Mood:  bright

It is lunch time and I am at my desk chowing down on a wonderful lunch that I made which I am very pleased with if I do say so myself. A beautiful salad (my own homemade dressing) with grilled chicken, parm cheese, cucumbers, red onions and mini-roma tomatoes and garlic bread croutons. I am also having some very ripe and wonderfully juicy fresh pineapple! Weee, I love this stuff. Top that off with an orange Sunkist soda and it is one of those perfect lunches for the moment.

See - here's the situation. I have a meeting at 2pm (god awful time to schedule a 2 hour meeting) but that is the only time a conference room was available and I am the principal presenter. I need to be up and lively. The information that I am speaking on is regulatory law. Joy of all joys for those people who are lawyers and love this stuff. I have no problem with regulatory law since I have been working on it since 1996 and understanding it is like falling off a log for me after 12 years of using it and explaining it to people. The 35 or more attendees at my Grant Management meeting today are not lawyers, nor are they people such as myself who enjoy law. They are current or former teachers who now manage our district grants or they are bookkeepers (not CPAs) former secretaries that learned through trial and error how to do bookkeeping.

I am speaking on two Codes of Federal Regulation (CFR). 2 CFR which covers grants, and 34 CFR (aka EDGAR) which covers the US Department of Education. When I worked for the Indian Tribe in CA, I had to know a whole bunch more on CFRs - the one that covers Tribes, another one for HUD, another for EPA, another for HUD, another for DOT, another for DOI, another for FEMA, etc. So, only having to focus on two today is kind of a "gift horse" compared to what I once did. I have downloaded copies of the various subparts I am going to be speaking on, and hopefully will not have to resort to reading the regulations to them verbetium. I'd much rather point out the highlights, emphasis best practices for implementing the regulations and understanding of the spirit of the laws.

Beside the federal regulations governing grants that can be found in CFRs, I am going to be speaking on the Government Accountability Office (GOA) requirements known as Chapter 2, section 16.8(c)...can you say "weeeee"? Yeah, definitions used by government employees that will be auditing us. Our employees need to know these definitions so when they speak with the federal monitors they understand what the feds are saying. Add to that Office of Management & Budget (OMB) Circulars A-87 (which was recently codified into 2 CFR Part 215) and OMB Circular A-133 & its Compliance Supplement and I think my meeting attendees might go suicidal on me.

If that weren't enough, I have to cover the state statutes and guidance manuals as well as our own Board of Education policies. You think that our own employees would know the policies that they are employeed under, but sadly, no they do not. Our new Director of Grants & Development Services has been working tirelessly to get all of this information on our district portal for grants, but I doubt these people are paying attention to all his work.

One blessing - no PowerPoint. I do not like to do PowerPoint presentations if I can avoid them. The handouts they produce are worthless. I supply the meeting attendees with my outline and notes I am speaking from and tell them to follow along and take notes. I use my overhead projector and laptop to bring items onto the screen the emphasize what I am speaking about. Cute little slides with bulletpoints are just too annoying for me to deal with during this type of a meeting.

Handouts galore for this meeting though - grrr, not my first choice, but this is a response to an auditor's comments and well...here's the situation.

Our audit went so well they couldn't find one thing wrong. The sampled 25% of our transactions since we are a low risk auditee and found nothing to be out of compliance, no fraud, we were fabulous! Auditors, though, have to prove their worth, and since nobody is perfect, they couldn't say that we were. They have GOT to find something. Now, listen, if you audited us and you found no material weaknesses, reportable conditions or significant deficiencies shouldn't that be enough. Well, no, not for these auditors. They decided to go full force into Compliance Testing. Which means, they couldn't find anything financial wrong with our transactions, so now they are going to look at our procedures and internal control stuff. Well, they didn't find anything and they left the end of October. We thought we were done.

Last week though, an auditor contacted one of my grant managers who is over a Type A program (big money) and asked her how she verified if the vendors she used in her grant weren't suspended or debarred from receiving federal dollars. The grant manager called me freaked out. I answered that under 34 CFR Part 80.35 and 80.36 that we couldn't give a subgrant or a contract to anyone that was on this list BUT that it wasn't the grant manager or I that checked on vendors it was our Purchasing agents that had to do this. It is a requirement in the regulations. Now, here is the thing. That grant has maybe four vendors used as a majority of the money is spent on hiring teachers, not paying contracted vendors. None of the vendors the grant used where debarred or suspended. This was not the issue. The issue was the Purchasing dept didn't have a procedure in place for checking the federal website to check if the vendors were on the government's debarred and suspended list. So, there is a risk there, since Purchasing isn't doing anything.

This is not a material weakness per se, as the district hasn't provided funds to debarred or suspended vendors, but because the Purchasing dept doesn't have a standardized procedure, we could accidently use a barred vendor and violate the regulations at 34 CFR Part 80.35 & 80.36.

I knew the regulations were there and have known for years, but training the Purchasing department on their own procedures is not within my realm of influance. They are in the Operations Division and I am Financial Services and if I were to try and tell somebody elses employees what they should do or not do, well, I think I would be crossing a line that I shouldn't cross. One time I mentioned a Purchasing policy in one of these grant management meetings and had a not so nice email whipped off at me from the Division Director. That was five years ago and he and I are cool now - he's one of my Facebook friends, but still, I do not mention Purchasing policy or procedures in my grant workshops. That's a fine line to walk and I am not about to try and tap dance on that line like I know all of their policies. Besides, they are Purchasing agents with licenses and go to their own trainings and whatnot, and they make FAR more money than I do. They should know their stuff and not have to hear it from me - someone not in their Division and beneath them in paygrade. So, this has lead to a comment from the auditors that will be addressed in the management letter of the audit.

Still - because of all this audit bullshit and the vendor question, it has been suggested (although not said outright) that I need to crack down on my people and slam some hardcore regulations into them so next year when the auditors are digging for something my people won't freak out and cause a stir, and can respond to the question calmly.

Thank goodness for fresh pineapple! I am going to need all the energy to keep this meeting alive and moving forward. I wish I knew how to juggle and do magic tricks.