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2.1 Application Process

Application Review

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Applicant Type
Pre-Award Risk Assessment
DOJ High-Risk Grantee Designation
Audit Issues
Verification of Taxpayer Identification Number
Review of Applicant Federal Debt
Confirmation of Dun & Bradstreet Data Universal Numbering System Number
Confirmation of Listing in System for Award Management

DOJ awarding agencies are required to ensure that awards meet certain legislative, regulatory, and administrative requirements. This requires that each DOJ awarding agency review and assess each application to determine the following:

  • The applicant is eligible for the specified program.
  • The costs and activities in the application are for allowable, allocable, necessary, and reasonable costs.
  • The applicant possesses the responsibility, financial management, fiscal integrity, and financial capability to administer Federal funds adequately and appropriately.

Applicant Type

Examples of types of applicants include, but are not limited to:

  • Nonprofit organization – Some DOJ programs may require that an organization have 501(c)(3) status (as described in the U.S. Internal Revenue Code)
  • For-profit organization (including organizations designated as small businesses)
  • State
  • Unit of local government
  • Tribe
  • Institution of higher education
  • Courts
  • Individuals (in limited circumstances)

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Pre-Award Risk Assessment

DOJ is required to review and assess the potential risks presented by applicants for Federal grants prior to making an award (2 C.F.R. § 200.205). DOJ will use a variety of factors which may include financial capabilities and past performance in a risk-based approach. To facilitate part of the risk assessment, all DOJ applications (other than an individual) are required to complete a questionnaire to assess their financial capability and submit it to DOJ before they can be approved for an award.

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DOJ High-Risk Grantee Designation

The DOJ’s High-Risk Grantee Designation Policy was formally approved on January 6, 2012, and was adopted by its three primary grant-making components:  the Office of Justice Programs (OJP), the Office of Community Oriented Policing Services (COPS), and the Office on Violence Against Women (OVW). OJP’s Office of Audit, Assessment, and Management (OAAM) is charged with administering the high-risk grantee process on behalf of DOJ. When an applicant is designated as high-risk by the OAAM, all DOJ grant-making components must consider the applicant as high-risk.

The purpose of the high-risk policy is to provide DOJ with a means of continuing to fund much needed criminal justice programs benefiting communities across the U.S., while maintaining proper stewardship of Federal funds and mitigating risk in the administration of DOJ-funded grant programs. It is important to note that high-risk grantees are not prohibited from applying for or receiving new awards from DOJ. However, high-risk grantees are managed and monitored closely, and any new awards these grantees receive are subject to additional restrictions, typically imposed through the inclusion of high-risk special conditions. Such conditions may be imposed not just at the beginning of a grant, but at any time throughout the period of the grant, if appropriate.

In general, a recipient may be designated as high-risk if any of the following apply to the recipient:

Under DOJ’s policy, recipients may be designated as high-risk automatically, or as a result of a referral to OAAM from sources such as a DOJ grant-making component or other federal grant-making organization.

  • High-risk referrals can be made by any DOJ personnel who works with grants, and can result from a wide variety of reasons, including, but not limited to:
    • issues identified during grant programmatic or financial monitoring reviews, budget reviews, financial capability reviews, etc.;
    • concerns noted during the routine administration of grants;
    • audits/investigative issues;
    • complaints by recipient personnel, third parties, and/or the media, etc.
  • Automatic high-risk designations are made by DOJ if any of the following conditions apply:
    • Recipient has audit reports with recommendation(s) that have been open for more than one year, and has not submitted documentation adequate to close the recommendation(s).
    • Recipient has not provided a corrective action plan to the DOJ within 105 days of transmission of the audit report to the recipient.
    • Recipient has audit reports with questioned costs in excess of $500,000 (regardless of the amount of time the audit report has been open).
    • Recipient has been referred to the Department of Treasury for collection because of their failure to timely repay funds owed on a DOJ award.
    • Recipient has been placed on the COPS Restricted Grantees List due to non-compliance with a previous COPS award(s).
    • Recipient has been recommended for government-wide suspension or debarment by a DOJ office or component.

If high-risk grantees do not comply with the additional conditions/restrictions imposed, or fail to make timely progress in addressing the issues that resulted in their high-risk designation, DOJ can consider more substantial sanctions, such as:  freezing funds on current DOJ awards; termination of existing awards; barring the grantee from receiving future DOJ grants; and/or recommending the grantee for (non-procurement) government-wide suspension or debarment.

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Audit Issues

  • DOJ may choose not to approve an applicant for an award if the applicant has an overdue audit report, an open audit report that has not been responded to, or if the applicant has not tried to resolve the issues identified in the audit.
  • Failure to comply with audit requirements may cause an application to be rejected, or funds to be withheld until audit compliance is achieved.

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Verification of Taxpayer Identification Number

  • DOJ may verify the employer identification number (EIN) provided on the application.
  • DOJ may assign a vendor number very similar to the recipient's EIN. This is done to ensure that a sub-agency within a governmental organization which receives awards directly will have a separate identifier from that of the parent agency.
  • For example, a State government has any EIN that is 123456777. A police department within the State applies for and receives an award from DOJ. Since the EIN is the same, a DOJ vendor number of 123456778 will be assigned in order to make the police department as a sub-agency within that State government.

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Review of Applicant Federal Debt

The SF-424 asks if the applicant is delinquent on any Federal debt.

  • The applicant is the organization that is requesting Federal assistance, not the person who signs the application as the authorized representative of the organization.
  • Federal debt includes delinquent audit disallowances, loans, taxes, and any outstanding debts with the Treasury.

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Confirmation of Dun & Bradstreet Data Universal Numbering System Number

All recipients must have a Data Universal Numbering System (DUNS) number when applying for Federal awards and cooperative agreements (initial or supplemental awards) (2 C.F.R. Part 25 - Universal Identifier and System of Award Management).  

  • An organization can obtain a DUNS number at no cost by calling the toll-free DUNS number request line at 1-866-705-5711.
  • Individuals who apply for grant awards or cooperative agreements from the Federal Government are exempt from this requirement.

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Confirmation of Listing in System for Award Management

The System for Award Management (SAM) is the Official U.S. Government system that consolidated the capabilities of the Central Contractor Registration (CCR), Federal Agency Registration (FedReg), the Online Representations and Certifications Application (ORCA), and the Excluded Parties List System (EPLS). It became operational in August 2012. Recipients must have registered their DUNS in https://www.sam.gov/portal/SAM/ in order to receive an award.

  • SAM collects, validates, stores, and disseminates data on organizations to help agencies in their acquisition missions, including Federal agency contract and assistance awards. The term “assistance awards” includes grants, cooperative agreements, and other forms of Federal assistance.
  • SAM registrations must be updated or renewed at least once per year to maintain an active status. SAM will send notifications to the registered user via email 60, 30, and 15 days prior to the expiration of the record.
  • It takes 2 to 3 days for SAM to complete record updates. Notification will be made via email when the process is complete and the record is active in SAM.
  • If an organization is new to doing business with the Federal Government, the initial registration in SAM takes up to 5 days to become active. Registration with SAM requires a DUNS number and the entity’s Tax ID number (TIN).
  • Organizations must maintain an “active” registration in https://www.sam.gov/portal/SAM/ for the entire period of the award.

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