Federal Grants Management Test To Accountability…and Beyond!! Brustein & Manasevit 2016 Fall Forum November 30 – December 2, 2016 Federal Grants Management Test Bonnie Graham, Esq. and Mike Bender, Esq. bgraham@bruman.com mbender@bruman.com www.bruman.com

WELCOME CLASS Please put all of your books away. You have 10 minutes to complete your 29 question pop quiz!

Question 1 2 C.F.R. § 200.69 Pg. 94 2 C.F.R. Part 200 applies to states and districts, but not to non-profits. True False

Question 2 2 C.F.R. § 200.313(d)(3) Pg. 116 During your inventory of grant-purchased equipment, you discover a piece of equipment is missing. You are in compliance as long as you update the inventory records to indicate that the equipment went missing. True False

Question 3 2 C.F.R. § 200.313(e)(1) Pg. 116-117 When determining whether or not a State or LEA has an obligation to pay back the Federal share of a piece of equipment after disposition, the State or LEA must determine whether or not the item is valued at more or less than $5000. Value is determined at: The time of purchase The time of disposition At any point in time as long as it is within the grant period

Question 4 2 C.F.R. § 200.318, Pg. 118 2 C.F.R. § 200.302(6), Pg. 108 2 C.F.R. § 200.302(7), Pg. 108 Pursuant to EDGAR, the following list includes some of the policies and procedures that must be in writing: Employee benefits, inventory, and financial management Procurement, cash management, allowable costs No policies and procedures must be in writing Procurement, inventory, and time and effort

Question 5 2 C.F.R. § 200.305(b)(9) Pg. 110-111 Grantees and subgrantees must remit to HHS any interest earned on cash advances over: $1,000 $500 No earned interest must be remitted. All interest may be kept by the grantee or subgrantee All earned interest must be remitted to USDE

Question 6 34 C.F.R. § 76.730 Pg. 59 Under the micro purchase method, grantees and subgrantees do not have to maintain records for any purchase below $3500. True False

Question 7 2 C.F.R. § 200.302(b)(4) Pg. 108 Under EDGAR requirements, computing devices that cost less than $5000 may be considered supplies, as such grantees and subgrantees no longer need to have controls in place to safeguard such property. True False

Question 8 2 C.F.R. § 200.406 Pg. 132 Office Wow!, where you normally purchase your supplies from, is having a sale. The store is offering rebates on items that you need for your USDE program. You decided to purchase a scanner that costs $150 with a $50 rebate. The Federal grant can be charged: $150 $100 $50 Under EDGAR, printers are not an allowable cost

Question 9 Can you use Federal grant funds to pay a student’s 2 C.F.R. § 200.456 Pg. 156 Can you use Federal grant funds to pay a student’s registration fee to attend an employment seminar? No Yes, as long as the seminar is related to the grant program Yes, as long as you received prior approval from the Federal awarding agency and the cost is allocable to the grant Yes, as long as you obtain a receipt

Question 10 2 C.F.R. § 200.113 Pg. 102 During a happy hour discussion with your co-worker, you learn that your co-worker obtained a reimbursement of Federal grant funds for a tablet she purchased for her grandchild. It was a relatively small amount of funds compared with the total grant amount and as far as you know, this is the only time she has done something like this. You must: Tell your co-worker to return the funds Alert the local newspaper Tattle on your co-worker to the state or USDE Take your co-worker’s admission to the grave

Question 11 2 C.F.R. § 200.318(h) (Pg. 119) 2 C.F.R. § 200.326 (Pg. 122) 2 C.F.R. § 200.213 (Pg. 107) A friendly and competent vendor, who your office has worked with in the past, has recently been suspended or debarred. However, his quote is the lowest price out of the bids you collected for the goods you are looking to purchase. Can you contract with the vendor? Yes No

Question 12 34 C.F.R. § 76.707 Pg. 57 You are attending a conference in San Diego, California. The conference is in May and you purchase your airplane ticket in January. The airplane ticket obligates to the Federal grant award: On the date you decided to make travel arrangements. On the date the travel arrangements are booked and seat assignments are confirmed. On the date the travel arrangements are paid in full. On the date you take the flight to San Diego.

Question 13 Costs are allocable to the grant if: 2 C.F.R. § 200.405 Pg. 132 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 80% 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

Question 14 2 C.F.R. § 200.343(b) Pg. 129 All obligations must be liquidated within 90 days after the end of the grant award funding period. True False

Question 15 2 C.F.R. § 200.432 Pg. 145-146 You are in charge of hosting your annual conference. In preparation you make a list of all your conference costs. Currently your list includes: speakers’ fees, local transportation, supplies, and providing locally available dependent-care. What costs are not allowable? Speakers’ fees Local transportation Supplies Providing locally available dependent-care

Question 16 2 C.F.R. § 200.413(c) Pg. 134 Generally, the salaries of administrative and clerical staff must be treated as indirect costs. True False

Question 17 2 C.F.R. § 200.430(i) Pg. 141 An administrator spends 10% of her time working on Perkins administration activities and the rest of her time working on non-Federal activities. Because most of her time is spent on non-Federal activities, she does not need to keep time and effort reports. True False

Question 18 A subgrant is different from a contract because: 2 C.F.R. § 200.330 Pg. 124 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

Question 19 2 C.F.R. § 200.313(c)(4) Pg. 116 The Science Department uses telescopes that were purchased in 2005. The director of the department wants to upgrade the equipment because his students were unable to see the 2016 blood moon. He asks for new telescopes, stating “the next time an astronomical phenomenon occurs I want to be ready.” Can you trade in the old telescopes to offset the cost of the replacement telescopes? Yes No

Question 20 34 C.F.R. § 76.707 Pg. 57 You signed a contract on August 21, 2015 for a speaker to present at a professional development event hosted by your organization on September 21, 2015. The payment for the speaker is issued on October 1, 2015. The expense for the speaker obligated on: September 21, 2015 August 21, 2015 When the encumbrance is entered into your financial management system. October 1, 2015

Question 21 2 C.F.R. §200.430(h)(8)(viii) Pg. 142 Budget estimates alone are appropriate support for salary charges to a Federal award. True False

Question 22 A compliant conflict of interest policy must address: 2 C.F.R. § 200.318(c)(1) Pg. 118 A compliant conflict of interest policy must address: Academic dishonesty Gratuity violations Diversity in employment practices All of the above

Question 23 2 C.F.R. § 200.320(f) Pg. 121 Grantees and subgrantees may sole source procurement from a vendor as long as that vendor was included in an approved application. True False

Question 24 2 C.F.R. § 200.335 Pg. 126 Recipients are not permitted to retain and store electronic records. True False

Question 25 2 C.F.R. § 200.335 Pg. 126 When original records are in paper, electronic versions may be substituted provided that the electronic records: Are subject to periodic quality control reviews Provide reasonable safeguard against alteration Remain readable a, b, and c None of the above because electronic storage of records is not permitted

Question 26 2 C.F.R. § 200.313(c)(2) Pg.116 An LEA purchases a computer lab with Title I funds that meet the threshold for equipment under the State rules. Occasionally, students in the 21st CCLC after school program use the computer lab as well. This is permissible as long as: The shared use is minimal and it does not interfere with the Title I students’ ability to use the lab. The activities of the 21st CCLC students are allowable under Title I Such use is not permissible Other programs are permitted to use the computers as well

Question 27 2 C.F.R. § 200.313(d)(2) Pg. 116 Pursuant to EDGAR an inventory of equipment purchased in whole or in part with Federal funds must be conducted: Once every two years Yearly Once every six months Whenever you feel like it

Question 28 2 C.F.R. § 200.319(a) and (b) Pg. 119 The following circumstances restrict competition in procurement transactions: In state or local preferences Requiring unnecessary experience Specifying a brand name b and c a, b, and c

Question 29 2 C.F.R. § 200.313(c)(1) Pg. 116 An LEA no longer needs a piece of equipment purchased for an IDEA program, other programs supported with funds from USDE do not need the equipment either. May the equipment be used in a program supported with funds from the Department of Labor? Yes No

Questions?

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