Transcript How to Successfully Manage CJD Grants

Step 1. Know the Basics
Step 2. Understand Grants Monitoring
Step 3. Properly Close Out the Grant
Step 4. Follow the Rules and Regulations
Step 5. Use Sample Forms
 Email is Preferred
([email protected])
 Include Grant Number in all
Correspondence
 CJD Main Number
(512) 463-1919
 Notify CJD Immediately If You
Get a Public Information
Request
Appointed or
authorized by
the governing
body.
Must be the
chief financial
officer for the
grantee
agency.
Responsible for
the day-to-day
operations of
the project
including
programmatic
reporting.
Failure to accept
your award
within 45 days
could result in
forfeiture of grant
funding.
Project Not Operational Within 60 Day
• Grantee must report to CJD the steps taken to
initiate the project, the reasons for delay, and
the expected revised start date.
Project Not Operational Within 90 Day
• Grantee must submit a statement to CJD
explaining the delay.
• CJD may cancel the project or extend the
implementation date past the 90-day period.
All funds must be paid through direct
deposit.
Texas Application for Payee Identification Number
–
http://www.window.state.tx.us/taxinfo/taxforms/
ap-152.pdf
Vendor Direct Deposit Authorization Form –
http://www.window.state.us/taxinfo/taxforms/74
-176.pdf
Internal Revenue Service Form W-9 http://www.irs.gov/pub/irspdf/fw9.pdf?portlet=3
Quarterly or Monthly Submissions
Must Report Cumulative Expenses
Reimbursement Basis
Calendar Quarter
Due Date
January 1 – March 31
April 22
April 1 – June 30
July 22
July 1 – September 30
October 22
October 1 – December 31
January 22
IMPORTANT CHANGE
All grants awarded with Recovery Act funds
must submit MONTHLY Financial Status Reports.
DUE DATE: 5th
Day of the
following
month
Example: Reporting Period of
5/31/09 (Cumulative Expenditures
through 5/31/09) – Report must be
submitted by 6/5/09.
 All Financial Status Reports must be
submitted through eGrants.
 For a step by step guide to creating and
submitting FSRs see the eGrants
Financial Management Guide.
Final date to
report
expenditures
Default
liquidation
date is - 90
calendar days
after the grant
ends
Expenditures
not reported to
CJD by the
liquidation date
will result in a
loss of funds for
the project
 Required by CJD
 Collected by Texas A&M Public
Policy Research Institute (PPRI)
 Reporting packets include:
• instructions for accessing the PPRI website
http://cjd3.tamu.edu/
• user name/log-in and password
• number and types of reports required for
the applicable fund source
All payments to an agency for all
grant funded projects will be held.
Reasons for vendor hold include:
•
•
•
•
•
Delinquent programmatic progress reports
Delinquent financial status reports
Delinquent single audit reports
Unresolved monitoring findings
Non-Compliance with State or Federal rules and
regulations
Must be submitted through eGrants and Certified by the
Authorized Official
Grant Officials or
Address Changes
Programmatic
Changes
Grant Adjustment Types
Budget Changes
Grant Period
Extensions
10% of Cumulative Expenditures can be moved without CJD’s Prior
Approval (except within Equipment and Indirect Costs)
Notify CJD within 20 Days of Changes
to Grant Officials or Address Changes
Changes to existing grant officials
Add new grant officials
Agency or project address changes
Types of Programmatic Adjustments
Changes to the Project Narrative
New or different Project Activities
Changes to the Performance Measures
New or different Population or Geographic Area
Changes to the Agency Name or Project Title
New or different Vendor/Payment Information
Types of Budget Adjustments
Increase CJD Funds (Supplemental)
Decrease CJD Funds (De-obligation)
Add or Change Line Items (no change in total award)
Reconciliation Adjustment
Monitoring Findings
Generated Program Income (GPI)
Grant Period Extensions
Handled on a Case-by-Case Basis
Must be Received Prior to the End of the Grant Period
Grant Period for Project CANNOT overlap the Start Date for
Continuation Funding
Detailed Explanation Required including the Benefit to the
Project’s Purpose
Personnel
Equipment
Contractual /
Professional
Services
Supplies and
DOEs
Travel
Construction
Indirect Costs
 Time/Activity Reports
 Case Numbers for Grant-Funded Law Enforcement
and Prosecution Personnel
 Volunteer Activities
 Signed Timesheet
 Salaries Consistent with Local Policy
 Backfill of Existing Positions
 Overtime
Contractual and
Professional




Contracts in Writing
Consistent with Texas Contract Law
Contract Monitoring Documentation
Compliance with Agency Procurement
Guidelines
 Invoices for Contract Deliverables
 CJD-Prescribed Procurement Questionnaire
Travel
 Employee Travel and Training Only
 Comply with Agency Travel Policies or
State Travel Policies
 Maintain Travel Log and Travel Receipts
 Pre-Approval of Out-of-State Travel
NOTE: Expenses for Outside Trainers go under
the Contractual Budget Category .
Equipment
 All purchases MUST be pre-approved by CJD
 Must maintain Inventory
 Procurement Questionnaire for purchases in Excess
of $100,000
 Must have invoices to support purchases
 Must be used for the purpose for which it is
purchased
 All changes to Equipment Line Items (including the
number of items) MUST be approved by CJD
Construction
•This budget category is
currently unavailable for
CJD funded projects.
Supplies & Direct
Operating Expenses
 Related to the daily operation of the CJD grant
 All costs MUST be Pro-Rated
 Rent or Lease MUST include cost/sq. ft. and
the number of square feet
 Documentation (ex. receipts, invoices) MUST
be maintained
 Includes small equipment
Indirect Costs
 When allowed, the standard rate is 2% of CJDfunded direct costs (NOTE: this is NOT the
CJD Award Amount)
 Cognizant agency approval letter required for
requests in excess of 2%
 ALL rates are negotiable
Matching Funds
 Cash or In-Kind
 Held to Percentage in Approved Budget
 Federal Funds CANNOT be used to meet match
requirements
Grants Monitoring Overview
Reviewing & Testing
Recurring Findings
Technical Assistance
Questions & Answers
What is grants monitoring?
“The process of reviewing grant
documentation to ensure that grant
funds are used for authorized
purposes.”
 Desk reviews
 Site reviews
 Grantee contact visits (informal)
 1st year COG Checklist Analyses (site
reviews and phone contact)
 Perform a risk assessment of grantees.
 Develop a monitoring schedule for the year.
 Carry-out monitoring schedule (Plan our
work & work our plan.)
Monitoring schedules are subject to change.
In most instances, we provide a 2 week advance
notice of the reviews to grantees and COG planners.
 Funding: The more money awarded, the
higher the risk of misspent funds ($10,000
vs. $1,000,000).
 No. of grants: The greater the number of
grants awarded, the higher the exposure
to non-compliance of requirements. (1
grant vs. 7 grants)
 Based on risk factors, grantees are assigned a
risk rank: high risk, medium risk, or low risk.
 A Monitoring Plan is developed from the
risk assessment report.
 Grantees in each level (high risk,
medium risk, low risk) are reviewed.
 Grantees are scheduled for review on a
rotation basis.
 Notify grantee of upcoming desk review.
 Gather and analyze grant documents
from the grantee.
 Call grantee and conduct a phone
interview regarding issues noted.
 Complete examination and issue a report.
 Follow-up with grantee on issues.
 Site reviews are scheduled with the grantees. Dates, times,
and locations are set.
 A notification letter is sent to the grantee. It includes a list of
documents to be examined.
 Reviews are conducted at the grantee’s office. Reviews may
last from 2 to 5 days, depending on the size and
complexity of the grant.
 Monitors continue the analysis of support documentation and
calculating of expenses, back at CJD.
 Written reports of the review are prepared and submitted to
grantees for response.
 Entrance conference.
 Examine documents, select samples, test
transactions, discuss issues with
grantees. Make copies for analysis
later. (Monitors time is very limited
while on-site.)
 Exit conference.
 General Grant Administration: FSR, program income, Single Audit
 Personnel: payroll, personnel activity reports, timesheets
 Contractual Services: contracts, contract monitoring, procurement
questionnaire
 Travel: invoices, receipts, training certificates
 Equipment Inventory: inventory list, physical observation,
procurement questionnaire
 Construction: pre-approval, change orders
 Supplies: invoices, receipts
 Indirect Costs: 2% limit, cost allocation plan
 In-Kind or Cash Match: what is used as match, how much has been
provided, volunteer timesheets
 Program Issues: specific to the unique program, program records
 Monitors continue to examine and analyze
documents back at the CJD office.
 The further analysis of the grantee’s documents
may result in additional findings. If this occurs,
the grantee will be contacted to discuss the
finding and may be able to clear the issue with
supplemental documentation or information.
 All findings will be presented in the report and
the grantee will have an opportunity to respond.
 Issue Draft report (includes requirements, findings, and
recommendations). Grantee has 15 days to respond
with corrective action.
 Receive grantee responses & corrective action.
 Analyze responses. Issue Second draft report, if necessary.
Reports will include the grantee’s responses.
 Receive grantee responses & corrective action
 Analyze responses. Issue Final report.
 (If necessary) Receive grantee responses and corrective
action.
 Issue Closeout letter. Review is complete.
 Single Audit issues
 FSR/PPRI reports submitted late
 Program Income not reported (from
seizures, forfeitures, other)
 Time sheets lack employee’s
or supervisor’s (or both)
signatures.
 Actual activity not
documented.
 Volunteers’ time not
documented same as
grant-funded employees.
 Overtime paid, without prior
CJD approval, or not
following approved
Overtime Policy.
 Procurement Questionnaire for contract
exceeding $100,000 not completed
and submitted to CJD.
 No written contract(s) for Contractual expenses.
 Grantee did not monitor (or have evidence of
monitoring) the contract. No contract monitoring
tool was used to document the grantee’s
oversight of the contract.
 Documentation of procurement not maintained.
 Requisition or voucher documents not
completed.
 Support documents (receipts, invoices, etc.)
not available.
 Purchase of unallowable items (gifts, alcoholic
beverages).
Procurement Questionnaire for purchases
exceeding $100,000 not completed
and submitted to CJD.
Incomplete/non-existent inventory list.
 Grant–purchased items not identified on the inventory
list.
 Equipment items not properly tagged.
 No procurement policy; competitive procurement
documents not maintained.
 Not pre-approved. Using grant funds
for construction must be preapproved by CJD.
 Non-essential operating expenses (snacks/
coffee/creamer/paper towels/etc.)
were purchased with grant funds.
 Prohibited items (i.e. advertisements,
gifts, fundraising expenses, admissions
to sporting events /amusement
parks/recreation) were purchased with
grant funds.
 Commingling of funds: Grant funds have been
commingled with other funds. (Requirement: Each
grant award must be accounted for separately.)
 Irreconcilable accounts: CJD Financial Status Report
does not reconcile to general ledger expenditures.
(Requirement: Grant expenditures need to
reconcile to GL expenditures.)
 Inability to trace expenditures: The source and
application of funds can not be
traced to the general ledgers.
(Requirement: Expenditures
need to be traceable to the GL.)
 Monitors provide technical assistance to the
grantees while on site (or over the phone,
if it is a desk review).
 This includes explaining governing directives
and discussing possible recommended
actions for compliance.
 Monitors may also provide samples of
documents to assist the grantee with
compliance, such as sample personnel
activity reports.
 Informal stop-in visits with grantees in the same geographic area
where we are doing site reviews
 Carried out if the monitor has time to stop-in; if the schedule is
too tight, the monitor will forgo the visit
 Monitor asks for the project director, talks to him/her about the
grant, and asks if there are any questions about the grant
 If time allows, grantee may offer a brief tour of the facility
 Visit usually lasts about 30 minutes or less
 No documentation is requested; although grantees may provide a
brochure or a business card
 Allows for CJD to more efficiently use state travel funds and for
CJD to make contact with more grantees out in the field.
 Completed by COG planner during site visit (or if a JAG Recovery
grant, then possibly phone contact form instead)
 Also, referred to in our Notification Letters to grantees before
reviews, for their use
 Purpose: Identifies grantee’s compliance issues
 Completed checklists are forwarded by planners through
eGrants to CJD
 Issues analyzed by CJD Grants Monitoring
 CJD may follow-up with a monitoring review
 (In-depth training sessions on the checklists & phone contact
form, tomorrow)
 Technical Assistance Checklist available at:
https://cjdonline.governor.state.tx.us
Then go to Updates, then Grants Monitoring Tools, then Checklist
(and Coversheet and Phone Contact Form for the COG
planners.)
 Examples of governing directives can be found on the link to
Grants Resources on eGrants, including:
– Guide to Grants
– Texas Administrative Code (TAC)
– Uniform Grant Management Standards (UGMS)
– Office of Justice Programs Financial Guide
– Financial Management Guide
Step 3.
Properly Close
Out the Grant
Final FSR
Final Progress
Report
Expend all GPI
Request Disposition of
Equipment
Step 4. Follow the
Rules and Regulations
• Office of Justice Programs (OJP) Financial Guide
http://www.ojp.usdoj.gov/financialguide/
• Education Department General Administrative Regulations (EDGAR)
http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
• Office of Management Budget (OMB) Circulars
http://www.whitehouse.gov/omb/circulars_default/
– A-21: Cost Principles for Educational Institutions
– A-87: Cost Principles for State, Local and Indian Tribal Governments
– A-102: Grants and Cooperative Agreements With State and Local
Governments
– A-122: Cost Principles for Non-Profit Organizations
– A-133: Audits of States, Local Governments, and Non-Profit
Organizations
• Fund Specific Guidelines
• Uniform Grants Management Standards (UGMS)
http://governor.state.tx.us/grants/what/
• Texas Administrative Code (TAC)
https://cjdonline.governor.state.tx.us/updates.aspx
• CJD’s Guide to Grants
https://cjdonline.governor.state.tx.us/updates.aspx
NOTE: CJD awards grants with both State and Federal funds. Use this
Matrix to figure out if your grant is awarded with State or Federal
funds. Sources highlighted in Yellow are prioritized by the COGs.
Fund Source
CD-Coverdell Nat'l Forensic Sciences Improve Act
DJ-Edward Byrne Memorial Justice Assistance Grant Program
ED-Safe and Drug-Free Schools and Communities State Grants
JA-Juvenile Justice and Delinquency Prevention Act
JB-Juvenile Accountability Incentive Block Grants
JT-Title V Delinquency Prevention Program
RT-Residential Substance Abuse Treatment for State Prisoners
VA-Victims of Crime Act, Victim Assistance Program
WF-STOP Violence Against Women Formula Grants
BVP-Bulletproof Vest Partnership
SCAAP-State Criminal Alien Assistance Program
DNA-Post-conviction DNA Testing Assistance Program
CE-County Essentials Program
CG-Operator and Chauffeurs Funding-Gangs
CH-Operator and Chauffeurs Funding-Prosecution
CR-Crime Stoppers Assistance Fund
DC-Drug Court Program
SF-State Criminal Justice Planning (421) Fund
Federal
X
X
X
X
X
X
X
X
X
X
X
X
State
X
X
X
X
X
X
STEP 5
Use Sample Forms
Time Sheets/Personnel Activity Logs – Blank
Time Sheets/Personnel Activity Logs –
Requirements
Post-Award Procurement Questionnaire
Resolution
Technical Assistance Checklist