1 Ted Davis, Manager, Career & Technical Education (CTE) Grants & MIS, Arizona Department of Education

2 Disclaimer – Ted’s opinion won’t even buy you a bad cup of coffee… Decisions should be based on –  Programmatic guidance, regulations, local statutes, your own legal counsel, etc.  Risk – Would an audit finding result in guidance to, “Do it differently next year”, or… Questioned costs that will result in the return of $$$

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6 LEA – Eligible Recipients Program law & applicable regulations. Your school, district or college guidelines related to –  State financial reporting requirements.  State and local procurement requirements.  State and local inventory and personal property control requirements.  K-12, OMB Circular A-87.  College or university, OMB Circular A-21 ( When the college is the Tech Prep fiscal agent).  Nonprofits, OMB Circular A-122.  The consolidated audit requirements – OMB Circular A-133.

7  OMB Circular A-133; the Cross Cutting Section and Your Program- Specific Compliance Supplement  EDGAR (34 CFR 74 – 99)  Your State Financial Reporting Instructions for Schools/Colleges  Whatever Audit Compliance Questionnaire your state auditors utilize when they audit school districts or supply to contracted audit firms doing recipient A-133 audits  Your state’s education code of law  Recent state legislation related to your program

8 Federal Program Offices – Perkins Act – OMB Circulars – EDGAR – Title 15, Current Bills, etc. – ALIS Auditor General – OIG Website – (Click on “Offices”, left-hand column, then select “Offices of Inspector General”, “home-page”.

9 My agency’s approved grant/plan 2006 Perkins – Section 135, Local Uses of Funds 2006 Perkins – Section 203, Tech Prep Programs Equipment – EDGAR 34 CFR § 80.3, & Assigning Cost To The Correct Fiscal year – EDGAR 34 CFR § K-12 – OMB Circular A-87, Attachment B (Allowable Costs) Colleges – OMB Circular A-21, Attachment B (Allowable Costs) Request For Guidance – EDGAR 34 CFR § 81.33

10 State Statutes (Yours) – Educational, procurement, etc. State educational financial reporting Guidelines (Yours) Any specific guidance from your state agency responsible for Perkins State audit guidelines. Ideally, you want a copy of what your auditors will use to review your fiscal practices if you are audited. Etc.

11 Fits with your application Allowable per the appropriate Circular Reasonable Allocable Consistently Treated Consistent with your organization’s policies Incurred in accordance with GAAP Not charged elsewhere Adequately Documented…

12 Photocopy or print off your most referred to resources… Put your questions and answers in the same binder… Keep it in the same spot on your shelf… Add to your binder, update it… Transfer any important notes to documents anytime you put in a new version or toss an older one.

13 Allowable Costs Equipment Time & Effort Reports Records Management Monitoring Miscellaneous (See Attached)

14 © © Header, March 30, 2004 “Ballard Street” by Jerry Van Amerongen Questions What And The $%& Are They Talking About ??

15 Ted Davis – Arizona Department of Education Career & Technical Education Section Phoenix, AZ