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 (firstname.lastname@governor.state.tx.us) 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 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://cjd.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, CJD will 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. 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 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 Technical Assistance Checklist available at: https://cjdonline.governor.state.tx.us Then go to Updates, then Grants Monitoring Tools, then Checklist. 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