when working on Federal programs. • True • False

13. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 80.36(b)(3), Page 116 Question 11. A conflict of interest arises when the following persons have a financial interest in a firm or company that is selected for a contract by the grantee: • Me (an employee of the grantee). • My son/daughter. • My husband/wife’s company is selected. • All of the above.

14. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Part B(8), page 290 Question 12. Contracts supported with Federal funds must be in writing. • True • False

15. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix A, Part C(3), page 292 Question 13. Costs are allocable to the grant if: • The cost of the goods or services is proportionate to the benefits received by the grant. • At least 50% of the goods or services will directly benefit the grant. • The goods or services, in any way, benefit the grant objectives. • The cost of the goods or services was included in the budget proposal.

16. Brustein & Manasevit, PLLC Question 14. EDGAR Plus Book 34 C.F.R. § 80.36(c)(4), Page 118 An LEA may use their favorite vendor as long as they can document that the vendor does a good job. • True • False

17. Brustein & Manasevit, PLLC EDGAR Plus Book Circular A-133 § __.210(b)(5), page 358 Question 15. A subgrant is different from a contract because: • A subgrant provides goods and services that are ancillary to the operation of the Federal program. • A subgrant uses the Federal funds to carry out a program as compared to providing goods and services for a program. • A subgrant is not subject to compliance requirements of the Federal program. • A subgrant and a contract are the same.

18. Brustein & Manasevit, PLLC Question 16. EDGAR Plus Book OMB Circular A-133, § __.105, page 355 The goal of an internal control is to ensure: • Operations run efficiently. • Data is accurate. • Compliance. • All of the above.

19. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 76.707, page 87 Question 17. Expenditures for services performed by a contractor are obligated to the Federal award: • On the date that the services are performed. • On the date that the grantee/subgrantee receives the invoice. • On the date that the subgrantee signs the contract. • At any point during the period of availability.

20. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix A, Part C(3)(c), page 292 Question 18. If there are funds remaining at the end of the project period, they may be used to purchase goods or services to be used in the future. • True • False

21. Brustein & Manasevit, PLLC Question 19. EDGAR Plus Book 34 C.F.R. § 80.23, page 108 A grantee/subgrantee must obligate all Federal funds: • Within the statute of limitations. • By the end of the period of availability. • As soon as possible. • None of the above.

22. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 76.707, page 87 Question 20. Expenditures on services performed by an employee are obligated to the Federal award: • On the date the employee signs their employment agreement. • On the date that the employee works. • On the date the employee signs their time and effort certification. • On the date the employee is paid for the services.

23. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 80.32(d)(3), page 114 Question 21. If equipment is missing upon inventory review, the grantee or subgrantee must: • Simply remove it off the inventory list. • Buy a new piece of equipment quickly. • Interview every staff member until one confesses to the theft. • Investigate.

24. Brustein & Manasevit, PLLC Question 22. EDGAR Plus Book 34 C.F.R. § 76.707, page 87 A flight for a conference obligates to the Federal grant award: • On the date the employee makes his/her travel arrangements. • On the date the seat assignments are confirmed. • On the date the travel arrangements are paid in full. • On the date the traveler takes the flight to their destination.

25. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix A, Part C, page 291 Question 23. For a cost to be allowable to a Federal grant award, it must meet the following criteria: • Necessary and reasonable. • Allocable to the Federal grant award. • Subtract applicable credits. • All of the above.

26. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix B(14) & (43), pages 300 & 308 Question 24. Assuming all costs are reasonable, which of the following cost incurred during an overnight business trip is not allowable: • Dinner (without any alcoholic beverages). • Hotel room. • Mileage costs. • A ticket to a movie.

27. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix B(25), page 304 Question 25. Federal funds may be used for equipment maintenance costs. • True • False

28. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix B(8)(h), page 297 Question 26. If an employee is paid less than 50% with Federal funds, the employee does not have to fill out a time and effort certification. • True • False

29. Brustein & Manasevit, PLLC EDGAR Plus Book 34 C.F.R. § 81.31(c), page 134 Question 27. Grantees and subgrantees should retain their records for: • 1 year from the date of obligation. • 3 years from the date of obligation. • 5 years from the date of obligation. • 10 years from the date of obligation.

30. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix B(8)(h)(3), page 297 Question 28. A teacher spends 100% of her time teaching in a special education classroom. Even if paid from multiple funding sources, the employee (if paid with some federal funds) would complete: • A semi-annual certification. • A monthly PAR. • Is not required to keep track of his/her time. • A weekly PAR.

31. Brustein & Manasevit, PLLC Question 29. EDGAR Plus Book OMB Circular A-87, Appendix A, Part C(2), Page 291 A cost is reasonable if: • It is on sale. • It does not cause the subgrantee to exceed its line item in the budget. • It does not exceed the cost that would be incurred by a prudent person under similar circumstances. • None of the above.

32. Brustein & Manasevit, PLLC EDGAR Plus Book OMB Circular A-87, Appendix B(8)(h)(4), page 297 Question 30. An administrator that works approximately half time on IDEA administrative activities and half on Title I, Part A administrative activities is required to keep: • A semi-annual certification. • A monthly PAR. • Is not required to keep track of his/her time. • A weekly PAR.

33. Brustein & Manasevit, PLLC The End!What Grade Did You Get?? Disclaimer This presentation is intended solely to provide general information and does not constitute legal advice. Attendance at the presentation or later review of these printed materials does not create an attorney-client relationship with Brustein & Manasevit, PLLC. You should not take any action based upon any information in this presentation without first consulting legal counsel familiar with your particular circumstances.