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

Ted Davis, Manager, Career & Technical Education (CTE)
Grants & MIS, Arizona Department of Education
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• 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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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.
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OMB Circular A-133; the Cross Cutting Section and Your ProgramSpecific 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
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• Federal Program Offices – http://www.ed.gov
• Perkins Act – http://www.ade.az.gov/cte/downloads/PerkinsIV081206.pdf
• OMB Circulars – http://www.whitehouse.gov/omb/circulars
• EDGAR –http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
• Title 15, Current Bills, etc. – ALIS www.azleg.state.az.us
• Auditor General – http://www.auditorgen.state.az.us/manuals_schooldistrict.htm
• OIG Website – www.ed.gov (Click on “Offices”, left-hand column, then select
“Offices of Inspector General”, “home-page”.
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• 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, 80.20 & 80.32
• Assigning Cost To The Correct Fiscal year – EDGAR
34 CFR § 76.707
• 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
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• 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.
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• 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…
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• 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.
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• Allowable Costs
• Equipment
• Time & Effort Reports
• Records Management
• Monitoring
• Miscellaneous
(See Attached)
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What And The
$%& Are They
Talking About ??
©
Questions
© Header, March 30, 2004 “Ballard Street” by Jerry Van Amerongen
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Ted Davis –
• Arizona Department of Education
• Career & Technical Education Section
• Phoenix, AZ
• 602-542-5349
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[email protected]
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