1. FEDERAL GRANTS MANAGEMENT TEST ERIN AUERBACH EAUERBACH@BRUMAN.COM JENNIFER CASTILLO JCASTILLO@BRUMAN.COM BRUSTEIN & MANASEVIT, PLLC FALL FORUM 2015

2. GRANTS MANAGEMENT TEST WELCOME CLASS! PLEASE PUT ALL OF YOUR BOOKS AWAY. YOU HAVE 10 MINUTES TO COMPLETE YOUR 30 QUESTION POP QUIZ! 2 BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

3. QUESTION 1. 2 CFR PART 200 APPLIES TO STATES AND DISTRICTS, BUT NOT TO NON-PROFITS. a. TRUE b. FALSE 3 2 C.F.R. § 200.69 Pg. 94 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

4. QUESTION 2. 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: a. SEPTEMBER 21, 2015 b. AUGUST 21, 2015 c. WHEN THE ENCUMBRANCE IS ENTERED INTO YOUR FINANCIAL MANAGEMENT SYSTEM. d. OCTOBER 1, 2015 4 34 C.F.R. § 76.707 Pg. 57 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

5. QUESTION 3. PURSUANT TO EDGAR, THE FOLLOWING LIST INCLUDES SOME OF THE POLICIES AND PROCEDURES THAT MUST BE IN WRITING: a. EMPLOYEE BENEFITS, INVENTORY, AND FINANCIAL MANAGEMENT b. PROCUREMENT, CASH MANAGEMENT, ALLOWABLE COSTS c. NO POLICIES AND PROCEDURES MUST BE IN WRITING d. PROCUREMENT, INVENTORY, AND TIME AND EFFORT 5 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 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

6. QUESTION 4. UNDER THE MICRO PURCHASE METHOD, GRANTEES AND SUBGRANTEES DO NOT HAVE TO MAINTAIN RECORDS FOR ANY PURCHASE BELOW $3500. a. TRUE b. FALSE 6 34 C.F.R. § 76.730 Pg. 59 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

7. QUESTION 5. DURING A DISCUSSION WITH YOUR CO-WORKER, YOU LEARN THAT YOUR CO- WORKER OBTAINED A REIMBURSEMENT OF FEDERAL GRANT FUNDS FOR CEMENT SHE PURCHASED TO REPAVE HER DRIVEWAY. 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: a. TELL YOUR CO-WORKER TO RETURN THE FUNDS b. ALERT THE LOCAL NEWSPAPER c. TATTLE ON YOUR CO-WORKER TO THE STATE OR USDE d. TAKE YOUR CO-WORKER’S ADMISSION TO THE GRAVE 7 2 C.F.R. § 200.113 Pg. 102 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

8. QUESTION 6. 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. a. TRUE b. FALSE 8 2 C.F.R. § 200.302(b)(4) Pg. 108 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

9. QUESTION 7. THERE IS A SALE AT THE SUPPLY STORE! THE STORE IS OFFERING REBATES ON ITEMS THAT YOU NEED FOR YOUR USDE PROGRAM. YOU DECIDED TO PURCHASE A PRINTER THAT COSTS $150 WITH A $50 REBATE. THE FEDERAL GRANT CAN BE CHARGED: a. $150 b. $100 c. $50 d. UNDER EDGAR, PRINTERS ARE NOT AN ALLOWABLE COST 9 2 C.F.R. § 200.406 Pg. 132 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

10. QUESTION 8. CAN YOU USE FEDERAL GRANT FUNDS TO PAY A STUDENT’S REGISTRATION FEE TO ATTEND AN EMPLOYMENT SEMINAR? a. NO b. YES, AS LONG AS THE SEMINAR IS RELATED TO THE GRANT PROGRAM c. YES, AS LONG AS YOU RECEIVED PRIOR APPROVAL FROM THE FEDERAL AWARDING AGENCY AND THE COST IS ALLOCABLE TO THE GRANT d. YES, AS LONG AS YOU OBTAIN A RECEIPT 10 2 C.F.R. § 200.456 Pg. 156 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

11. QUESTION 9. YOU ARE ATTENDING A CONFERENCE IN ASPEN, COLORADO. THE CONFERENCE IS IN MAY AND YOU PURCHASE YOUR AIRPLANE TICKET IN JANUARY. THE AIRPLANE TICKET OBLIGATES TO THE FEDERAL GRANT AWARD: a. ON THE DATE YOU DECIDED TO MAKE TRAVEL ARRANGEMENTS. b. ON THE DATE THE TRAVEL ARRANGEMENTS ARE BOOKED AND SEAT ASSIGNMENTS ARE CONFIRMED. c. ON THE DATE THE TRAVEL ARRANGEMENTS ARE PAID IN FULL. d. ON THE DATE YOU TAKE THE FLIGHT TO ASPEN, COLORADO. 11 34 C.F.R. § 76.707 Pg. 57 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

12. QUESTION 10. COSTS ARE ALLOCABLE TO THE GRANT IF: a. THE COST OF THE GOODS OR SERVICES IS PROPORTIONATE TO THE BENEFITS RECEIVED BY THE GRANT b. AT LEAST 80% OF THE GOODS OR SERVICES WILL DIRECTLY BENEFIT THE GRANT c. THE GOODS OR SERVICES, IN ANY WAY, BENEFIT THE GRANT OBJECTIVES d. THE COST OF THE GOODS OR SERVICES WAS INCLUDED IN THE BUDGET PROPOSAL 12 2 C.F.R. § 200.405 Pg. 132 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

13. QUESTION 11. AN AGENCY MAY EXTEND THE EFFECTIVE DATE FOR COMPLIANCE WITH THE PROCUREMENT STANDARDS BY 2 YEARS… a. AUTOMATICALLY b. NEVER c. IF THE AGENCY FOLLOWS THE PRIOR RULES AND INDICATES IN WRITING WHICH STANDARDS IT IS COMPLYING WITH d. ONLY A 1-YEAR EXTENSION IS PERMISSIBLE 13 2 C.F.R. § 200.110 Pg. 101 Admin. Handbook 3 rd Ed 80 FR 54407 (Sept. 10, 2015) BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

14. QUESTION 12. YOU DECIDE TO HOST A 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? a. SPEAKERS’ FEES b. LOCAL TRANSPORTATION c. SUPPLIES d. PROVIDING LOCALLY AVAILABLE DEPENDENT-CARE 14 2 C.F.R. § 200.432 Pg. 145-146 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

15. QUESTION 13. ALL OBLIGATIONS MUST BE LIQUIDATED WITHIN 90 DAYS AFTER THE END OF THE GRANT AWARD FUNDING PERIOD. a. TRUE b. FALSE 15 2 C.F.R. § 200.343(b) Pg. 129 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

16. QUESTION 14. GRANTEES AND SUBGRANTEES MUST REMIT TO HHS ANY INTEREST EARNED ON CASH ADVANCES OVER: a. $1,000 b. $500 c. NO EARNED INTEREST MUST BE REMITTED. ALL INTEREST MAY BE KEPT BY THE GRANTEE OR SUBGRANTEE d. ALL EARNED INTEREST MUST BE REMITTED TO USDE 16 2 C.F.R. § 200.305(b)(9) Pg. 110-111 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

17. QUESTION 15. GENERALLY, THE SALARIES OF ADMINISTRATIVE AND CLERICAL STAFF MUST BE TREATED AS INDIRECT COSTS. a. TRUE b. FALSE 17 2 C.F.R. § 200.413(c) Pg. 134 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

18. QUESTION 16. THE FOLLOWING CIRCUMSTANCES RESTRICT COMPETITION IN PROCUREMENT TRANSACTIONS: a. IN STATE OR LOCAL PREFERENCES b. REQUIRING UNNECESSARY EXPERIENCE c. SPECIFYING A BRAND NAME d. B AND C e. A, B AND C 18 2 C.F.R. § 200.319(a) and (b) Pg. 119 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

19. QUESTION 17. 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 2015 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? a. YES b. NO 19 2 C.F.R. § 200.313(c)(4) Pg. 116 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

20. QUESTION 18. A SUBGRANT IS DIFFERENT FROM A CONTRACT BECAUSE: a. A SUBGRANT PROVIDES GOODS AND SERVICES THAT ARE ANCILLARY TO THE OPERATION OF THE FEDERAL PROGRAM b. A SUBGRANT USES THE FEDERAL FUNDS TO CARRY OUT A PROGRAM AS COMPARED TO PROVIDING GOODS AND SERVICES FOR A PROGRAM c. A SUBGRANT IS NOT SUBJECT TO COMPLIANCE REQUIREMENTS OF THE FEDERAL PROGRAM d. A SUBGRANT AND A CONTRACT ARE THE SAME 20 2 C.F.R. § 200.330 Pg. 124 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

21. QUESTION 19. BUDGET ESTIMATES ALONE ARE APPROPRIATE SUPPORT FOR SALARY CHARGES TO A FEDERAL AWARD. a. TRUE b. FALSE 21 2 C.F.R. §200.430(h)(8)(viii) Pg. 142 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

22. QUESTION 20. GRANTEES AND SUBGRANTEES MAY SOLE SOURCE PROCUREMENT FROM A VENDOR AS LONG AS THAT VENDOR WAS INCLUDED IN AN APPROVED APPLICATION. a. TRUE b. FALSE 22 2 C.F.R. § 200.320(f) Pg. 121 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

23. QUESTION 21. PURSUANT TO EDGAR AN INVENTORY OF EQUIPMENT PURCHASED IN WHOLE OR IN PART WITH FEDERAL FUNDS MUST BE CONDUCTED: a. ONCE EVERY TWO YEARS b. YEARLY c. ONCE EVERY SIX MONTHS d. WHENEVER YOU FEEL LIKE IT 23 2 C.F.R. § 200.313(d)(2) Pg. 116 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

24. QUESTION 22. AN LEA PURCHASES READING ROBOTS WITH IDEA FUNDS THAT MEET THE THRESHOLD FOR EQUIPMENT UNDER THE STATE RULES. OCCASIONALLY, TITLE I STUDENTS USE THE READING ROBOTS AS WELL. THIS IS PERMISSIBLE AS LONG AS: a. THE SHARED USE IS MINIMAL AND IT DOES NOT INTERFERE WITH THE IDEA STUDENTS’ ABILITY TO USE THE ROBOTS b. THE ACTIVITIES OF THE TITLE I STUDENTS ARE ALLOWABLE UNDER THE IDEA c. SUCH USE IS NOT PERMISSIBLE d. OTHER PROGRAMS ARE PERMITTED TO USE THE COMPUTERS AS WELL 24 2 C.F.R. § 200.313(c)(2) Pg.116 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

25. QUESTION 23. RECIPIENTS ARE NOT PERMITTED TO RETAIN AND STORE ELECTRONIC RECORDS. a. TRUE b. FALSE 25 2 C.F.R. § 200.335 Pg. 126 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

26. QUESTION 24. WHEN ORIGINAL RECORDS ARE IN PAPER, ELECTRONIC VERSIONS MAY BE SUBSTITUTED PROVIDED THAT THE ELECTRONIC RECORDS: a. ARE SUBJECT TO PERIODIC QUALITY CONTROL REVIEWS b. PROVIDE REASONABLE SAFEGUARD AGAINST ALTERATION c. REMAIN READABLE d. A, B AND C e. NONE OF THE ABOVE BECAUSE ELECTRONIC STORAGE OF RECORDS IS NOT PERMITTED 26 2 C.F.R. § 200.335 Pg. 126 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

27. QUESTION 25. 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? a. YES b. NO 27 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 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

28. QUESTION 26. AN ADMINISTRATOR SPENDS 10% OF HER TIME WORKING ON PERKINS ADMINISTRATION ACTIVITIES AND THE REST OF HER TIME WORKING ON NONFEDERAL ACTIVITIES. BECAUSE MOST OF HER TIME IS SPENT ON NONFEDERAL ACTIVITIES, SHE DOES NOT NEED TO KEEP TIME AND EFFORT REPORTS. a. TRUE b. FALSE 28 2 C.F.R. § 200.430(i) Pg. 141 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

29. QUESTION 27. 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? a. YES b. NO 29 2 C.F.R. § 200.313(c)(1) Pg. 116 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

30. QUESTION 28. 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: a. THE TIME OF PURCHASE b. THE TIME OF DISPOSITION c. AT ANY POINT IN TIME AS LONG AS IT IS WITHIN THE GRANT PERIOD 30 2 C.F.R. § 200.313(e)(1) Pg. 116-117 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

31. QUESTION 29. A COMPLIANT CONFLICT OF INTEREST POLICY MUST ADDRESS: a. ACADEMIC DISHONESTY b. GRATUITY VIOLATIONS c. DIVERSITY IN EMPLOYMENT PRACTICES d. ALL OF THE ABOVE 31 2 C.F.R. § 200.318(c)(1) Pg. 118 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

32. QUESTION 30. 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. a. TRUE b. FALSE 32 2 C.F.R. § 200.313(d)(3) Pg. 116 Admin. Handbook 3 rd Ed BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.

33. WHAT GRADE DID YOU GET?? 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 LAWYER-CLIENT 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. 33 BRUSTEIN & MANASEVIT, PLLC © 2015. ALL RIGHTS RESERVED.