1. Financial Management  Subgrantees shall use fiscal control and fund accounting procedures to insure proper distribution of and accounting for Federal funds.

2. That means you as a subgrantee must be able to:  Spend your 21 st Century Grant funds correctly and  Prove that you did Section 76.702 of EDGAR

3. EDGAR? Who is he and what does he have to do with my grant?

4. EDGAR E ducation Department General Administrative Regulations  80.20 Local Education Agencies  74.21Systems of Higher Education http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html

5. Essentially these sections describe the standards for the financial administration of federal programs:  Financial Reporting  Accounting Records  Internal Control  Budget Control  Allowable Costs  Source Documentation  Cash Management

6. Common Areas of Concern for Financial Management  Allowable Costs OMB Circular A-87 for LEAS OMB A-21 for Institutions of Higher Ed  Records/Source Documents Accounting Records must be supported by cancelled checks, paid invoices, payroll, time & attendance records

7. Allowable Costs OMB Circular A-87 & A21 Costs must meet the following criteria:  Be necessary and reasonable  Be allocable  Be authorized or not prohibited under State or local laws or federal grant regulation

8. Reasonable Costs: Do not exceed that which would be incurred by a prudent person Are ordinary and necessary for the operation of the program Represent sound business practices and arms length bargaining

9. Allocable Costs  Must provide a benefit to the program in proportion to the amount of the expenditure. Costs are allocated over the period of the grant Goods may be charged to the program in accordance with the relative benefit received

10. Records/Source Documents  Lack of documentation is a primary reasons for audit findings  Documentation must be available to support every expenditure Initial requisition Final disbursement You must follow your own rules

11. Supplement Not Supplant  Federal funds must be used to augment the regular educational program;  Cannot replace nonfederal funds that would otherwise have been used.

12. Supplanting Has Occurred  If the LEA uses Title IV-B to provide services that it was required to provide under other federal, state or local laws; or  If the LEA uses Title IV-B funds to provide services it provided with nonfederal funds in the prior year