Indirect Cost FAQs

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.

Aaron Kramer Brosnan joined Brustein & Manasevit, PLLC in July 2019. Mr. Brosnan assists clients with federal grants management and various education programs, including the Individuals with Disabilities Education Act, Strengthening Career and Technical Education for the 21st Century Act, the Workforce Innovation and Opportunity Act, and the Every Student Succeeds Act. Mr. Brosnan also works with clients on compliance with the rules and regulations under the Uniform Grant Guidance, as adopted by the Education Department General Administrative Regulations.

Prior to joining the firm, Mr. Brosnan worked for the Office of the State Superintendent of Education (OSSE) on special education compliance matters. During law school, Mr. Brosnan interned with the Office of Hearings and Appeals at the US Department of Education and with the National School Boards Association. Prior to law school, Mr. Brosnan worked for the Landmark School in Massachusetts as a special education teacher and reading specialist.

Mr. Brosnan received his Bachelor's Degree in Biology and Studio Art from the College of the Holy Cross in 2010 and his Master's Degree in Special Education from Simmons College in 2014. Mr. Brosnan received his Juris Doctor from the George Washington University Law School in 2015. Mr. Brosnan is a member of the District of Columbia Bar.