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Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. [email protected] [email protected] Spring Forum 2011
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Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. [email protected] [email protected].

Mar 26, 2015

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Page 1: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Allowability and Grants Management Test When Working With NonTraditional Providers

Tiffany R. Winters, Esq.Erin Auerbach, [email protected]@bruman.com

Spring Forum 2011

Page 2: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Grants Management Test for NonTraditional Providers

Welcome Class!

Please put all your books away

You have 10 minutes to complete your 30 question pop quiz!

Page 3: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 1:

A contractor and a subgrantee have the same legal responsibly when working on federal programs.

A. TrueB. False

EDGAR Plus Book OMB Circular A-133 § __.210, page 358

Page 4: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 2:

A subgrant:A.Is not subject to compliance requirements of the Federal program.B.Is very similar to a contract.C.Provides goods or services that are ancillary to the operation of the Federal program.D.Uses the Federal funds to carry out a program as compared to providing goods or services for a program.

EDGAR Plus Book OMB Circular A-133 § __.210(b)(5), page 358

Page 5: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 3:

In order to receive Federal funds, grantees and subgrantees must implement financial management systems that:

A. Include budget controls, such as routinely reconciling actual expenditures to budgeted amounts.

B. Are capable of producing accurate, current and reliable financial reports.

C. Include detailed accounting records that show the source and application of Federal funds.

D. All of the above.

EDGAR Plus Book 34 C.F.R. § 74.21 page 9

Page 6: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 4:

The same rules apply whether the grant is awarded directly from the US Department of Education or through the State education agency.

A. TrueB. False

EDGAR Plus Book Table of Contents page iii34 C.F.R. Part 75, page 3134 C.F.R. Part 76, page 63

Page 7: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 5:

Data driven decision making is an important aspect of determining if costs are necessary.

A. TrueB. False

EDGAR Plus Book OMB Circular A-21 Appendix C(2), page 238OMB Circular A-122 Appendix A(2), page 322

Page 8: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 6:

The goal of an internal control is to ensure:A. Effectiveness and efficiency of operations.B. Reliability of financial reporting.C. Compliance with applicable laws and

regulationsD. All of the above.

EDGAR Plus Book OMB Circular A-133, § __.105, page 355

Page 9: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 7:

Grantees and subgrantees must maintain detailed property records for all equipment purchased with Federal funds.

A. TrueB. False

EDGAR Plus Book 34 C.F.R. § 74.34 (f), page 17

Page 10: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 8:

Contracts supported with Federal funds must be in writing.

A. TrueB. False

EDGAR Plus Book OMB Circular A-87, Part B(8), page 290

Page 11: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 9:

Grantees and subgrantees should retain their records for: A.1 year from the date of obligation.B.3 years from the date of obligation.C.5 years from the date of obligation.D.10 years from the date of obligation.

EDGAR Plus Book 34 C.F.R. § 81.31(c), page 134

Page 12: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 10:

A grantee /subgrantee must obligate all Federal funds:A.By the end of the Tydings period.B.By the end of the period of availability.C.Within the statute of limitations. D.None of the above.

EDGAR Plus Book 34 C.F.R. § 74.28, page 15

Page 13: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 11:

Expenditures on services performed by an employee of a grantee/ subgrantee are obligated to the Federal award:

A. On the date when the subgrantee signs the contract to obtain the services.

B. On the date that the services are performed.C. On the date the employee signs the time and

effort certification. D. On the date the employee is paid for the

services.

EDGAR Plus Book 34 C.F.R. § 76.707, page 87

Page 14: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 12:

Grantees and subgrantees don’t have to reconcile actual expenditures to budgeted amounts, since the budgeted amounts are not based on the actual expenditures and are only estimates.

A. TrueB. False

EDGAR Plus Book 34 C.F.R. § 74.25, page 13

Page 15: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 13:

For a cost to be allowable to a Federal grant award, it must meet the following criteria:

A. Necessary and reasonable.B. Allocable to the Federal grant award.C. Subtract Applicable Credits.D. All of the above.

EDGAR Plus Book OMB Circular A-21 Appendix C(1-2, 5), pages 238-239OMB Circular A-122 Appendix A(2,5), pages 322-323

Page 16: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 14:

A cost is reasonable if:A.It supports the grant objectives, but costs more than the fair market value for the item being purchased.

B.The cost does not cause the grantee or subgrantee to exceed its total Federal allocation.

C.It does not exceed the cost that would be incurred by a prudent person under similar circumstances.

D.None of the above.

EDGAR Plus Book OMB Circular A-21 Appendix C(3), page 238OMB Circular A-122 Appendix A(3), page 323

Page 17: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 15:

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 50% 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.

EDGAR Plus Book OMB Circular A-21 Appendix C(4), page 238OMB Circular A-122 Appendix A(4), page 323

Page 18: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 16:

All employees of nonprofit organizations paid in whole or in part with federal funds must fill out a time and effort documentation at least:A.WeeklyB.MonthlyC.Semi-annuallyD.None of the above

EDGAR Plus Book OMB Circular A-122, Appendix B(8)(m)(2)(d),page 334

Page 19: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 17:

Postsecondary institutions are subject to:

A. OMB Circular A-21B. OMB Circular A-87C. OMB Circular A-122D. All of the above

EDGAR Plus Book Table of Contents page iiiOMB Circular A-21, page 233

Page 20: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 18:

An airplane ticket for a business conference obligates to the Federal grant award:

A.On the date the subgrantee decides 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 the traveler takes the flight to their destination.

EDGAR Plus Book 34 C.F.R. § 76.707, page 87

Page 21: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 19:

Professional employees of postsecondary institutions paid in whole or in part with federal funds, regardless of cost objectives, must fill out a time and effort certification at least:

A. MonthlyB. DailyC. Every six monthsD. Weekly

EDGAR Plus Book OMB Circular A-21,Part J(10)(c)(2)(e), page 257

Page 22: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 20:

Assuming all costs are reasonable, which of the following cost incurred during an overnight business trip is not allowable:A.Dinner (without any alcoholic beverages)B.Hotel roomC.Mileage costsD.A ticket to a movie

EDGAR Plus Book “Entertainment Costs”OMB Circular A-21, page 264OMB Circular A-122, page 337

Page 23: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 21:

A grantee /subgrantee can sole source a contract as long as the vendor does a good job.

A. TrueB. False

EDGAR Plus Book 34 C.F.R. § 74.43, page 20

Page 24: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 22:

Expenditures for services performed by a contractor are obligated to the Federal grant award:

A. On the date that the services are performed. B. On the date that the grantee/subgrantee

receives the invoice. C. On the date that the grantee /subgrantee

signs the contract for services.D. At any point during the period of availability.

EDGAR Plus Book 34 C.F.R. § 76.707, page 87

Page 25: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 23:

The major “systems” in grants management are:A. Procurement, Data Reporting, and

Contracting.B. Inventory Management, Procurement, and

Financial Management.C. Data Reporting, Financial Management, and

Inventory Management.D. Inventory Management,

Assessment/Evaluation, and Financial Management.

EDGAR Plus Book Part 74 Table of Contents, page 3

Page 26: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 24:

If there are funds remaining at the end of the project period, they may be used to purchase goods or services to be used in the future.

A. TrueB. False

EDGAR Plus Book AllocabilityOMB Circular A-21 Appendix C(4), page 238OMB Circular A-122 Appendix A(4), page 323

Page 27: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 25:

The cost of housing and personal living expenses for a nonprofit organization’s officers is an allowable direct cost if necessary for the performance of the grant and if grantor approval is received.

A. TrueB. False

EDGAR Plus Book OMB Circular A-122,Appendix B(20), page 339

Page 28: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 26:

A program that is partially funded with Federal funds that charges tuition for students to participate in the program may put all the tuition earned into its general funds account.

A. TrueB. False

EDGAR Plus Book 34 C.F.R. § 74.24, page 12

Page 29: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 27:

When postsecondary institutions or non-profits generate program income in a federal education program, they can use the program income as follows:

A. Add the program income to the program budget that earned the income.

B. Use the program income to finance the non-Federal share of the program.

C. Deduct the program income, after costs, from the program award.

D. All of the above.

EDGAR Plus Book 34 C.F.R. § 74.24, page 12

Page 30: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 28:

A physical inventory of all equipment must be taken:

A. YearlyB. Once every two yearsC. Once every six monthsD. Whenever you feel like it

EDGAR Plus Book 34 C.F.R. § 74.34(f)(3), page 17

Page 31: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 29:

If equipment is missing upon inventory review, the grantee or subgrantee must:

A. Simply remove it off the inventory list.

B. Buy a new piece of equipment quickly.

C. Interview every staff member until one confesses to the theft.

D. Investigate.

EDGAR Plus Book 34 C.F.R. § 74.34(f)(3), page 17

Page 32: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

Question 30:

A conflict of interest in procurement arises when the following persons have a financial or other interest in a firm that is selected for an award:

A. An employee, officer, or agent of the grantee or subgrantee.

B. An employee, officer, or agent of the grantee or subgrantee and his/her immediate family members.

C. An employee, officer, or agent of the grantee or subgrantee and his/her partners.

D. All of the above.

EDGAR Plus Book 34 C.F.R. § 74.42, page 19

Page 33: Allowability and Grants Management Test When Working With NonTraditional Providers Tiffany R. Winters, Esq. Erin Auerbach, Esq. twinters@bruman.com eauerbach@bruman.com.

The End!What Grade Did You Get??

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 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 does not create an attorney-client relationship with Brustein & Manasevit.  You should not

take any action based upon any information in this presentation without first consulting legal counsel familiar with your

particular circumstances.33