This Guide is provided for the use of all recipients and their subrecipients of Federal grant programs administered by the three primary Department of Justice (DOJ) grant-making components. The Guide was developed to serve as a compilation of the various laws and regulations governing DOJ grants financial management and administration. Any individual who works for a recipient or subrecipient should use this Guide as a reference for financial and administrative management of DOJ-funded grant programs or projects. These individuals may include administrators, financial management specialists, grants management specialists, accountants, and auditors. This Guide also may be used as a training resource for new employees.

Recipients

• A recipient is an entity that receives a Federal award directly from a Federal agency to carry out an activity under a Federal program. The term does not include subrecipients or individuals that are participants or beneficiaries of the award.
• Recipients are required to adhere to the applicable law of their jurisdiction, and the financial and administrative rules in this Guide. However, other programmatic and technical requirements (for example, as set out in award conditions or contained in program-specific guidelines) may also apply.
• Recipients are required to adhere to all applicable uniform (grants) administrative requirements, cost principles, and audit requirements set forth in 2 C.F.R. Part 200 and other applicable law.

Subrecipients

• A subrecipient is an entity that receives a subaward from a pass-through entity to carry out part of a Federal award. The term subrecipient does not include  a beneficiary or participant. A subrecipient may also be a recipient of other Federal awards directly from a Federal agency.
• Subrecipients are required to adhere to the applicable law of their jurisdiction and the financial and administrative rules in this Guide. The pass-through entity may also impose additional financial and administrative requirements.
• Subrecipients are also required to adhere to all applicable uniform (grant) administrative requirements, cost principles, and audit requirements set forth in 2 C.F.R. § 200 and other applicable law.

For-Profit (or Commercial) Entities

For-profit organization generally means an organization or entity organized for the purpose of earning a profit. The term includes but is not limited to:

1.  An “S corporation” incorporated under subchapter S of the Internal Revenue Code;
2.  A corporation incorporated under another authority;
3.  A partnership;
4.  A limited liability company or partnership; and
5.  A sole proprietorship

In accordance with 2 C.F.R. § 200.101(a)(2), OJP/OVW applies 2 C.F.R. Part 200, subparts A through E (excluding 2 C.F.R. § 200.317 through 200.327), to for-profit (or commercial) entities. However, for-profit (or commercial) entities receiving funding through the COPS Office must comply with 2 C.F.R. Part 200, subparts A through E. In addition, in accordance with 2 C.F.R. § 200.400(g), the recipient or subrecipient must not earn or keep any profit resulting from Federal financial assistance unless expressly authorized by the terms and conditions of the Federal award.

To the extent allowable and consistent with applicable law, and unless expressed explicitly otherwise herein, this Guide applies to any recipient or subrecipient that is a for-profit (or commercial) entity. As used throughout the Guide, the term “recipients or subrecipients” includes for-profit entities.

A Note about Payment Programs

Payment programs (also known as reimbursement- or reimbursable payment programs) provide payments to eligible participating jurisdictions for designated purposes but do not involve the post-award activities that take place under grants. Three examples of DOJ payment programs are the Bulletproof Vest Partnership (BVP) program and the State Criminal Alien Assistance Program (SCAAP), both administered by OJP’s Bureau of Justice Assistance, and the Special Tribal Criminal Jurisdiction Reimbursement Program, administered by OVW. Under the BVP program, for instance, certain costs that a jurisdiction incurs to purchase body armor may be reimbursed. This Guide generally does not apply to payment programs, except where it discusses certain requirements applicable to payments made under those programs, according to their terms and conditions. Please visit the applicable payment program website for information about each program’s specific requirements.

1.2 Resources

Government-Wide Grants Management Requirements and DOJ Regulatory Adoption

This DOJ Grants Financial Guide (Guide) includes references to the policies and guidance issued by the Office of Management and Budget (OMB). The largest division of the Executive Office of the President, OMB is responsible for implementing and enforcing the President’s policies across the entire Federal Government.

OMB issued a government-wide framework for grants management, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 C.F.R. Part 200), also known as the Uniform Guidance, in 2013.  DOJ has implemented the Uniform Guidance via DOJ regulation at 2 C.F.R. Part 2800.  OMB updates the Uniform Guidance from time-to-time.  This version of the Guide reflects the version of the Uniform Guidance in effect as of October 1, 2024.

The 2013 guidance superseded the following OMB requirements:

• OMB Circular A-21, Cost Principles for Educational Institutions;
• OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments;
• OMB Circular A-89, Federal Domestic Assistance Program Information;
• OMB Circular A-102, Grant Awards and Cooperative Agreements with State and Local Governments (Common Rule);
• OMB Circular A-110, Uniform Administrative Requirements for Awards and other Agreements, Institutions of Higher Education, Hospitals and other Non-Profit Organizations;
• OMB Circular A-122, Cost Principles for Non-Profit Organizations;
• OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations; and
• Sections of OMB Circular A-50, Audit Follow-up.

The following requirements remain in place:

• Government-wide Debarment and Suspension (Non-procurement) are codified at 2 C.F.R. Part 180, with DOJ-specific rules at 2 C.F.R. Part 2867.
• Government-wide Requirements for Drug-Free Workplace (Grants) is codified at 28 C.F.R. Part 83.
• Restrictions on lobbying are codified at 28 C.F.R. Part 69.

Applicability of the DOJ Grants Financial Guide

Office of the Inspector General Fraud Hotline

Recipients should report any allegations of fraud, waste, and abuse of grant funds to the appropriate DOJ grant-making component. In addition to reporting allegations to the grant-making component, allegations should be reported to the DOJ office of the Inspector General online at https://oig.justice.gov/hotline, by fax (202) 616-9881, or by mail:

U.S. Department of Justice
Office of the Inspector General
Investigations Division
ATTN: Fraud Detection Office
950 Pennsylvania Avenue N.W.,
Washington, DC 20530

Other Available Resources

• Guide to Procurements Under DOJ Grants and Cooperative Agreements [PDF - 563 Kb]
• OVW Recipient Resources available at https://www.justice.gov/ovw/after-receiving-ovw-funds.
• JustGrants Resources and Training can be found at https//justicegrants.usdoj.gov.
• The OJP Support Team is available via email at [email protected] or phone at 838-872-5175.
• OJP Recipient Resources can be found at https://www.ojp.gov/funding/implement/overview.
• The OVW JustGrants Helpdesk Support Team is available via email at [email protected] or phone at 1-866-655-4482.
• The COPS office Response Center is available at [email protected] or phone at 1-800-421-6770.
• The Federal Funding Accountability and Transparency Act (FFATA) is available at https://www.fsrs.gov.
• Federal grant information is available at http://www.grants.gov.
• Federal Government regulation information is accessible at http://www.regulations.gov