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Documentation You Need to Comply with the New Federal EDGAR Requirements
At TECS, we know EDGAR. We are ready to help you get EDGARIZED and implement the new EDGAR requirements in 2 Code of Federal Regulations 200 with documentation solutions tailored to the needs of your school district or charter school.

I. EDGAR is the nickname for Title 2 of the Code of Federal Regulations 2 CFR 200. EDGAR requirements and regulations apply to any school district or charter school that receives federal funds. EDGAR applies to any federal grant received after December 26, 2014, including NCLB, IDEA-B, and Perkins. Federal resources limit the application of EDGAR rules and regulations to federal funds only. School districts and charter schools, however, may want to consider adopting the rules in EDGAR for both federal and state and local funds.

Districts and charter schools that have not yet implemented EDGAR can take advantage of a grace period, which ends on July 1, 2017. Districts or charter schools taking the grace period must document that action in their procurement policies and procedures.

What you should do now: Purchasing Director or Business Manager – If your district or charter school has not yet implemented EDGAR, document in your policies and procedures that you will implement EDGAR by July 1, 2017. TECS can help you prepare your policies and procedures so that they comply with the new EDGAR.

II. According to the Texas Education Agency’s Internal Controls Guidance Handbook, “Under the new EDGAR, grantees must strengthen accountability for federal funds and improve local policies that prevent, detect, and reduce fraud, waste, or abuse of funds.” EDGAR impacts:

• Requirements for internal controls;
• Documented business procedures;
• Compliance with federal statutes, rules and conditions;
• EDGAR Coaching
• Financial management;
• Grant fund expenditures and the impact of those expenditures on grant program outcomes;
• Monitoring and reporting: and
• The assessment of district and charter school risk by oversite agencies.

What you should do now: Federal Programs Director and Business Manager – Work across your departments to develop policies and procedures for federal funds and programs. Document those policies and have them approved according to your approval process, by either your Board or Administration. Apply those policies and procedures to the financial management of all federal formula and competitive grants.

III. In order to get EDGARIZED, you must have documented procedures that comply with the requirements in the Code of Federal Regulations and include:

• Payment with Grant Funds (2 CFR 200.302);
• Determination of the Allowability of Costs (2 CFR 200.302);
• Procurement (2 CFR 200.318);
• Standards of Conduct and Conflict of Interest (2 CFR 200.318);
• Evaluating Proposals in Response to RFPs (2 CFR 200.320);

The federal General Accounting Office, in The Green Book, describes the documentation that provides evidence of a robust system of internal controls, which includes, at a minimum:

• Policies and procedures supporting the system of internal controls;
• Management responsibilities and roles;
• Organizational objectives; and
• Methods of correcting audit findings related to gaps in internal controls.

What you should do now: Federal Programs Director and Business Manager – Align your business operations with EDGAR requirements. If your operations or procedures are not compliant with EDGAR, bring them into compliance by July 1, 2017.

IV. At TECS, we are EDGAR experts! We understand EDGAR’s documentation requirements. We can work with your current operational policies and procedures to bring your district or charter school up to the standards required by the new EDGAR. We provide assurance that your process of EDGARIZATION is smooth and successful.

What you should do now: Federal Programs Director and Business Manager – Contact TECS to review your district’s or charter’s policies and procedures, conduct a gap analysis to compare them to EDGAR requirements, and develop EDGARIZED policies, procedures, and business work flows.

For more information contact TECS, Inc. at 866.513.5515, extension 2104, or email darrigona@tecslink.com.

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