Navigating the New EDGAR

Transcription

1 Navigating the New EDGAR MASB Fall Conference October 23, 2015 Brad Banasik, Esq. Legal Counsel/Director of Labor Relations & Policy Michigan Association of School Boards phone: (517) Richard N. Clapp, Ph.D. President Neola, Inc. mobile: (330) NAVIGATING THE NEW EDGAR The Education Department General Administrative Regulations (EDGAR) Key Components Title 34 Part 75 Direct Grants Program Part 76 State-Administrated Programs Title 2 Part 200 Cost/Administrative/Audit Rules 1

2 EFFECTIVE DATES 2 CFR PART 200 December 26, 2014 Direct Grants from ED July 1, 2015 State Administered Programs July 1, 2016 Procurement Rules One Year Grace Period APPLICABLE PROGRAMS Statute Authorizes Fund Allocation to States by Formula State Allocates Funds by Formula Title I IDEA-B National School Lunch Program Perkins Competitive Awards AEFLA Adult Education & Family Literacy Act 21st Century Schools UNIFORM GRANT GUIDANCE Written policies and procedures are required! Emphasis on internal controls 2

3 NEW FINANCIAL MANAGEMENT RULES 2 CFR (B) (PG 118) 1. Identification of Awards (NEW) 2. Written Cash Management Procedures (NEW) 3. Written Allowability Procedures (NEW) 7 FINANCIAL MANAGEMENT CONTROLS Internal Controls Budget Control Cash Management Procedures Allowability Procedures Time and Effort Documentation Procurement Standards Conflict of Interest Vendor Selection Property Management UNIFORM GRANT GUIDANCE Written Cash Management Procedure (b)(6) & Written Allowability Procedures (b)(7) Written Conflicts of Interest Policy (c) Written Procurement Procedures (c) Written Method for Conducting Technical Evaluations of Proposals and Selecting Recipients (d)(3) Written Travel Policy (b) 3

4 POLICIES Grants Management (Policy 6110) Record Keeping Time & Effort Conflict of Interest ( Bylaw ; Policy 1130/3110/4110) Procurement (Policy Purchasing) Cost Principles Vendor Selection Methods of Procurement Bid Protest Travel (Bylaws and ; Policy 6550) Financial Management (Policy 6110/6111) Internal Controls Cash Management Inventory & Property Management (Policy 7300/7310/7450/7455) VOLUME 30 NUMBER 1 UPDATE Conflict of Interest Bylaw ; Policy 1130/3110/ Revised Grant Funds Policy 6110 Revised Internal Controls Policy 6111 New Purchasing Policy 6320 Revised Travel Payment & Reimbursement Policy 6550 Revised Food Services Policy Revised WRITTEN PROCEDURES Administration of Grant Programs Allowable Cost Compliance Direct Costs Indirect Costs Obligation of Funds Property & Equipment Management Disposition of Equipment Records Retention Travel & Expense Procurement 4

5 CURRENT/COMPLIANT NOT ENOUGH Regular/Periodic Review/Report in consultation with Publish/post Administrative Guidelines Implement CURRENT/COMPLIANT NOT ENOUGH Training: Harassment Medications/Treatment Public Records Professional Misconduct Ethics Suicide Prevention Epi-pen Bullying Child Abuse Technology Use Wellness Safety Diabetes YOUR WORK IS NEVER DONE Policies and procedures are only useful if they are current, accurate and regularly used. Ongoing professional development and training What the requirements are, and how your organization meets the requirement. Continually review and revise 15 5

6 Brad Banasik, Esq. Legal Counsel/Director of Labor Relations & Policy Michigan Association of School Boards phone: (517) Richard N. Clapp, Ph.D. President Neola, Inc. mobile: (330) NEOLA, INC. (1,300 SCHOOL DISTRICTS IN 7 STATES) Bylaws and Policies Administrative Guidelines Electronic Publishing Update Service BYLAWS & POLICIES Domain of the Board Statutory Responsibility What 6

7 PURPOSE Statutory Requirement Federal/State Regulatory Agency Authority/Guidance Establish Parameters ADMINISTRATIVE GUIDELINES/PROCEDURES Responsibility of the Superintendent/Treasurer/CFO Implementation of Board Policy/Statute Who When Where How BYLAWS & POLICIES