You can find the eligibility requirements for block, formula, and discretionary awards in the grant program guidelines.

• Block and formula awards: Generally, States, territories, and sometimes Indian tribes and local units of government are eligible for awards under OJP's various block and formula grant programs. Specific eligibility criteria for each program is set forth in the program's governing statute and rules.
• Discretionary awards: OJP may award funds under its discretionary grant programs to some or all of the following types of recipients, depending on authorizing legislations and selected program strategies:  States, units of local government, Indian tribes and tribal organizations, individuals, educational institutions, hospitals, and private nonprofit and private commercial organizations.

For programmatic and technical requirements relating to block and formula award applications, contact OJP or the awarding agency to request program guidelines.

OJP or the awarding agency will announce in the Federal Register, Grants.gov, and/or the Grants Management System (GMS) any programs that they have developed for funding under their discretionary programs. Additionally, OJP funding opportunities are posted on the OJP website at https://www.ojp.gov/funding/explore/current-funding-opportunities, as well as OJP bureau and program office websites. You can also find a collection of available assistance programs in the Catalog of Federal Domestic Assistance published by the U.S. General Services Administration.

As an applicant, you must assure and certify that you are in compliance with all applicable civil rights nondiscrimination requirements that are prescribed on the OJP Assurances Form 4000/3 (attached to the Application for Federal Assistance Standard Form 424 [SF-424]). You must assure that your subrecipients are in compliance as well.

Additional responsibility in the event of a finding of discrimination:

• This responsibility will apply to you if you are a recipient of Federal funds and a Federal or State court or administrative agency finds through a due process hearing that you have, or a subrecipient or a contractor has, discriminated on the grounds of race, color, national origin, sex, or disability.
• If these conditions apply, then you need to forward a copy of the hearing findings to the OJP Office for Civil Rights (OCR).

If you are a recipient of Federal funds and your award is $500,000 or more, you must submit an Equal Employment Opportunity Plan to OCR. Your subrecipients are required to submit one as well if they receive $500,000 or more in Federal funds.

Intergovernmental review is a process issued under Executive Order 12372 [PDF - 12 KB] to review Federal programs and activities. Additional information is available at https://obamawhitehouse.archives.gov/omb/grants_spoc.

• If your State has established a process for intergovernmental review and the program that you are applying for is selected for review, then you must submit a copy of your application to the State's single point of contact for intergovernmental review prior to or at the same time that you submit your application to OJP or the awarding agency.
• If you need any additional information regarding this requirement, please check https://obamawhitehouse.archives.gov/omb/grants_spoc.

Applicants for OJP funding (or funding through other Department of Justice components that follow this Financial Guide) submit applications online through either the federal grants portal Grants.Gov (www.grants.gov) or the Department of Justice's Grants Management System (GMS) (http://www.grants.gov/web/grants/home.html). Each program solicitation will specify which system should be used for that program, and will contain detailed technical instructions on how to register with the system and apply for funding. Applicants for formula/block funding, earmarked funding, and continuation funding, are generally required to register and create a profile in GMS. Applicants for competitive funding are generally required to register in Grants.Gov. It is best to register well in advance of the application deadline, as processing registration into these systems may take some time (in most cases, approximately one week).

Most OJP discretionary solicitations require, at a minimum, a number of elements. These generally include the Standard Form (SF) 424 (Application for Federal Assistance), a program narrative, budget detail worksheet and budget narrative. There are also a number of certifications that may be required, and other elements as specified in the program solicitation.

• Note regarding SF424 question regarding determination of applicant type: Applicants must specify what type of entity they are on the SF424. Generally, applicants for OJP grants are one of the following types of entities: States, units of local government, Indian tribes or units of tribal government, not-for-profit organizations, for-profit organizations, educational institutions, and (in limited circumstances) individuals. It is possible to select other applicant types as well, as appropriate.
• Note regarding SF424 question regarding delinquency on Federal debt: The question on the SF 424 applies to  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.

OJP or the awarding agency is required to ensure that awards meet certain legislative, regulatory, and administrative requirements. This policy requires that OJP or other awarding agency makes sure of 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:

• An individual
• Not-for-profit organization
• For-profit organization
• State
• Local unit of government
• Tribe
• Educational institution

Decision and Designation Regarding Risk Status of Applicant

When an applicant is designated as high risk by the Office of Audit, Assessment and Management, (OAAM), all DOJ components must consider the applicant high risk.

• Under the DOJ High Risk Grantee Designation Program, OAAM may designate a grantee as high risk if the grantee:
• Has a history of unsatisfactory performance;
• Is not financially stable;
• Has an accounting system that does not meet the standards set forth in Title 28 CFR §66.20 [PDF - 144 KB] (which details standards for financial management systems);
• Has not conformed to the terms and conditions of previous awards;
• Is otherwise not responsible;
• Has open a single audit report or Office of the Inspector General (OIG) audit report recommendations that have been open for more than a year, whereby an adequate corrective action plan has not been submitted by the grantee to OJP;
• Does not respond to requests from OJP to address open single audit or OIG audit report recommendations;
• Has significant noncompliance issues that were identified through the normal award administration process (i.e., financial or programmatic monitoring);
• Is subject to an OIG investigation where award noncompliance issues were noted that require corrective action;
• Is included on the list of grantees currently prohibited from receiving funding from the Office of Community Oriented Policing Services; and/or
• Was referred to the U.S. Department of Treasury (Treasury) under the Treasury Offset Program for collection of award funds owed to OJP.
• The DOJ may also impose additional restrictions on awards to grant recipients designated as high risk in accordance with Title 28 CFR §66.12 [PDF - 142 KB] and Title 28 CFR §70.14 [PDF - 127 KB].

Audit Issues

• OJP may not approve you for an award if you have an overdue audit report or an open audit report that you have not responded to or tried to resolve.
• If you are not in compliance with audit requirements, your application for an award may be rejected, or your funds may be withheld until audit compliance is achieved.

Verification of Taxpayer Identification Number

• OJP or the awarding agency will verify the employer identification number (EIN) provided on the application.
• OJP may assign a vendor number very similar to your EIN. This is done so that when a sub-agency within your government receives awards directly, they will have a separate identifier from that of the parent agency.
• For example, you are a State government and your EIN is 123456777. A police department within your government applies for and receives an award from OJP, but since the EIN is the same, we assign them an OJP vendor number of 123456778 so that we can identify them as a sub-agency within your government.

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.

Assessment of Applicant's Financial Capability

If you are a nongovernmental organization and you do not have any history with OJP within 3 years, then you are required to complete a Financial Capability Questionnaire [PDF - 541 KB] and submit it to OJP before you can be approved for an award.

Confirmation of Dun & Bradstreet Data Universal Numbering System Number

All organizational grant applicants must have a Data Universal Numbering System (DUNS) number when applying for Federal awards and cooperative agreements (initial or supplemental awards). For more information, see the White House memo [PDF - 67.3 KB] regarding the authority to collect a DUNS number.

• As an organization, you 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.

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. It is where organizations (Entities) register if they want to do business with the Federal Government.

• 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.
• If you had an active record in the CCR in August 2012, your Entity's record was migrated and included in SAM.
• You must update or renew your registration 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.
• To update or renew your Entity record(s) in SAM, you will need to create a SAM User Account and link it to your migrated (existing) Entity records.
• It takes 2 to 3 days for SAM to complete record updates. You will be notified via email when the process is complete and your record is active in SAM.
• If your 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 your Entity's Tax ID number (TIN).

Recipients of OJP awards will be held accountable for all debts owed to the Federal Government. A debt may be incurred as a result of the following actions:

• Receiving an overpayment of Federal funds.
• Audit disallowances.
• Costs disallowed during monitoring reviews.
• Doing anything else that amounts to a breach of award.

Under the Debt Collection Improvement Act of 1996, if after written notification, the amount owed to the Federal Government continues to be delinquent, your debt will be referred to a collection agency or Treasury for further action.

As required by the Federal Claims Collection Standards and Office of Management and Budget (OMB) Circular A-129, OJP or the awarding agency will apply interest, penalties, and administrative costs to a delinquent debt owed by a debtor or award recipient.

OJP will complete a financial review of your application to ensure that you are financially capable and have the financial integrity to administer Federal funds. As part of this review, OJP will take all of the following steps:

• Perform a cost analysis of your project.
• OJP will obtain cost breakdowns, verify cost data, evaluate specific elements of cost, and examine data to determine the necessity, reasonableness, allowability, allocability, and appropriateness of your proposed cost.
• Review your current indirect cost rates approved by DOJ or rates approved by other Federal agencies.
• If you do not have an approved rate, you must submit an indirect cost proposal to your cognizant Federal agency.
• Determine the adequacy of your accounting system and operations to ensure that Federal funds, if awarded, will be expended in a reasonable manner.
• If you are a nongovernmental organization and you have not received an award from OJP in the past 3 years, then you are required to complete a Financial Capability Questionnaire and submit it to OJP before you can be approved for an award.
• Review your credit reports, the status of any Federal debt that you may have to ensure you are not delinquent, and other prescreening information, including checking SAM to ensure your organization is not suspended or debarred from receiving Federal funds.

OJP requires most award applicants to certify certain conditions and behaviors before it will recommend the applicant for award. In order to comply with the certification requirements provided in the common rules, applicants must complete and submit OJP Form 4061/6 [PDF - 17 KB] entitled "Certifications Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; and Drug-Free Workplace Requirements."

Debarment and Suspension Certification

Debarment and suspension certification requires that agencies establish and implement procedures to ensure that Federal assistance is not awarded to entities that are prohibited from receiving Federal funds. Those procedures should include a review of information in SAM regarding exclusion status. Such procedures help the Federal government and your agency to conduct business only with responsible persons.

• This certification must be completed and submitted to OJP's program offices during the application review process.
• The Government-wide common rule for debarment and suspension, codified in Title 28 CFR Part 67 [PDF - 96 KB] (DOJ specific provisions), and in Title 2 CFR Part 180 [PDF - 328 KB] (government-wide provisions), sets out the guidance that Federal agencies use to implement debarment and suspension procedures.
• Debarment or suspension of a participant in a program by one agency has a Government-wide effect.

Responsibilities for prospective block/formula recipients:

• If you are applying for this type of award, then you are not required to submit this certification.
• However, you are responsible for monitoring subrecipient submissions of the OJP Form 4061/1, "Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion—Lower Tier Covered Transactions (Sub-Recipient)," and for maintaining these submissions at the State level.

Responsibilities for individuals or corporations with critical influence or high levels of control over the prospective award:

• If you fall into this category, then you must complete OJP Form 4061/1 (or a similar form).
• You will be responsible for monitoring the submission and maintaining the official subrecipient certifications.
• Subrecipients are not required to complete certification if their subaward is less than $100,000.

Drug-Free Workplace Certification

All applicants must meet the requirements in Title 28 CFR Part 83 [PDF - 156 KB] in order to receive Federal funds. Subpart F of Title 28 CFR Part 83 [PDF - 156 KB] implements the statutory requirements of the Drug-Free Workplace Act of 1988.

If you are applying for a Federal award, you must certify that you will maintain a drug-free workplace. If you make a false certification, you are subject to suspension, termination, and debarment. All applicants are required to certify, regardless of award amount.

Additional requirements:

• Direct recipients of Federal discretionary awards must certify that they will comply with the Drug-Free Workplace Act of 1988.
• State agencies that administer block/formula awards:
• Must submit this certification to the awarding agency.
• Must obtain certification from each State agency that is subawarded funds.
• If the subrecipient is not a State agency, it is not required to submit the certification.
• Applicants with more than one prospective award are required to submit a certification for each award.
• There is one exception to the rule: a State, including a State agency, may submit a single annual certification to each awarding agency rather than one for each award.

There are different certifications for individuals and organizations:

• If you are an individual, you must certify that you will not engage in the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance in conducting any activity with the award.
• If you are an organization, you must certify that you will provide a drug-free workplace by ensuring the following:
• Publish a statement notifying employees that the unlawful manufacture, distribution, dispensing, possession, or uses of a controlled substance are prohibited in your workplace and specify that actions will be taken against employees for violation of such prohibition.
• Establish a drug-free awareness program to make employees aware of:
• The dangers of drug abuse in the workplace;
• Your policy of maintaining a drug-free workplace;
• Any available drug counseling, rehabilitation, and employee assistance programs; and
• The penalties that may be imposed upon employees for drug abuse violations occurring in the workplace.
• Require that each employee engaged in the performance of the award be given a copy of the employer's statement about drugs in the workplace.
• Notify the employee that, as a condition of employment under the award, he or she must:
• Abide by the terms of the statement; and
• Notify the employer of any criminal drug statute conviction for a violation occurring in the workplace not later than 5 days after such conviction.
• Notify the awarding agency within 10 days after receiving notice from an employee or otherwise receiving actual notice of such conviction.
• Take one of the following actions, within 30 days of receiving notice, with respect to any employee who is so convicted:
• Take appropriate personnel action against such an employee, up to and including termination; or
• Require the employee to participate satisfactorily in a drug abuse assistance or rehabilitation program approved for such purposes by a Federal, State, or local health, law enforcement, or other appropriate agency.

Lobbying Certification

You must complete this certification before OJP will recommend you for an award. You can find guidance on lobbying certification and restrictions in Title 28 CFR Part 69 [PDF - 404 KB]. These restrictions on lobbying apply to all recipients and subrecipients.

Additional restrictions on lobbying applicable to all recipients and subrecipients are:

• 18 United States Code (U.S.C.) 1913
• Interim Financial Guidance for New Restrictions on Lobbying [PDF - 34 KB]
• Lobbying Disclosure Act of 1995

In addition to the restrictions above, you are required to adhere to restrictions on lobbying included in 31 U.S.C. 1352. These restrictions include the following:

• If you have a Federal award, cooperative agreement, or contract, you cannot use Federal funds to pay a person for influencing or attempting to influence an officer or employee of any agency, a member of Congress, an officer or employee of Congress, or an employee of a member of Congress in connection with any of the following covered Federal actions:
• The awarding of any Federal contract;
• The making of any Federal grant;
• The entering into of any cooperative agreement;
• The extension, continuation, renewal, amendment, or modification of any Federal contract, grant, or cooperative agreement.
• Individuals who receive an initial Federal award, contract, or cooperative agreement of more than $100,000, must submit a Lobbying Certification to that awarding agency certifying that:
• You have not made and will not make any payment for a lobbying activity;
• If you have used or will use non-Federal funds to pay anyone for lobbying activities, then you will submit a Disclosure of Lobbying Activities form;
• The information from this certification will be included in your award documents for all subawards at all tiers (including subcontracts, subawards and contracts under awards, and cooperative agreements), and all of your subrecipients must provide certification and disclosure;
• You will submit the disclosure form to the awarding agency;
• You or your subrecipient is responsible for reporting lobbying activities of your/its employees if the employee's tenure is less than 130 working days within 1 year immediately preceding the date of your or your subrecipient's application or proposal submission; and
• If you are a subrecipient who requests or receives Federal funds exceeding $100,000 you will submit a certification and a disclosure form to your awarding agency.

All certifications will be maintained by the awarding agency and all disclosure forms will be forwarded from tier to tier until received by OJP.

The disclosure form must contain the following information:

• Name and address of reporting entity;
• Federal program name;
• Federal award number;
• Federal award amount;
• Name and address of lobbying registrant.

If an event occurs that requires disclosure or materially affects the accuracy of the information contained in any disclosure form previously filed, then you must file a disclosure form at the end of each quarter. We provide examples of such events below:

• A cumulative increase of $25,000 or more in the amount paid or expected to be paid for influencing or attempting to influence a covered Federal action.
• A change in the person(s) or individual(s) influencing or attempting to influence a covered Federal action.
• A change in the officer(s), employee(s), or member(s) contacted to influence or attempt to influence a covered Federal action.

Penalties and enforcement of lobbying restrictions will be as follows:

• If you make an expenditure prohibited by the new restrictions on lobbying you will be subject to a civil penalty of $10,000 to $100,000 for each expenditure.
• If you fail to file or amend the disclosure form as required, you will be subject to a civil penalty of $10,000 to $100,000 for each such failure.

See Chapter 13: Unallowable Costs for cost restrictions relating to lobbying.

If you are a Federal Government contractor, subcontractor, award recipient, or subrecipient, you are encouraged to enforce policies that require employees, contractors, or subrecipients to wear seat belts when driving company-owned, rented, or personal vehicles while they are on the job. For the Federal policy on seat belt use, refer to the Highway Safety Act.

If you are a Federal Government contractor, subcontractor, award recipient, or subrecipient, you are encouraged to enforce policies that ban text messaging while driving company-owned, rented, or Government-owned vehicles; while driving privately owned vehicles when on official Government business; or when performing any work for or on behalf of the Government. For more on this topic, see the Federal policy on reducing text messaging while driving [PDF - 57 KB].

If you are a tribal organization carrying out a contract, grant, or cooperative agreement, you are eligible to have access to Federal sources of supply, including lodging providers, airlines, and other transportation providers.

Section 201(a) of the Federal Property and Administrative Services Act of 1949, 40 U.S.C. 481(a), indicates that employees of tribal organizations are eligible to have access to sources of supply on the same basis as employees of an executive agency if a request is made by the tribal organization.

Your application has gone through the review process and you have just been approved for an award. The next step in this process is award notification. Here are the details:

• The Office of Justice Programs (OJP) sends award notifications by email through the Grants Management System (GMS) to the individuals listed in your application as the point of contact and the authorizing official.
• GMS automatically issues the notifications after 12:01 a.m. eastern time on the award date.
• The email notification includes detailed instructions on how to access and view the award documents and how to accept the award in GMS.

The award document serves as the official document binding the recipient and OJP to the grant agreement. A sample award document is included in Appendix I. It includes the name of recipient, project title, award period, budget period, type of Federal funds (awards and cooperative agreements), amount of Federal funds, award number, and special conditions that must be met during the award period.

ACTION ITEM

You have 45 days from the award date to accept the award document or the award may be terminated. The Office of Community Oriented Policing Services (COPS) awards have a 90-day acceptance time frame.

To accept the award, you must log into GMS and designate a Financial Point of Contact (FPOC). You can find instructions for designating a FPOC in the GMS User Guide.

Here are some important points about the FPOC:

• He or she will be responsible for the financial administration of the award.
• He or she may be the same as the Principal Point of Contact (PPOC). Alternatively, the FPOC may be one or more separate individuals designated by the recipient.
• The designation of the FPOC must be completed in GMS before the award acceptance documents can be printed.

Once the FPOC has been designated, recipients should:

• Print and read the award document carefully.
• Have the award document signed and dated by the authorized recipient official designated in the application to indicate full acceptance of all terms and conditions. The name of this person is preprinted on the award document. An electronic signature will not be accepted.
• The authorized recipient official should also initial the bottom right corner of each page of the special conditions to signify agreement.

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• If the name of the person accepting the award is not the name preprinted on the award document, then the recipient must submit a Grant Adjustment Notice (GAN) to explain the reason for the change. Submission of the GAN is done through the GMS. The award acceptance document will be rejected if it is signed by anyone other than the authorizing recipient official named on the award document unless a GAN has been approved.
• If the signature on the award document is not legible enough for OJP to tell that the signature is that of the authorized recipient official, it will delay final award document acceptance, and may even cause rejection of the award document.

Do not make any changes to the award document! Doing so will make it null and void.

The signed award document and the special conditions should be submitted to the Office of the Chief Financial Officer (OCFO) Control Desk using any of the following methods:

• Email to [email protected]
• Toll-free fax to 866-388-3055
• Local fax (Washington, DC) to 202-354-4081
• Alternate fax to 202-353-8475

ACTION ITEM

Select only one of these submission options to avoid duplicate submissions. The original signed award document should be retained by the award recipient in its official award file.

If you decide not to accept the award, please contact your program manager to discuss any changes that need to be made. No Federal funds will be disbursed to a recipient until OJP has received the signed award document indicating acceptance of the award and all special conditions.

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By signing the award acceptance document, the recipient confirms that the project director is an employee of the recipient's organization.

You may direct questions concerning award notification and/or acceptance to OCFO Customer Service.

Special conditions are terms and conditions that are included with your award. Special conditions may include additional requirements covering areas such as programmatic and financial reporting, prohibited uses of Federal funds, consultant rates, changes in key personnel, and proper disposition of program income.

Some special conditions may be based on the program or the nature of the award itself. Regardless of the program office or the award, there are several special conditions that you will have with any OJP award. These conditions include but are not limited to the following:

• Compliance with this Financial Guide
• Submission of an Equal Employment Opportunity Plan if required
• Compliance with audit requirements
• Compliance with the Anti-Lobbying Act
• Compliance with the False Claims Act or committing fraud with grant funds
• Compliance with Recovery Act requirements, if applicable
• Compliance with FFATA requirements

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Failure to comply with special conditions may result in withholding of funds.

The recipient, upon accepting the award, also agrees to complete and keep on file, as appropriate, the U.S. Citizenship and Immigration Services' Employment Eligibility Verification Form I-9. This form is to be used by recipients of Federal funds to verify that persons are eligible to work in the United States.

Specific types of recipients and program awards have their own special conditions, as described below.

Commercial or For-Profit Organizations

If you are a commercial or for-profit organization, you have additional special conditions on your award. You must agree to:

• Not make a profit on the award and not charge a management fee for the performance of the award.
• Comply with Federal Acquisition Regulation (FAR) cost principles.

Information Technology Awards

If you have received an information technology (IT) award, you must agree to send written notification to the State IT Point of Contact regarding any IT project that is being funded by this award. Here are the details of this condition:

• This correspondence should include a brief description of the project.
• A copy of the correspondence should be sent to the grant manager.
• Once the copy has been received, the grant manager will remove this condition and inform the recipient that he or she has done so.
• If there is no State IT Point of Contact, the recipient agrees to submit a letter to the grant manager stating that this condition is not applicable for that reason.
• The intent of this condition is to facilitate information system communication.
• This condition does not require that the State IT Point of Contact concur with or approve the IT project.
• For a list of State IT Points of Contact, go to Justice Information Sharing State and Territory Points of Contact.

Cooperative Agreements—Reporting on Events

If you have received a cooperative agreement award and you hold or sponsor a conference, meeting, retreat, seminar, symposium, training activity, or similar event funded under the cooperative agreement, and the total cost of any one event exceeds $20,000 in award funds, you must email your report utilizing the conference form [Excel - 266KB] to [email protected] within 45 days after the end of the event. You will need the following information in order to submit each report:

Download checklist [PDF - 53 KB]

• Name of event
• Event dates
• Location of event
• Number of Federal attendees
• Number of non-Federal attendees
• Cost of event space, including rooms for breakout sessions
• Cost of audiovisual services
• Other equipment costs (e.g., computer fees, telephone fees, etc.)
• Cost of printing and distribution
• Cost of meals provided during the event (generally not allowable)
• Cost of refreshments provided during the event (generally not allowable)
• Cost of event planner (logistical & programmatic)
• Cost of event facilitators
• Any other costs associated with the event

Additionally, you must itemize and report the following costs, which are paid for or reimbursed with cooperative agreement funds, for any attendee (including participants, presenters, and speakers):

• Meals and incidental expenses portion of per diem
• Lodging
• Transportation to/from event location (e.g., common carrier, privately owned vehicle [POV])
• Local transportation (e.g., rental car, POV) at event location
• Lodging

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Items paid for with registration fees, or other non-award funding, do not need to be reported on conference form.

State Block or Formula Subawards

If you have received a block or formula subaward from your State, your project must be operational within a specified time frame or face the possibility of it being cancelled. The State is required to pass on to you the following conditions:

• If a project is not operational within 60 days of the original start date of the award period, the State requires you to send a letter explaining the steps taken to initiate the project, the reasons for the delay, and the expected revised start date.
• If a project is not operational within 90 days of the original start date of the award period, the State will require from you a second letter explaining the implementation delay.
• Upon receipt of the 90-day letter, the State may cancel the project and request OJP approval to redistribute the funds to other project areas.
• The State may also, under extenuating circumstances, extend the implementation date of the project past the 90-day period.
• When this occurs, a note must be added to the appropriate subaward files explaining the extension.

ACTION ITEM

States should evaluate all special conditions of their direct award and document whether each special condition will be passed to its subrecipients. If a special condition is not passed to the subrecipient, the State should document why it made this decision.

When you are approved for an award, the Federal agency that is granting you the award will reserve (set aside) the amount of the money that they are giving you and record it in their books. Any funds or monies that are set-aside funds are reserved against the award until you and the subrecipient spend all of these funds.

If the funds are not used within statutory or other time limits, the funds that were set aside will revert back to OJP or the awarding agency through de-obligation of the unused balance.

Funding process:

• On the award date, you are notified of award approval and obligation, as described previously.
• Once you accept the award, in order for you to receive payment of funds obligated in OJP's accounting system, you must be in compliance with the special conditions listed in the award document. You also must be in compliance with all reporting requirements.
• All recipients are required to submit the SF-425 (also known as the Federal Financial Report or FFR) for each award on a quarterly basis for the life of the grant. A copy of the FFR is located in Appendix II.
• For discretionary awards, performance and progress reports are also required on a semiannual basis.
• Funds will not be disbursed if reports are delinquent.

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If the award date is after the start date of the award, the first FFR submitted to OJP should cover the time period from the actual award date to the end of the calendar quarter in which the award was made.

Before you can start drawing down and spending your money, you must complete and submit an Automated Clearinghouse (ACH) form. This form will have your banking information on it, which enables your award funds to be electronically transferred into your bank account.

ACTION ITEM

The completed ACH form you are required to submit must have the original signature of the authorized official of your financial institution. You can find the ACH form at OJP Standard Forms and Instructions, along with instructions on where to submit the original, signed document.

The U.S. Department of the Treasury uses the ACH information to transmit payment data using electronic funds transfer to the recipient's designated financial institution. Payments cannot be made without a current, valid, and complete ACH form on file.

III. Postaward Requirements of this Guide provides additional information on payments and the Grants Payment Request System (GPRS).

FINANCIAL MANAGEMENT TIP

If you have an active award, you do not have to submit a new ACH form for each new award. However, if you would like to revise your current banking information, a new ACH form must be submitted.

All recipients and subrecipients are required to establish and maintain adequate accounting systems and financial records and to accurately account for funds awarded to them. As a recipient, you must have a financial management system in place that is able to record and report on the receipt, obligation, and expenditure of grant funds. You should keep detailed accounting records and documentation to track all of the following information:

• Federal funds awarded
• Federal funds drawn down
• Matching funds of State, local, and private organizations, when applicable
• Program income
• Subawards (amount, purpose, award conditions, and current status)
• Contracts expensed against the award
• Expenditures

Please consult Title 28 CFR Part 66 [PDF - 221 KB] and Title 28 CFR Part 70 [PDF - 215 KB] for more information.

What Is An Adequate Accounting System?

• An adequate accounting system can be used to generate reports required by award and Federal regulations. Your system must support all of the following:
• Financial reporting that is accurate, current, complete, and compliant with all financial reporting requirements of your award or subaward
• If you are a recipient, establishment of reasonable procedures to ensure the receipt of reports on subrecipients' cash balances and cash disbursements in sufficient time to enable them to prepare complete and accurate cash transactions reports to the awarding agency
• Accounting systems should be able to account for award funds separately (no commingling of funds).
• An adequate accounting system allows you to maintain documentation to support all receipts and expenditures and obligations of Federal funds.
• An adequate accounting system collects and reports financial data for planning, controlling, measuring, and evaluating direct and indirect costs. Your system should help you capture all relevant expenses to make sure that you obtain approval from your cognizant Federal agency for all indirect costs.
• Your system should have all of the following capabilities:
• Internal control. Your system should allow you to exercise effective control and accountability for all grant and subgrant cash, real and personal property, and other assets. As a recipient or subrecipient, you must adequately safeguard all such property and assure that it is used solely for authorized purposes. Please consult these resources for additional information.
• Budget control. Your system should let you compare actual expenditures or outlays with budgeted amounts for each award and subaward. It also must relate financial information to performance or productivity data, including the development of unit cost information whenever appropriate or specifically required in the award or subaward agreement.
• Allowable cost. Your system should support you in making sure that you follow applicable Office of Management and Budget cost principles, agency program regulations, and the terms of grant and subgrant agreements in determining the reasonableness, allowability, and allocability of costs.
• Source documentation. Your system should require you to support accounting records with source documentation (e.g., cancelled checks, paid bills, payrolls, time and attendance records, and contract and subgrant award documents).
• Cash management. An adequate system will require you to follow procedures for minimizing the time between the transfer of funds from the U.S. Department of the Treasury and disbursement by recipients and subrecipients whenever advance payment procedures are used. Also, when advances are made by electronic funds transfer, or EFT, methods, your system should help you as the recipient to make draw downs as close as possible to the time of making disbursements.
• Subrecipient monitoring support. Your system should involve monitoring of cash draw downs by subrecipients to assure that they conform substantially to the same standards of timing and amount as apply to advances to you as the direct recipient.
• An adequate accounting system for a recipient must be able to accommodate a fund and account structure to separately track receipts, expenditures, assets, and liabilities for awards, programs, and subrecipients.

The adequacy of your financial management system may be reviewed as part of the application process or at any time subsequent to the award.

Block and Formula Awards

To properly account for block and formula awards, the State should establish and maintain program accounts which will enable separate identification and accounting for:

• Block and formula grant funds expended through subrecipients
• Formula funds utilized to develop a State plan and to pay that portion of expenditures necessary for administration

Discretionary Awards

To properly account for discretionary awards, all recipients should establish and maintain program accounts which will separately identify and account for:

• Receipt and disposition of all funds (including program income)
• Funds applied to each budget category included within the approved award
• Expenditures governed by any special and general provisions
• Non-Federal matching contribution, if required

The American Recovery and Reinvestment Act Awards

• All recipients must track, account for, and report on American Recovery and Reinvestment Act of 2009 (Recovery Act) award funds separately from all other funds (including funds from other U.S. Department of Justice awards).
• Recovery Act funds may be used with other non-Recovery Act funding sources to assist in the completion of the same or similar projects, but tracking and reporting of Recovery Act funds must be separate.
• If a position is funded partially with Recovery Act funds, then Recovery Act-funded hours must be tracked separately.
• Additional details on the management of Recovery Act awards can be found in Chapter 25: The American Recovery and Reinvestment Act of 2009 of this Guide.

FINANCIAL MANAGEMENT TIP

Recommendations for separately tracking and reporting on Recovery Act awards: 1) At a minimum, use a spreadsheet to track each Recovery Act award; 2) Automated systems must have codes or accounts specific to Recovery Act-funded programs and identify all Recovery Act transactions with the new codes (e.g., ARRA-BJA, ARRA-OVW-STOP, ARRA-COPS).

To ensure adequate fiscal administration, accounting, and auditability of all Federal funds received, your records should be established using the Federal agency "total program cost" basis. This includes all of the following types of funding sources:

• Federal funds
• State funds
• Match
• Program income
• Any other funds received for the program

You should submit budgets based upon the total estimated costs for the project including all funding sources. List anticipated expenditures according to the funding source from which they will be paid. The example below displays one sheet of a sample budget; additional back-up pages will further break out personnel and other costs, as well as the anticipated source(s) for match and program income.

Sample Budget

Budget Categories	Projected Project Costs	Federal Award	15% Match	Program Income	Balance
Personnel/Direct Labor	$69,732	$59,272	$10,490	—	$(30)
Fringe @ 33% Actual	$23,012	$19,560	$3,462	—	$(10)
Subtotal	$92,744	$78,832	$13,952	—	$(40)
Travel	$4,620	$4,620	—	—	—
Equipment	—	—	—	—	—
Office Supplies	$720	$220	$500	—	—
Contractual	$4,000	$4,000	—	—	—
Other	$2,618	$2,037	—	—	$581
Training Supplies	$2,250	$1,200	$500	—	$550
Registration Fees	—	—	—	$1,200	$(1,200)
Indirect @ 10% Actual	$10,695	$9,091	$1,495	—	$109
Total Project Costs	$117,647	$100,000	$16,447	$1,200	—

Although Federal regulations do not require physical segregation of cash deposits, the accounting systems of all recipients and subrecipients must ensure that agency funds are not commingled with funds from other Federal agencies.

• You must account for each award separately.
• Recipients and subrecipients are prohibited from commingling funds on either a program-by-program or project-by-project basis.
• Funds specifically budgeted and/or received for one project may not be used to support another.
• If your automated general ledger accounting system cannot comply with this requirement, you should establish a system to adequately track funds according to each budget category.

FINANCIAL MANAGEMENT TIP

Some programs, such as the Justice Assistance Grant program, require the deposit of funds into a trust fund. In addition, sometimes a high-risk designation will require a recipient to segregate awards into separate bank accounts.

Example

How a recipient can avoid commingling funds:

A recipient with three awards has a bank account with a balance of $47,948. The subsidiary accounting ledgers for the cash account clearly show how much cash is available for each award: for award 1, $15,000; for award 2, $30,068; and for award 3, $ 2,880.

Sample Ledger	Award 1	Award 2	Award 3
Grant Award	$23,500.00	$50,000.00	$10,800.00
Program Income	$1,169.00	0.00	0.00
In-Kind	0.00	0.00	0.00
Total Project	$24,669.00	$50,000.00	$10,800.00
Personnel/Direct Labor	$4,750.00	$10,600.00	$1,950.00
Fringe @ 33% Actual	$1,567.50	$3,498.00	$643.50
Subtotal	$6,317.50	$14,098.00	$2,593.50
Travel	0.00	$45.00	0.00
Equipment	0.00	$3,610.00	$4,606.50
Supplies	$2,042.50	$263.80	0.00
Contractual	0.00	0.00	0.00
Other	$430.00	$103.20	0.00
Indirect @ 10% Actual	$879.00	$1,812.00	$720.00
Total Expense	$9,669.00	$19,932.00	$7,920.00
Cash Balance	$15,000.00	$30,068.00	$2,880.00

If your accounting system does not make it possible to identify funds and expenditures with a particular program (with the identification supported by source documentation), a site visit or an audit of that program may result in those costs being questioned or disallowed.

Example

How a recipient can make sure that funds and expenditures are clearly identifiable with specific programs within the accounting system:

A recipient has three active awards and four staff members who charge a portion of their time to all three awards. One expense account with payroll costs for all four staff members is not sufficient for purposes of accounting for each award. Each staff member must complete time and attendance records which clearly show the time each spent on each award by name or code; the recipient must maintain the time and attendance records and use them to distribute actual payroll costs to each award.

Direct recipients must have established, written policies on subrecipient monitoring.

Reviewing Financial Operations

• Direct recipients should be familiar with, and periodically monitor, their subrecipients' financial operations, records, systems, and procedures.
• As a recipient, you should direct particular attention to the subrecipient's maintenance of current financial data.
• Please refer to 3.14 Subrecipient Monitoring for additional information about subrecipient monitoring.

Recording Financial Activities

• The recipient should record in its books in summary form the subrecipient's award or contract obligation, as well as cash advances and other financial activities.
• The recipient should record on its books the expenditures of its subrecipients. Alternatively the subrecipient may file report forms for tracking of its financial activities.
• Non-Federal contributions applied to programs or projects by subrecipients should likewise be recorded, as should any program income resulting from program operations.

Budgeting and Budget Review

• The recipient should ensure that each subrecipient prepares an adequate budget on which its award commitment will be based.
• The detail of each project budget should be kept on file by the recipient.

Accounting for Non-Federal Contributions

• Non-Federal contributions may include in-kind services (donated services such as volunteered time) or cash.
• Recipients should ensure that the requirements, limitations, and regulations pertinent to non-Federal contributions are applied.

Ensuring that Subrecipients Meet Audit Requirements

• Recipients must ensure that subrecipients have met the necessary audit requirements contained in this Guide (see 3.19 Audit Requirements).

Reporting Irregularities

• Recipients and their subrecipients are responsible for promptly notifying the awarding agency and the Federal cognizant audit agency of any illegal acts, irregularities, and/or proposed or actual actions.
• Illegal acts and irregularities include conflicts of interest, falsification of records or reports, and misappropriation of funds or other assets.
• Please notify the appropriate OJP Bureau or Program Office of any irregularities that occur.

Avoiding Business with Debarred and Suspended Organizations

• Recipients and subrecipients must not award or permit any award at any level to any party which is debarred or suspended from participation in Federal assistance programs.
• For details regarding debarment procedures, see Title 28 CFR Part 67, "Government-wide Debarment and Suspension." [PDF – 94KB]

Bonding

• The awarding agency may require adequate fidelity bond coverage where a recipient lacks sufficient coverage to protect the Federal Government interest (see Title 2 CFR Part 215, Subpart C, paragraph 21(c) [PDF – 237KB] ).

Consistent with the national goal of expanding the opportunities for women-owned and minority-owned business enterprises, recipients shall be encouraged to use women-owned and minority-owned banks (a bank which is owned at least 50 percent by women or minority group members). For more information see Title 2 CFR Part 215.22 (j) [PDF - 172 KB].

A list of minority-owned banks may be obtained from the following agency:

Minority Business Development Agency
U.S. Department of Commerce
Washington, DC 20230

Federal funds must be used to supplement existing State and local funds for program activities and must not supplant those funds that have been appropriated for the same purpose.

• Supplanting will be reviewed during the application process, post-award monitoring, and audit.
• If reviewers think that supplanting may have occurred, then the applicant or recipient will be required to supply documentation demonstrating that the reduction in non-Federal resources occurred for reasons other than the receipt or expected receipt of Federal funds.
• For certain programs, a written certification may be requested by the awarding agency or recipient agency stating that Federal funds will not be used to supplant State or local funds.

Example

To help clarify the difference between supplementing and supplanting, we provide the following example:

State funds are appropriated to hire 50 new police officers, and Federal funds are awarded for hiring 60 new police officers. At the end of the year, the State has hired 60 new police officers, and the Federal funds have been exhausted. The State has not used its funds towards hiring new officers, but instead reduced its appropriation for that purpose and assigned or appropriated the funds to another purpose. In this case, the State has supplanted its appropriation with the Federal funds. If supplanting had not occurred, 110 new officers would have been hired using Federal funds for 60 officers and State funds for 50 officers.

ACTION ITEM

Where the conduct of a program or one of its components is delegated to a subrecipient, the direct recipient is responsible for all aspects of the program including proper accounting and financial recordkeeping by the subrecipient. The recipient is responsible for the accounting of receipts and expenditures, cash management, maintenance of adequate financial records, and refunding of expenditures disallowed by audits.