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On Friday, September 4th, a D.C. District Court judge vacated the Interim Final Rule from the U.S. Department of Education on providing equitable services under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. This means that ED’s interim final rule is not enforceable. However, this brings about more questions than answers. Can SEAs and LEAs continue to use the various methodology options under the IFR? Must LEAs recalculate their proportionate share? What about expenditures already made? May all teachers and students continue to be served? This virtual training will review the applicable court cases, discuss the consequences of the decisions, and provide recommendations and best practices in light of the legal standards and defenses for moving forward.
Each year, the Office of Management and Budget (OMB) releases the OMB Compliance Supplement. This document provides auditors with the necessary guidance for conducting Single Audits of federal programs for all non-federal entities that expend $750,000 or more in federal funds in a year. Among other things, the Compliance Supplement includes definitions and descriptions of all compliance requirements, ways to test internal controls, and specific areas of focus for various federal programs.
This virtual training will discuss relevant changes to the 2020 Supplement, released on August 14, including relevant language regarding time & effort reporting, applicability of compliance requirements to major federal education programs, and the impact of COVID-19 and related grants. As this Compliance Supplement is the guide book auditors will use for the coming year, it is important for all federal program administrators at non-federal entities to be familiar with the changes and relevant language included in this year’s edition.
On August 13, 2020, the Office of Management and Budget published the final updates to the Uniform Grants Guidance (2 CFR Part 200). Only two rules go into immediate effect, while most of the revisions will not apply until grant awards after November 12, 2020. No matter what, every State education agency, school district, college, university and nonprofit must be in compliance with these new rules by the time they receive their July 1, 2020 grants awards. The UGG update affects procurement, pre-award costs, the liquidation period, period of availability, budget period, and more. Don’t miss what will be an exciting summarization of the new changes and how it will affect your administration of federal grants!
Can SEAs and districts charge indirect costs to CARES Act funding? If so, what rate should be used? How do funding shortfalls, stimulus money and school closures impact indirect cost recovery? How do agencies charge terminal leave, mass severance and other benefits to grants? In this session, we will provide straight-forward answers to your questions on cost allocation, indirect cost rates, and more.
You made it through the introductory sessions now test your knowledge. In this interactive session, you’ll have the chance to test your knowledge of the federal grants management rules. We’ll cover a wide range of topics, from allowability to procurement to time and effort and more! Join us to show off what you have learned and maybe even learn some more new things!
The Uniform Grant Guidance (UGG) has now been in effect for five years. One of the major reforms instituted by these federal regulations is in the arena of subrecipient monitoring. Prior to the issuance of the UGG, most pass-throughs satisfied the statutory requirement for monitoring by random or geographic selection criteria, and conducted invasive and exhausting on-site reviews. The UGG changed that with the requirement to base monitoring on risk factors. In addition, the UGG permits technical assistance and training to satisfy the monitoring requirement. Pass-through agency staff have been gravitating towards desk-level and virtual monitoring, and even more so now in light of COVID-19. This training will discuss in detail the legal parameters of the UGG monitoring and enforcement requirements. We will profile the recent guidance from ED’s OCFO on the pass-through review of single audits, and the requirements for management decisions. We will share best practices from states. Whether you work for the pass-through or the subrecipient, you need to understand these expanding requirements.
This virtual training will review the time and effort rules under EDGAR as well as ED’s new cost allocation guide, provide examples of time and effort forms, review flexibilities to address teleworking and discuss audit findings while providing best practices on how to avoid them.
The COVID-19 pandemic has emphasized the importance of maintaining student privacy policies and procedures that address the requirements and best practices for protecting student privacy while working from home, in a typical office setting, or while offering online educational services.
This virtual training will discuss how to maintain student privacy when staff are working from home and when staff participate in a “bring your own device” program. Additionally, this training will cover parents’ right to access records and complying with those requests when schools are closed, and the use of electronic consent.
This virtual training will also cover issues in offering online education, including the definition of personally identifiable information, the definition and disclosure of directory information, the use of the FERPA school official exception in providing online educational services, the use of video or other forms of online instruction, and the application of the Protection of Pupil Rights Amendment, and terms of service for online services.
This virtual training will focus on the federal requirements from the Uniform Grant Guidance dealing with financial management systems, procurement, and inventory management. Looking at prior audit and monitoring findings, we will discuss common mistakes and compliance issues grantees and subrecipients often run into in managing their federal grants. This session will also cover some best practices to help strengthen internal controls and void these common pitfalls in the world of grants management.
This virtual training will review audit findings from prior disaster relief audits and discuss applicability to current COVID-19 allowability issues and concerns. The session will discuss how best to document and address OMB’s COVID flexibilities approved by ED to avoid audit findings and provide best practices as to how States, districts and IHEs can implement internal controls to assure allowability while reducing the risk of fraud, waste, and abuse of current federal funds.
“Is this allowable?” is one of the most common, but sometimes difficult, questions that grants personnel face. This presentation will provide participants with an overview of the cost principles and selected items of cost found in Part 200 of the Uniform Grants Guidance. This presentation will also include an overview of best practices for compliant allowability procedures and internal controls, and review all relevant factors that non-federal entities must consider when determining allowability of costs.
This virtual training will review in detail the Interim Final Rule from the U.S. Department of Education on providing equitable services under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Attendees will review the statutory language in the CARES Act and precedent in the Elementary and Secondary Education Act, as well as the April 2020 non-binding guidance on equitable services. The presentation will compare and contrast those documents with the Interim Final Rule issued in June of 2020, and cover the details of that rule as well as implications for States and districts. Finally, the webinar will discuss the potential for further change to that rule, and when the issue might be resolved.
This virtual training will outline the requirements of the new final rule on sexual harassment and assault under Title IX of the Education Amendments of 1972. This new rule will require, at institutions of higher education, courtroom-like adjudicatory hearings where designated representatives for both parties would be able to call and cross-examine witnesses. These hearings would be optional for K-12 schools. Additionally, the new rule changes the standard of what constitutes sexual harassment and requires recipients of federal funds to train personnel to evaluate evidence, implement the “rape shield” law, and make decisions on one of two standards of evidence. Implications for educational entities, pushback, and major requirements to be implemented before the coming school year will all be covered.
This virtual training will cover the ins and outs of relief funding for higher education provided by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, including allowable uses of funds and frequently asked questions. In addition, this session will provide up-to-date information on flexibilities offered by the U.S. Department of Education to postsecondary institutions and accrediting agencies in response to the COVID-19 pandemic, including guidance for COVID-19-related interruptions of study and flexibilities offered for career and technical education programs. We will also discuss general federal grant flexibilities authorized by the Office of Management and Budget that are available to postsecondary institutions.
The COVID-19 school closures have created unprecedented challenges for school systems, not the least among them the provision of special education and related services to students with disabilities in accordance with IDEA. This virtual training will cover high priority IDEA compliance topics in terms of closing out the 2019-2020 school year during these challenging times and preparing for a successful return to brick and mortar operation, as well as, reviewing the impact of and potential flexibilities that may come from the Coronavirus Aid, Relief and Economic Security (CARES) Act on IDEA programming. The CARES Act provides new funding that includes all allowable uses of funds under IDEA (as well as many other flexible options) and provided the U.S. Secretary of Education with an opportunity to request the authority to waive requirements not otherwise waivable. CARES Act funds will be available as well as remaining FY 19 IDEA funds with FY20 funds coming in July. Will the FY 18 IDEA funds be extended until 2021 under GEPA as the ESSA funds have been? Each of these funding streams must be documented and expended on allowable costs. The session will highlight topics such as allowability, extended school year, compensatory services, and maintenance of effort, among others.
States and school districts have significant accountability when it comes to ensuring their ESSA funds are spent in an allowable manner. New funding always brings higher risk. The Coronavirus Aid, Relief and Economic Security (CARES) Act includes all allowable uses of funds under ESSA (as well as many other flexible options), ESSA FY18 funds are extended until 2021, and there are still FY 19 ESSA funds with FY20 funds coming in July. Each of these funding streams must be documented and expended on allowable costs. This virtual training will cover the current requirements and flexibilities offered by the Office of Management and Budget and the U.S. Education Department. The session will review documentation best practices and discuss how States and districts can implement internal controls to assure allowability and reducing the risk of fraud, waste, and abuse.
ED released guidance outlining its interpretation of how states and districts must provide CARES Act equitable services. Notably, ED’s guidance requires the CARES Act equitable services set-aside to be calculated on total enrollments in public verse private schools, not taking poverty into account. This appears inconsistent with the Congressional language on the way equitable services should be provided and with how allocations to States and districts are calculated, so took States and districts by surprise – and is likely to draw significant pushback. The guidance answers additional questions, such as what non-public schools are eligible for the funds, who may be served, which LEA is responsible for providing the equitable services, and how and when to begin the consultation process. This session will cover ED’s guidance and its impact on districts. We will also cover Congressional and district reactions to the guidance, and the general enforceability given the disclaimer that the contents “do not have the force and effect of law and are not meant to bind the public in any way.”
This virtual training will review the educational stimulus provisions of the CARES Act (the Coronavirus Aid, Relief, and Economic Security Act), including the additional funding available for ESEA and other major programs through the U.S. Department of Education and State Governors, as well as new waivers mandated by Congress. This will include discussion of the potential uses of funds for that funding and cautions regarding fiscal requirements.
Attendees will learn about the discussion regarding providing the Secretary of Education with expanded waiver authority in areas like the Individuals with Disabilities Education Act, the Perkins Act, ESEA, and others, and what the Secretary is likely to request – as well as what Congress may or may not approve. Existing waiver authority under ESEA, new expedited waivers, and considerations like advocate concerns will also be covered.
Finally, this session will cover major guidance issued to date regarding COVID-19 and its impact on ESEA programs.
This virtual training will cover COVID-19-related legislation enacted, including any supplemental appropriations or economic stimulus measures and how that legislation may impact and provide relief to federal grantees. The training will also discuss COVID-19 guidance for grantees from the Office of Management and Budget and the U.S. Departments of Education and Agriculture, which may cover issues such as extended school closures, child nutrition program flexibility, and federal ESEA waivers, among others. Finally, this training will delve into precautions that grantees must take if seeking to transfer federal funds to meet local obligations as States face reduced tax revenues and increased demands on Medicaid.
In light of the current coronavirus outbreak, it is important to think ahead, plan, and prepare to ensure compliance with IDEA and Section 504 of the Rehabilitation Act. What do extended periods of school closures mean in terms of providing a free and appropriate public education (FAPE) to students with disabilities? What considerations should be made for students who have health conditions that may put them at higher risk for a severe reaction to the virus? During this virtual training session, we will cover considerations that need to be made in serving students with disabilities during these challenging times, including addressing common scenarios likely to arise during the next few months, as well as explore implications on the use of IDEA funds.
All non-federal entities must maintain proper cash management procedures. While most grantees and subrecipients understand that this includes proper disbursement and reimbursement procedures, non-federal entities may find themselves in hot water if they do not follow proper cash management rules related to income earned in a federal program, and applicable credits received during the award, or in tracking and recording cash and in-kind contributions for matching or cost sharing requirements. This webinar will discuss the applicable financial management rules, including how to record and use program income, applying credits to federal awards in line with the regulations, and how to properly document matching funds and services.