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

2. Key Questions 1.What is the significance of EDGAR? 2.Which OMB Circulars apply? 3.What is the relationship to program regulations? 4.What legal authorities do you rely on? Brustein & Manasevit, PLLC 2

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 3

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

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

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 6

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 7

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 8

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 9

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 10

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 11

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 12

13. Questions? Brustein & Manasevit, PLLC 13

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 14