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EDGAR and OMB Circular Tutorial for SEAs and LEAs

EDGAR and OMB Circular Tutorial for SEAs and LEAs. Bonnie Little Graham bgraham@bruman.com Brustein & Manasevit, PLLC www.bruman.com Spring Forum 2013. Key Questions. What is the significance of EDGAR? Which OMB Circulars apply? What is the relationship to program regulations?

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EDGAR and OMB Circular Tutorial for SEAs and LEAs

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  1. EDGAR and OMB Circular Tutorial forSEAs and LEAs Brustein & Manasevit, PLLC Bonnie Little Graham bgraham@bruman.com Brustein & Manasevit, PLLC www.bruman.com Spring Forum 2013

  2. Key Questions • What is the significance of EDGAR? • Which OMB Circulars apply? • What is the relationship to program regulations? • What legal authorities do you rely on? Brustein & Manasevit, PLLC

  3. Anatomy of EDGAR • Administrative Rules • SEAs/LEAs – Part 80 • Postsecondary – Part 74 • Nonprofits – Part 74 • State-Administered Programs – Part 76 • Direct Grants – Part 75 • Enforcement – Part 81 • Lobbying – Part 82 • Debarment/Suspension – Part 85 • FERPA – Part 99 Brustein & Manasevit, PLLC

  4. Cost Principles • SEAs/LEAs – A-87 • Postsecondary Institutions – A-21 • Nonprofits – A-122 Brustein & Manasevit, PLLC

  5. Audit Principles • SEAs/LEAs – A-133 • Postsecondary Institutions – A-133 • Nonprofits – A-133 Brustein & Manasevit, PLLC

  6. Roadmap • Standards for Financial Management • How to Determine if a Cost is Allowable • Cash Management Controls and Obligations • Asset Controls • Procurement Controls • Selected Cost Items • Audits and Enforcement Brustein & Manasevit, PLLC

  7. Roadmap of EDGAR and OMB Circulars • Standards for Financial Management Systems • 80.20(b) (p. 2) • Allowable Costs • 80.22 (p. 3) • Basic Guidelines • A-87(p. 4-6) Brustein & Manasevit, PLLC

  8. Roadmap of EDGAR and OMB Circulars • Period of Availability of Funds • 80.23 (p. 8) • When Obligations are Made • 76.707 (p. 9) • When Certain Subgrantees May Begin to Obligate Funds • 76.708 (p. 10) • Obligations Made During Carryover Period • 76.710 (p. 11) Brustein & Manasevit, PLLC

  9. Roadmap of EDGAR and OMB Circulars • Equipment • 80.32 (p. 12) • Procurement • 80.36 (p. 14) • Retention and Access Requirements for Records • 80.42 (p. 22) Brustein & Manasevit, PLLC

  10. Roadmap of EDGAR and OMB Circulars • Records Related to Grant Funds • 76.730 (p. 23) • Monitoring and Reporting Program Performance • 80.40 (p. 24) • Enforcement • 80.43 (p. 25) Brustein & Manasevit, PLLC

  11. Roadmap of EDGAR and OMB Circulars • Selected Items of Cost • Appendix B to A-87 (p. 26) • Travel (p. 28) • Advertising (p. 28) (outreach) • Personnel Costs (p. 33) • Meetings (p. 36) Brustein & Manasevit, PLLC

  12. Roadmap of EDGAR and OMB Circulars • A-133 Single Audits • _210 (p. 39) – Subrecipient and Vendor Determinations • Mitigating Circumstances • 81.33 (p. 135) Brustein & Manasevit, PLLC

  13. Questions? Brustein & Manasevit, PLLC

  14. Disclaimer This presentation is intended to solely 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. Brustein & Manasevit, PLLC

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