COVID Flexibilities and How to Avoid Audit Findings

Bonnie Little Graham joined Brustein & Manasevit, PLLC in 2009. Ms. Graham actively represents federal education grantees and subgrantees in the resolution of adverse audit and program review determinations, false claims act investigations, and other administrative legal actions. Ms. Graham has successfully resolved significant audit findings for her clients through administrative appeal proceedings, as well as through settlement negotiations and cooperative audit resolution techniques. Ms. Graham also works closely with clients on issues pertaining to “high risk” grantee and subgrantee designations, and on cost allocation matters, including indirect cost rate development, negotiation, and application.

Ms. Graham regularly assists her clients with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and other administrative statutes and regulations, such as the General Education Provisions Act (GEPA) and the Education Department General Administrative Regulations (EDGAR), providing workshops and trainings, developing compliant policies and procedures, and reviewing contracts and other grant-related documentation for compliance with federal requirements. Ms. Graham also works with clients on the requirements of the Individuals with Disabilities Education Act (IDEA), the Elementary and Secondary Education Act (ESEA), and Title IV of the Higher Education Act, conducting mock-reviews of program implementation and advising on federal requirements, best practices and allowable flexibilities.

Ms. Graham lives in Alameda, California. Prior to joining the firm, Ms. Graham worked as an associate at a corporate firm in Charlotte, North Carolina.

Tiffany Winters Kesslar joined Brustein & Manasevit, PLLC in July 2006. Ms. Kesslar represents clients regarding Federal grants management compliance and assists her clients with both fiscal and programmatic aspects of federal education programs, including the Every Student Succeeds Act (ESSA), amending the Elementary and Secondary Education Act (ESEA), and the Individuals with Disabilities Education Act (IDEA). Ms. Kesslar also actively represents clients in the resolution of adverse audit findings and compliance under the Office of Management and Budget’s Uniform Grants Guidance (UGG) and other federal administrative regulations, such as the General Education Provisions Act (GEPA) and the Education Department General Administrative Regulations (EDGAR).

Ms. Kesslar regularly serves as a keynote speaker on federal education grants compliance. Ms. Kesslar has developed and conducted trainings, webinars, and audio conferences on federal grants management and the fiscal and programmatic requirements of various federal programs. Ms. Kesslar also conducts mock monitoring and internal control reviews of State agencies, local educational agencies, institutions of higher education and nonprofits for fiscal and programmatic compliance with federal administrative requirements. Additionally, Ms. Kesslar serves on the Board of Directors for the National Grants Management Association.

Prior to joining the firm, Ms. Kesslar served as a law clerk at the Superior Court of the District of Columbia. Ms. Kesslar graduated cum laude from Clemson University and received her Juris Doctorate from the Catholic University Columbus School of Law. Ms. Kesslar is a member of the U.S. Supreme Court bar and the District of Columbia bar.