2015 2016 Workshop Series UNIFORM GRANT...

2015‐2016 Workshop Series

UNIFORM GRANT GUIDANCE * April 19, 2016 Webcast (9:30 – 11:30 AM)

The US Office of Management and Budget (OMB) issued comprehensive grant reform rules titled, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” The new requirements consolidate what was previously in eight separate OMB Circulars into a single new document. This consolidation resulted in various areas of change to the previous requirements. These new rules are being commonly called the Uniform Grant Guidance (UGG). The objective of this webcast is to assist participants with preparing for implementation of the requirements of the UGG.

The UGG requirements apply to all federal awards and certain modifications to existing federal awards made after December 26, 2014. The requirements apply to awards received directly from federal agencies and federal awards passed through other entities such as the State of Pennsylvania and Pennsylvania Intermediate Units. Webcast participants will gain an understanding of what is changing under UGG and will gain the tools and resources needed to ensure compliance with the new requirements. Learn about:

An analysis of the most significant change under the UGG

The impact of changes on LEAs

Policy and procedure changes necessary to achieve compliance with UGG

Review of available resources, templates, and forms

Sample policies and procedures

INTENDED AUDIENCE: Business Manages, Accountants, Federal Program Coordinators

SPEAKERS: Gina L. Brillhart, CPA, CFO/Assistant to the Executive Director, Lancaster‐Lebanon IU #13 John W. Compton, Jr., CPA, CGFM, Partner, Baker Tilly Virchow Krause, LLP Adam Hartzel, CPA, Senior Manager, Baker Tilly Virchow Krause, LLP Cindy Rhoads, UGG Coordinator, PDE Division of Federal Programs Heather Masshardt, Policy Services Manager, Pennsylvania School Boards Association

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Thank you for your participation!

Pennsylvania Association of School Business Officials

Mailing Address: Office Location: P.O. Box 6993 2608 Market Place Harrisburg, PA 17112-0993 Harrisburg, PA 17110 Telephone 717-540-9551 www.pasbo.org FAX 717-540-1796

PASBO Webcast Presentation 1

Uniform Grant Guidance

April 19, 2016 Webcast 9:30 - 11:30 AM

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Pennsylvania Association of School Business Officials

Presenters

• Gina L. Brillhart, CPA, CFO/Assistant to the Executive Director, Lancaster‐Lebanon IU #13

• John W. Compton, Jr., CPA, CGFM, Partner, Baker Tilly Virchow Krause, LLP

• Adam Hartzel, CPA, Senior Manager, Baker Tilly Virchow Krause, LLP

• Heather Masshardt, Policy Services Manager, Pennsylvania School Boards Association

• Cindy Rhoads, UGG Coordinator, PDE Division of Federal Programs

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Smart Business + Informed Decisions = Great Schools

Part 1 ‐ Significant Changes and the Impact on LEAsJohn W. Compton, Jr., CPA, CGFMPartner, Baker Tilly Virchow Krause, LLP

Adam Hartzel, CPASenior Manager, Baker Tilly Virchow Krause, LLP

Part 2 ‐ SEA/LEA RequirementsCindy RhoadsUGG Coordinator, Federal Programs Division , PDE

Part 3 ‐ Policies, Procedures, and ResourcesHeather MasshardtPolicy Services Manager, PSBA

Gina L. BrillhartCFO/Assistant to the Executive Director, IU13

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Today’s Session

Smart Business + Informed Decisions = Great Schools4

Part 1: Significant Changes and the Impact on LEAs

John W. Compton, Jr., CPA, CGFM

Partner, Baker Tilly Virchow Krause, LLP

Adam Hartzel, CPA

Senior Manager, Baker Tilly Virchow Krause, LLP



• December 26, 2013− Published in Federal Register

• December 26, 2014− Administrative and Cost Principles effective− System‐wide changes− New Awards− Increments added to existing awards

• Fiscal Years beginning after December 26, 2014− Audit requirement changes

• Fiscal Years beginning after June 30, 2017− Procurement changes

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UGG Effective Dates


Reduce administrative

burden

Improve the integrity of financial

management

Strengthen accountability for federal dollars

Increase impact and accessibility of

program

Reorient recipients toward achieving program objectives

Award grants based on merit

Increase management focus on performance

outcomes

Streamline rules governing federal

funds

Reduce fraud, waste and abuse

through single audit tool

Objectives of New Guidance

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The following OMB Circulars are superseded:

• A‐21, Cost Principles for Educational Institutions

• Sections of A‐50, Audit Follow‐Up, related to Single Audits

• A‐87, Cost Principles for State, Local and Indian Tribal Governments

• A‐89, Federal Domestic Assistance Program Information

• A‐102, Awards and Cooperative Agreements with State and Local Governments

• A‐110, Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations

• A‐122, Cost Principles for Non‐Profit Organizations

• A‐133, Audits of States, Local Governments and Nonprofit Organizations

All OMB guidance now streamlined in 2 CFR 200

Streamlining Circulars and Guidance

7


Reforms to administration requirements

(subparts A-D)

Reforms to cost principles

(subpart E)

Audit requirements

(subpart F)

Subpart A, 200.XXX –Acronyms and Definitions

Subpart B, 200.1XX –General

Subpart C, 200.2XX –Pre‐Award – Federal

Subpart D, 200.3XX –Post Award – Recipients

Subpart E, 200.4XX –Cost Principles

Subpart F, 200.5XX –Audit Requirements

Three Major Sections

Plus, 11

Appendices

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Items getting the most attention:

200.23 – “Contractor” replaces “vendor”

200.303 – Internal control guidance within administrative requirements

200.317 ‐ 200.326 – Procurement requirements

200.330 ‐ 200.332 – Subrecipient monitoring

Cost Principles

200.412 ‐ 200.414 – Direct and indirect costs

200.430 – Compensation, personal services

UGG Administrative Requirements

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1. Schedule of Expenditures of Federal Awards (SEFA)a. Starting point for single audit testing

b. Preparation of the SEFA (2 CFR 200.510)

c. Must include:– Total federal awards expended–Amounts provided to subrecipients–All other non‐cash awards

• food commodities

• donated property

• others

– Total for each CFDA number and cluster of programs– Pass‐through entity ID number

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UGG ‐ Auditee Responsibilities



2. Schedule of Expenditures of Federal Awards (SEFA)• New Notes to the SEFA (2 CFR 200.510)

–Use of indirect cost rate– Loan and Loan guarantees at end of period

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3. SEFA• Important notes about the SEFA

–Reconcile to accounting and other records–Auditor uses the SEFA to base the performance of risk assessments and selection of major programs

– Completeness and accuracy is critical


4. Financial Management System

Auditee financial management system must provide for the following (2 CFR 200.302):

• Identification of all federal awards. Include:– Catalog of Federal Domestic Assistance (CFDA) title and number

– Federal award identification number and year– Federal awarding agency– Pass‐through entity (PTE), if applicable

• Accurate, current, and complete disclosure of the financial results

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5. Internal Control and Compliance Requirements

Establish and maintain internal

control over federal programs

Comply with federal statutes,

regulations, federal awards

Evaluate and monitor

compliance

Take prompt action when

non-compliance is identified

Safeguard protected personally identifiable

information (PPII)


Changes Section

Required to establish and maintain effective internal controls over federal programs

200.303

(Previously only in single audit requirements)

COSO and federal green book tied inalthough Q&A clarifies usage as “best practice”

Internal Controls

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Requirements for Written Policy/Procedure:

1. Cash Management Procedure (200.302)

2. Allowability of Costs Procedures (200.302)

3. Conflict of Interest Policy (200.318)

4. Procurement Procedures (200.319)

5. Travel Policy (200.474)

6. Subrecipient Monitoring Procedure (200.331)

Internal Controls

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Process Narrative• A written description of business practices to create, record, transfer, or change information.

• A process narrative details the steps required from initiation to completion to achieve an objective.

Control Documentation• A written description of methods to prevent, detect, or correct errors from occurring.

• May include:

− Control objective type

• Preventive

• Detective

− Owner

− Frequency

Process vs. Control

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Factors SectionCosts must be reasonable (prudent person test) 200.404

Costs must be allocable (charged in accordance with relative benefit received)

200.405

Costs must be net of applicable credits (purchase discounts, rebates, allowances, recoveries, refunds, adjustments)

200.406

Certain costs require prior written approval 200.407

Unallowable costs (if identified after paid, must be refunded) 200.410

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Cost Principles

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Changes Section

Focus on high standards for maintaining strong internal controls to justify costs of salaries and wages

200.430

Flexibility in process used to meet those standards 200.430

Personnel activity reports not specifically required – focus shifted to appropriate internal controls in place

200.430

Internal controls must exist to ensure adjustments are made so final amounts charged to federal awards are proper

200.430

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Cost Principles – Time & Effort

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Time distribution records must be maintained for all employees:• Paid in whole or in part with federal funds• Used to meet a match/cost share requirement

Cannot be based on budgeted distributions alone – needs to be supported by actual hours worked. Budgets may need adjustment.

Include all time worked for the organization to calculate what portion relates to federal awards.

Nonexempt employees must also prepare records indicating the total number of hours worked each day.

In addition to the allocation of time, need to continue to consider controls over existence of employees, reasonableness of compensation

If previous system of controls worked well, no changes may be needed.

Considerations ‐ Time & Effort

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Category Section

Direct costs are defined as those costs that can be identified specifically with a particular grant award (or cost objective)

200.413

Indirect costs are those incurred for a common or joint purpose benefitting more than one cost objective

200.414

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Cost Principles – Direct and Indirect

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Changes SectionClarification that administrative costs may be treated as direct costs when they meet certain conditions

200.413

Provision for de minimis indirect rate of 10% of modified total direct costs (MTDC) for those who have never had a negotiated indirect rate

200.414

For those with negotiated rates, requires federal agencies to accept (usually)

200.414

Entities may apply for a negotiated rate at any time 200.414

Existing negotiated rates may be extended for up to four years 200.414

Pass‐through entities required to provide indirect cost rate to subrecipients

200.331

Cost Principles – Direct & Indirect

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Changes Section

Payment of interest earned on federal funds• Up to $500/year may be retained by recipient for

administrative costs• Amounts in excess of that should be paid to one central

federal agency (HHS)

200.305

Interest on Federal Funds

22



Changes SectionDefined that computers are considered supplies, not equipment 200.940

Flexibility in electronic document retention, with associated internal controls

200.335

Grant documentation should be retained for a minimum of 3 years from date of submission of final reports

200.333

Technology & Record Retention

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• Effective Date – originally December 26, 2014; revised to allow for a grace period

− Two full fiscal years after the effective date of Uniform Guidance

• Calendar year ‐ grace period ends December 31, 2016

• June 30th fiscal year ‐ grace period ends June 30, 2017

− Compliance with the old or new standard must be documented each year of the grace period.

− Auditors will review procurement policies and procedures based on the documented standard.

• Still a work‐in‐process

• More information to come from PASBO, PSBA, and DFP in the coming months

24

New Procurement Standards



Definitions

Subrecipient – a non‐Federal entity that receives a subaward from a pass‐through entity to carry out part of a Federal program

Contractor – an entity that receives a contract as defined in 200.22 Contract (terminology of vendor no longer used)

Pass‐through entity must make case‐by‐case determination whether each agreement it makes for disbursing federal funds is a subrecipient or contractor, which should also be documented.

Nature of relationship trumps what the agreement is called!

Subrecipient Monitoring

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Changes Section

Heightened focus on subrecipient monitoring 200.331

• Various required elements of subaward

• Mandatory risk assessment to determine appropriate monitoring

• Verify subrecipients have audits, if required

• Review audit results and adjust pass‐through entity records, if needed

• Determine necessary action for subrecipient noncompliance, follow up, issue management decision


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Factors to Consider in Evaluating Subrecipient Risk:

• Prior experience with same or similar subawards • Results of previous audits• Whether new or substantially changed personnel or systems• Extent and results of Federal awarding agency monitoring

Monitoring must include:• Reviewing financial and performance reports required by the pass‐through

entity• Follow up and ensuring timely and appropriate action on deficiencies• Issuing a management decision for audit findings

Subrecipient Risk Assessment & Monitoring

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Determine if subrecipient or

contractor

Clearly identify subawards to subrecipients

Consider results of subrecipient audits

Provide certain subaward

information at time of subaward

Evaluate each subrecipient’s

risk of noncompliance

Consider imposing specific

subaward conditions

Monitor activities of subrecipients

Verify the subrecipient is

audited

Consider taking enforcement

action for noncompliant subrecipients

Pass‐Through Entity Requirements



• Effective for years ending on and after December 31, 2015; for June 30th fiscal years, June 30, 2016 (no early implementation)

• Single audit threshold raised from $500,000 to $750,000

• Low risk auditee criteria updated

• Threshold for Type A program raised from $300,000 to $750,000

• Questioned costs threshold raised to $25,000 (known or likely) and requires description of calculation

• Findings require “perspective” section (isolated, prevalent, type of sampling used)

• Repeat findings require identification as repeat and the prior finding reference number

Single Audit Changes

29


• Federal due date is still nine months after fiscal year end.

− Any future changes would require a change in federal law (not currently proposed).

• An entity with strong internal controls and few audit findings will likely have fewer high‐risk Type A programs

What Hasn’t Changed?

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• Has always been important – even more so now!

• What has changed:

− Include total amount provided to subrecipients for each federal program

• What hasn’t changed:

• Prepared by auditee

• For the same entity/time period as the basic financial statements

• Reconciled or reconcilable to underlying accounting records/financial statements

SEFA – Section 200.510

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• Include at a Minimum:− List individual federal programs by federal agency.

• For a cluster, list individual federal programs within the cluster

− Identify the pass‐through entity and related identification number

− Include total amount provided to subrecipients for each federal program

− Provide total federal awards expended by individual program/cluster

− For loan or loan guarantee programs, identify in the notes to the schedule the balances outstanding at year‐end

− Notes to describe the significant accounting policies used in preparing the schedule

SEFA – Section 200.510

32



Type of auditee Current (A‐133)

New (UGG)

Not low risk 50% 40%

Low risk 25% 20%

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Coverage Requirements


Tips for Preparing for Your Single Audit• Gather and summarize grant information

− Have an accurate SEFA ready for the auditor

− Know whether awards are subject to pre‒Uniform Guidance or Uniform Guidance

• Document your policies, procedures, and controls

− Documentation drives quality and compliance

• Staff working on federal programs need to be trained in Uniform Guidance

administrative requirements and cost principles

• Use resources available such as webinars, articles, etc., to verify

management stays up‐to‐date on the requirements

− Review of the OMB Compliance Supplement, contracts, etc.

− Review the Uniform Guidance FAQs

• Provides clarifications, effective dates, etc.

34



Tips for Preparing for Your Single Audit• File financial and performance reports in a timely manner

− Late reports often indicate weaknesses in grant management systems

− Late reports are red flags that may invite scrutiny

• If auditee is a Pass‐Through Entity (PTE):

− Identify all subrecipients

− Risk assessments

− Ensure subawards meet requirement

• Develop monitoring files

− Site visits

− Contracts

− Cross‐agency information

− Single audit reports

− Correspondence on issue resolution

35


Common Audit Findings

• Lack of written documentation

− UGG requires written documentation:

• Cash management

• Procurement

• Subrecipient monitoring

• Conflict of interest

• Time and effort reporting

• Travel

• Payroll time‐and‐effort reporting

− UGG includes strong emphasis on internal controls

− Review allocation methodologies for compliance

36



Common Audit Findings• Federally Purchased Capital Assets

− Tracking of capital assets required

− Documentation requirements:

• Description

• Serial number or identifying number

• Source of funding

• Title

• Acquisition date

• Cost

• % of federal participation

• Location

• Use and condition

• Disposition data

37


Common Audit Findings

• Subrecipient Contracts

−Missing required data elements in pass‐through contracts

− Lack of risk assessment process

• Risk assessment must be documented

• Annual evaluation (re‐evaluation)

• Identification of Uniform Guidance Awards

− Separate identification of pre‐ and post‐ UG awards

38



In which Uniform Guidance topic would your organization most like to see additional training?

a. Administrative Requirements

b. Cost Principles

c. Procurement

d. Subrecipient Monitoring

39

Polling Question 1


Part 2: SEA/LEA Requirements

Cindy Rhoads

UGG Coordinator, Federal Programs Division, PDE

40



• SEA Risk Analysis (200.331(b))• SEA Monitoring (200.331(d ))

• SEA Performance Reporting (200.328(1))

• Required Policies and Procedures

SEA Requirements

41


• SEA MUST evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of subrecipient monitoring.−Must occur prior to making awards

SEA Risk Analysis

42



• Prior experience with same or similar grants

• Results of previous audits− Single Audits

• Changes in personnel or substantially changed systems

• Monitoring Findings

• Any other fiscal/administrative considerations specific to a particular grant (program office discretion)

Areas of Risk to Consider

43


• Additional Technical Assistance• On‐site Reviews of Subrecipient Program Operations

• Verify every subrecipient is audited as required by Section F of UGG

Assessment of Risk Monitoring Tools

44



• Impose additional conditions to grants (200.207)

− Require payments as reimbursement rather than advanced payments

− Provide evidence of acceptable performance within a given performance period

− More detailed financial reports

− Additional project monitoring

− Requiring LEA to obtain technical or management assistance

− Establishing additional prior approvals

• Must notify subrecipient in writing of the nature, reason, action required and timeline for all additional conditions imposed.

Remedies for Noncompliance

45


• If additional conditions do not work:

− Temporarily withhold cash payment pending correction of

deficiencies

− Disallow all or part of the cost of the activity or action not in

compliance

− Wholly or partly suspend or terminate the Federal award

− Initiate suspension or debarment proceedings

− Withhold further federal awards for the project or program

− Take other remedies that are legally available

Remedies for Noncompliance

46



• SEA must monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward. Pass‐through monitoring must include:

− Review of required financial and programmatic reports

− Follow up and ensuring that the subrecipient takes action on all deficiencies found through monitoring, audits, onsite reviews or other means.

− Issue management decisions for audit findings.


47


• Major change in UGG focuses on performance rather than compliance

• Subrecipients will be required to submit a performance report for all federal grant programs (Fall 2016)

− Focus on progress toward meeting performance measures for federal grants

• If not met, why?

• Additional information required by Federal awarding agency.

Performance Goals

48



• Written Cash Management Procedure − § 200.302(b)(6) & § 200.305

• Written Allowability Procedures − § 200.302(b)(7), including Written Method for Conducting Technical Evaluations of Proposals and Selecting Recipients ‐§ 200.320(d)(3)

• Written Conflict of Interest Policy − § 200.318(c)

• Written Procurement Procedures − § 200.319(c)

• Written Travel Policy − § 200.474(b)

Required Policies/Procedures

49


• Brustein & Manasevit Templates

• Philadelphia School District Templates

• UGG Monitoring Tool

• Administrative Manual

Website: www.pafpc.org

Resources Available for Sharing by DFP

50



• DFP Regional Meetings (Fall 2016)

• Federal Programs Annual Conference−May 1‐4, 2016

− Seven Springs

−www.pafpc.org

−Onsite Technical Assistance

Additional Training

51


What written Board‐approved policies are required by the Division of Federal Program?

a. Procurement and Travel

b. Conflict of Interest and Travel

c. Allowability of Costs and Cash Management

d. Subrecipient Monitoring and Procurement

52

Polling Question 2



Part 3: Policies, Procedures, and Resources

Heather Masshardt

Policy Services Manager, PSBA

Gina L. Brillhart

CFO/Assistant to the Executive Director, IU13

53


Policy• A clear statement that sets forth the purposes and prescribes, in general terms, the organization and programs of a school system

• Creates a framework within which the staff can discharge assigned duties

• Directs the school entity’s course of action• Directs what is required for the school entity:What is required by state and federal laws, regulations and court decisions?What is necessary for legal liability?What is the directive of the Board?

Policy or Procedure?

54



Procedure or Administrative Regulation

• Tool to implement policy

• Precise statement with specific details, related to a specific issue

• Directive for staff actions

• Subject to administrative changes without Board approval

• Individual responsibilities

• Specific actions and timelines

• Step‐by‐step procedures

• District‐wide or building specific

Policy or Procedure?

55




• 626. Federal Fiscal Compliance

• 626.1. Travel Reimbursement – Federal Programs

• 827. Conflict of Interest Operations section, aligned with the Fraud policy (828)

• 808. Food Services (provided to members) Related to federal funds/procurement also

Additional updates based on USDA requirements

Administrative Regulations also provided to members

UGG Policies

57


• Costs/Obligations/Property Management

• Procurement

• Allowability of Costs

• Cash Management

• Subrecipient Monitoring

UGG Procedures

58



• Web‐based system – access policies through the system and copy into draft area to develop for your school entity Notification and access given to Superintendent/Director and Board Secretary

• Work with school solicitor, federal programs coordinator, business office to customize the policies and procedures to your school entity

• Language preceded by brackets { } indicates options you should choose or omit

• Policies require Board approval—waive second reading if necessary

*PSBA’s UGG policies and procedures are being provided to all school districts/IUs/CTCs—contact [email protected]

What to Do Next

59


Have you reviewed your food service procedures and processes with both the new UGG and USDA requirements?

a. Yes, we are getting everything updated

b. No, but we know where we need to start

c. No, we need more assistance in this area

d. I didn’t know there were any differences

60

Polling Question 3



Samples of the policies and procedures discussed today can be found on the PASBO site for this webinar.

Samples

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Note: Manual will be available April 29th.


OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

• “Uniform Grant Guidance (UGG)”

• “Uniform Guidance”

Document link:https://www.federalregister.gov/articles/2013/12/26/2013‐30465/uniform‐administrative‐requirements‐cost‐principles‐and‐audit‐requirements‐for‐federal‐awards

E‐CFR link:http://www.ecfr.gov/cgi‐bin/text‐idx?SID=851fc57edf5b684e13dc71eff5caaaaf&node=pt2.1.200&rgn=div5

FAQ link:https://cfo.gov/wp‐content/uploads/2014/08/2014‐08‐29‐Frequently‐Asked‐Questions.pdf

COFAR Agency Exceptions link:https://cfo.gov/wp‐content/uploads/2014/12/Agency‐Exceptions.pdf

Resources

62



• Uniform Guidance e‐CFR− Accessible via ecfr.gov

• Council on Financial Assistance Reform (COFAR) webpage− Accessible via cfo.gov

• Office of Management and Budget – Policy statements− Accessible via whitehouse.gov

• This includes text comparisons for cost principles and audit requirements.

• Federal Compliance Supplement− Accessible via whitehouse.gov

63

Additional Resources

• Send text questions using the “Chat” function at the left side of your screen.

• Type message in box and click “Enter” to send.

Time for Questions

64


Thank you for your participation!

REMINDER: Webcast sites are asked to have every participant sign‐in on the Attendance Form and return to the PASBO Office for attendance and credit purposes.

Forms must be received by April 26.

65

Join us for these upcoming programs:

• ELEMENTS OF SCHOOL LAW & ORGANIZATION –April 26/Kulpsville; April 28/Mars

• HOW TO NAVIGATE EMPLOYEE LEAVES –April 29/Mars; May 4/Kulpsville; May 5/Grantville

• ELEMENTS OF PURCHASING* – May 10/Harrisburg

• SUCCESSFUL ONLINE TESTING ‐May 12/Webcast

• ELEMENTS OF TRANSPORTATION* – May 17/Harrisburg

• STUDENT ACTIVITY ACCOUNTING – May 18/Webcast

• STARTING A DISTRICT FOUNDATION – May 24/Webcast

For info, visit www.pasbo.org/workshops

66


UNIFORM GRANT GUIDANCE

Webcast Recording Order Form The US Office of Management and Budget (OMB) issued comprehensive grant reform rules titled,

“Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal

Awards.” The new requirements consolidate what was previously in eight separate OMB Circulars

into a single new document. This consolidation resulted in various areas of change to the previous

requirements. These new rules are being commonly called the Uniform Grant Guidance (UGG). The

objective of this webcast is to assist participants with preparing for implementation of the

requirements of the UGG.

A recording of the webcast program will be available for download approximately one week after

the program date. Whether you use it as a review or share it with fellow employees unable to attend

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ill be mailed. Credit is a

vailable for the

live program

only, not th

e recording.

P:\W

orksho

ps\15‐16

\WEB

CASTS\Web

castAttend

ance‐CPE.doc

PASB

O W

ebcast Atten

dance Form

ALL AT

TENDEES SIGN IN

ON THIS SHEET


2015 2016 Workshop Series UNIFORM GRANT...

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