Bonnie Little Graham
bgraham@bruman.com
Brustein & Manasevit, PLLC
www.bruman.com
Spring Forum 2013
Brustein & Manasevit, PLLC
EDGAR and OMB
Circular
Tutorial for
SEAs and LEAs
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What is the significance of EDGAR?
Which OMB Circulars apply?
What is the relationship to program regulations?
What legal authorities do you rely on?
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Key Questions
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• 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
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Anatomy of EDGAR
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Cost Principles
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• SEAs/LEAs – A-87
• Postsecondary Institutions – A-21
• Nonprofits – A-122
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Audit Principles
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• SEAs/LEAs – A-133
• Postsecondary Institutions – A-133
• Nonprofits – A-133
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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
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Roadmap
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 Standards for Financial Management Systems
 80.20(b) (p. 2)
 Allowable Costs
 80.22 (p. 3)
 Basic Guidelines
 A-87(p. 4-6)
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Roadmap of EDGAR and
OMB Circulars
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 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)
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Roadmap of EDGAR and
OMB Circulars
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 Equipment
 80.32 (p. 12)
 Procurement
 80.36 (p. 14)
 Retention and Access Requirements for Records
 80.42 (p. 22)
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Roadmap of EDGAR and
OMB Circulars
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 Records Related to Grant Funds
 76.730 (p. 23)
 Monitoring and Reporting Program Performance
 80.40 (p. 24)
 Enforcement
 80.43 (p. 25)
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Roadmap of EDGAR and
OMB Circulars
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Roadmap of EDGAR and
OMB Circulars
 Travel (p. 28)
 Advertising (p. 28) (outreach)
 Personnel Costs (p. 33)
 Meetings (p. 36)
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 Selected Items of Cost
 Appendix B to A-87 (p. 26)
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 A-133 Single Audits
 _210 (p. 39) – Subrecipient and Vendor Determinations
 Mitigating Circumstances
 81.33 (p. 135)
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Roadmap of EDGAR and
OMB Circulars
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Questions?
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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.
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Disclaimer
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