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 mcasanova@capcog.org (512) 916-6163 • Erica Linneman, Criminal Justice Planner elinneman@capcog.org (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 name@governor.state.tx.us) • 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 egrants@governor.state.tx. 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