Ted Davis Manager Career Technical Education CTE

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

• 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 $$$ 2

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

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

• Federal Program Offices – http: //www. ed. gov • Perkins Act – http: //www. ade. az. gov/cte/downloads/Perkins. IV 081206. pdf • OMB Circulars – http: //www. whitehouse. gov/omb/circulars • EDGAR –http: //www. ed. gov/policy/fund/reg/edgar. Reg/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”. 8

• 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 9

• 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. 10

• 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… 11

• 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. 12

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

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

Ted Davis – • Arizona Department of Education • Career & Technical Education Section • Phoenix, AZ • 602 -542 -5349 • ted. davis@azed. gov 15