1. Michael L. Brustein, Esq. mbrustein@bruman.com
To Accountability…and Beyond!! Brustein & Manasevit Fall Forum 2016 November 30 – December 2, 2016
EDGAR OVERVIEW
Pass-through monitoring
Procurement
Financial
Management
Definitions
Property
Standards
Period of Performance
Cost Principles
Record
Retention
Michael L. Brustein, Esq. 1

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EDGAR 101
What is EDGAR?
Why were these regs codified?
How do they impact programs?
When were they issued?
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KEY PARTS
Part 75: Direct grants
Part 76: State-Administered (ESEA, IDEA, AEFLA, CTE)
Part 81: Enforcement
2 CFR Part UGG (Replaced Parts )
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DEVELOPMENT OF UGG
President’s Executive Order 2011
Notice of Intent 2012
NPRM – Feb. 2013
UGG – Dec. 2013
Agency Review – June 26, 2014
OMB Issuance – Dec. 26, 2014
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5. POST UGG ED INTERPRETATIONS
Pass through risk assessment
Deferral on performance measures
Retain Time/Effort certifications
Audit findings below $25,000
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ROADMAP OF THE UGG
Subpart A- Definitions
Subpart B- General Provisions
Subpart C- Pre-Award
Subpart D- Post Award
Subpart E- Cost Principles
Subpart F- Audit Requirements
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KEY DEFINITIONS
Computing Devices
– Compliance Supplement
– Cost Objective
– Internal Controls
Micro-Purchase
– Non Federal Entity
– Pass Through
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GENERAL PROVISIONS
– Conflicts
– Mandatory Disclosures
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POST AWARD - FINANCIAL
– Financial Management
– Reporting Program Performance
Payment
– Period of Performance
34 CFR Determining Obligations
– Program Income
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POST AWARD - PROPERTY
– Equipment
– Supplies
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11. POST AWARD-PROCUREMENT
– General Procurement Standards
– Competition
– Methods of Procurement
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12. SUBRECIPIENT MONITORING
– Subrecipient/Contractor Determination
– Reqs. for Pass-Throughs
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RECORD RETENTION
– Retention Reqs.
– Methods for Collection
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COST PRINCIPLES
– Factors affecting allowability
– Classification of Costs
– Direct Costs
– Indirect Costs
– Required Certifications
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SELECTED ITEMS OF COST
– Conferences
– Travel
– Compensation
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QUESTIONS?
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Legal Disclaimer
This presentation is intended solely to provide general information and does not constitute legal advice or a legal service.  This presentation does not create a client-lawyer relationship with Brustein & Manasevit, PLLC and, therefore, carries none of the protections under the D.C. Rules of Professional Conduct.  Attendance at this presentation, a later review of any printed or electronic materials, or any follow-up questions or communications arising out of this presentation with any attorney at Brustein & Manasevit, PLLC 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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