The Impact of OMB Circulars (Super or Otherwise) on Federal Programs. Michael Brustein, Esq. [email protected] Brustein & Manasevit, PLLC Fall Forum 2012. What are “circulars”? Do they matter? Where do they stand in the legal hierarchy?. Administrative Principles.
Michael Brustein, Esq.
Brustein & Manasevit, PLLC
Fall Forum 2012
What will be the effective date of changes?
But allows for disparate treatment depending on type of entity
(look to Compliance Supplement)
Increasing threshold would increase burden on SEA for monitoring and Limited Scope Audits
*OIG and A-133 Single Audit
5 year statute of limitations
(See Appendix to 34 CFR Part 81)
The Tydings Cases
Disclaimer lack merit
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