Transcript How to Successfully Manage CJD Grants

Conducted by
Michelle Casanova,
Assistant Director, Community and Economic Development
Erica Linneman
Criminal Justice Planner
• CAPCOG Contacts
• CJD Contacts
• New CJD Training Requirements
Recurring Findings
• Michelle Casanova,
Assistant Director, Community
and Economic Development
[email protected]
(512) 916-6163
• Erica Linneman,
Criminal Justice Planner
[email protected]
(512) 916-6047
• Include Grant Number
and Project Name in all
Correspondence
• Mailing Address:
6800 Burleson Road
Building 310, Suite 165
Austin, TX 78744
• CAPCOG Website:
www.capcog.org
Governor’s Office, CJD
• Email is preferred
(first name.last
[email protected])
• CJD Main Number:
(512) 463-1919
• CJD Fax Number:
(512) 475-2440
• Include Grant Number
in all Correspondence
• eGrants Home Page
https://cjdonline.governor.
state.tx.us
• Email Address for
eGrants Help Desk
[email protected].
us
New CJD Training Requirements
Recurring CJD Grant Management Findings
 Single Audit issues
 FSR/PPRI reports submitted late
 Program Income not reported (from
seizures, forfeitures, other)
Recurring CJD Grant Management Findings
 Time sheets lack employee’s or supervisor’s (or
both) signatures.
 Actual activity not documented.
 Volunteers’ time not documented same as grantfunded employees.
 Overtime paid, without prior CJD approval, or not
following approved Overtime Policy.
Recurring CJD Grant Management Findings
 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.
Recurring CJD Grant Management Findings
 Requisition or voucher documents not
completed.
 Support documents (receipts, invoices, etc.)
not available.
 Purchase of unallowable items (gifts, alcoholic
beverages).
Recurring CJD Grant Management Findings
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.
Recurring CJD Grant Management Findings
 At this time, construction costs are
not an allowable line item for grants
through CJD.
Recurring CJD Grant Management Findings
 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.
Recurring CJD Grant Management Findings
 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.)
Applications for funding through the following fund sources
are reviewed by the CAPCOG Criminal Justice Advisory
Committee (CJAC)
• Violence Against Women Act – Recovery Solicitation
• General Victim Assistance – Direct Services Solicitation
• Violent Crimes Against Women Criminal Justice and Training
Projects – Domestic Violence, Sexual Assault, Dating Violence
and Stalking Solicitation
• Juvenile Services Solicitation
• Criminal Justice Programs Solicitation
• Appointed/authorized by the governing body of the
organization.
• Authorized to apply for, accept, reject, alter, or
terminate the grant.
• Generally the county judge, mayor, city manager,
chair of non-profit, etc.
• Has ability to complete and submit Financial Status
Reports (FSR).
• Required to be the chief financial officer for the
grantee agency.
• Responsible for maintaining financial records to
account for all grant funds.
• Responsible for requesting funds and the completion
of required financial reporting at least quarterly in
eGrants.
• Responsible for day-to-day operations of project.
• May have a different Project Director per agency
grant.
• Must be an employee of the grantee agency.
• Responsible for required programmatic reporting.
• The AO, FO, and PD will receive an
email from eGrants announcing the
award
• The AO must log into eGrants and go
to the “Accept Award” tab to
preview the Statement of Grant
Award
• Preview and Print out Award Letter
– Read Award Letter Carefully
• Conditions of Funding and Other FundSpecific Requirements
• Due dates and contractual obligations
– Follow your internal processes, then
have AO accept award.
REMEMBER: Your Grant
Application is the basis of your
contract with CJD, so print out the
CJD-approved grant application
and use it as your program
implementation guide.
Failure to accept
your award
within 45 days
could result in
forfeiture of grant
funding.
• Review the CJD Grantee Personnel Activity Report
Timesheet Requirements
• Increase your Fidelity Bond coverage
• Review and finalize processes for collecting and tracking
data for programmatic reporting
• Look for an email from Texas A&M (Public Policy Research
Institute, PPRI) with your programmatic reporting
information (make sure you receive the correct reports for
your grants’ fund source)
– This information will only be emailed to the AO, FO, PD
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.
• 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 (See Texas Administrative Code)
• 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
NOTE: Your grant must be
accepted and activated BEFORE
you request an adjustment or FSR
 All Financial Status Reports (FSR)
must be submitted through eGrants.
 For a step by step guide to creating
and submitting FSRs see the eGrants
Financial Management Guide.
All funds from CJD are paid to the Grantee
through direct deposit on a reimbursement basis.
Texas Application for Payee Identification Number
http://www.window.state.tx.us/taxinfo/taxforms/a
p-152.pdf
Vendor Direct Deposit Authorization Form
http://www.window.state.us/taxinfo/taxforms/74176.pdf
Internal Revenue Service Form W-9
http://www.irs.gov/pub/irs-pdf/fw9.pdf?portlet=3
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
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 per a Cost
Allocation Plan
 Rent or Lease MUST include cost/sq. ft. and
the number of square feet
 Documentation (ex. receipts, invoices) MUST
be maintained
 Includes small equipment with a useful life of
less than one year and a purchase price of $999
or less per unit
Indirect Costs
 When allowed, the standard rate is 2% of
CJD - funded direct costs (NOTE: to compute
this, divide the amount you are applying for
by 1.02 to calculate 2% of Direct Costs)
 Cognizant agency approval letter required
for requests in excess of 2%
Matching Funds
 Do not include a match on a grant if one is not
required
When required, a match can be cash or in-kind
 Held to Percentage in Approved Budget
 Federal Funds CANNOT be used to meet match
requirements
NOTE: All adjustments are requested and submitted through
eGrants. Extensions, increases, or decreases must be Certified by
the Authorized Official and submitted through eGrants
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
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
Final FSR
Final Progress
Report
Expend all GPI
Request Disposition of
Equipment
• There are two types of reporting
required for CJD grants :
• Programmatic
• Financial
 Required by CJD
 Collected by Texas A&M Public
Policy Research Institute (PPRI)
 Reporting packets include:
• instructions for accessing the PPRI website
http://cjd.tamu.edu/
• user name/log-in and password
• number and types of reports required for
the applicable fund source
Mandatory
Quarterly Due Dates
• Quarterly or Monthly
Submissions
• January 1 - March31
APRIL 22
• April 1 – June 30
• Must Report
Cumulative Expenses
• Reimbursement Basis
JULY 22
• July 1 – September 30
OCTOBER 22
• October 1 – December 31
JANUARY 22
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
NOTE: Placement on Vendor Hold will also result in
a points deduction on the grantee’s next CJACreviewed application.
 CJD Technical Assistance:
Provided to the grantees while on site (or over
the phone, if it is a desk review).
Includes explaining governing directives and
discussing possible recommended actions for
compliance.
CJD Monitoring:
Desk reviews
 Site reviews
 Grantee contact visits (informal)
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, CJD provides 2 weeks 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)
 Risk Rank: Based on risk factors, grantees are
ranked: 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.
CAPCOG Technical Assistance:
Grant workshop and grant management
training.
Grant application assistance and preview.
CJD Monitoring:
1st year COG Checklist Analyses (site
reviews and phone contact)

 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: Not Applicable
 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
 Fund-Specific Program Issues: specific to the unique program, program
records
 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