However, the full matching share must be contributed by the end of the award period. This type of GAN can also be used to de-obligate a portion of the award amount; however, the original award amount may not be increased by this procedure. Adopt effective fraud risk-management efforts within the organization, and encourage the  subrecipients to do the same in order to prevent and detect fraud as early as possible. Don't require unnecessary experience or other unnecessary criteria or elements that cannot be justified or supported with procurement procedures and the Procurement Standards. See 2 C.F.R. If it isn't documented, it doesn't exist! What if there are multiple meetings occurring within the larger event offered to all the attendees? If a recipient receives fees that do not fall within one of the circumstances above or does not receive prior approval via GAN, then the resulting program income must be deducted from the OVW award pursuant to 2 C.F.R. If it is not allowable under the Federal award, it is not allowable as match. Recipients are to use the Grant Adjustment Notice (GAN) module in GMS to request the extension. Pass-through entities that award $25,000 or more to subrecipients are required to submit data in the FFATA Subaward Reporting System. Funds for P/E, P/I, and P/S expenditures should be advanced to the officer for a specific purpose. Appalachian Regional Development Act of 1965, 40 U.S.C. Return interest income in excess of $500. Where these costs are included in rental charges, they may not be charged elsewhere. Audit confirmation requests for OVW awards should be emailed to [email protected]. Direct recipients and subrecipients are obligated to: Typical issues involving failure to properly support the use of award funds include: Applicants and recipients must represent their eligibility for funding accurately and cannot provide false or misleading information in their application, subsequent narrative progress reports, or federal financial reports. Also include a copy of the agenda (a draft version is acceptable) in one of the available tabs with the prior approval submission. The grant-making component reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use, for Federal Government purposes (and to authorize others to do so), the following: With respect to data produced under a Federal award, the grant-making component has the right to do the following: Freedom of Information Act. If the EFT is returned for insufficient funds, DOJ will process the transfer two more times. In general, in order for a Start Date GAN to be approved, there must not have been any draw down of funds. For questions regarding ACH information on file with DOJ, please contact the OCFO Customer Service Center at 1-800-458-0786 or by email at [email protected]. § 200.330 (through 200.332 – Subrecipient Monitoring and Management). Payment is electronically deposited into the recipient's bank account, typically within 72 hours. Income received from the sale of seized and forfeited assets (personal or real property) or from seized and forfeited money must follow the "Addition Method" of handling program income unless an alternate method is designated in the recipient's award document. The amount of payment should match the value of services and/or information provided and should be based on the following factors: The level of the targeted individual, organization, or operation. Recipients must have written subrecipient monitoring policies and procedures. The GPRS process and timeline for payment transactions is as follows: The Debt Collection Improvement Act of 1996 states that all eligible recipients of Federal payments must receive funds electronically. Non-federal entities are responsible for replacing or repairing property that is willfully or negligently lost, stolen, damaged, or destroyed. Final Federal Financial Report (FFR) (submitted on SF-425). Sometimes minor data entry errors will cause error messages. Indirect cost rates negotiated on the basis of modified total direct costs may only be applied against the first $25,000 of any subcontract or subaward under the agreement. § 200.22 (Contract). The total reimbursement will not exceed 10% of the amount recovered. All cooperative agreement and contract recipients (but not grant recipients) must obtain prior written approval from OJP/COPS Office before incurring conference planning costs in accordance with the previously described approval process, except for such costs that are the reasonable minimal costs of identifying conference locations and developing the itemized cost estimates required to assemble and submit a conference cost approval request. It is important to use this form for the post event report. This type of arrangement may require application of special matching share requirements under construction programs. GPRS is the system for requesting payment of award funds. For purposes of this chapter (OJP/COPS Office Conference Approval, Planning, and Reporting) references to "contractor" means a Federal contractor, unless context indicates otherwise. Recipients should keep in mind that idle funds in the hands of subrecipients will impair the goals of effective cash management. ATTN: Accounting Control Branch This requirement is also applicable to events pre-approved for less than $500,000. If approved, the request will be forwarded to the project cashier, who will record the request and transmit the monies, along with a receipt form, to the member agency. Despite the multiple meetings offered within the larger event, DOJ/OJP/COPS Office considers and approves this type of event as a single event. Question 11: To whom should I submit event requests?Answer: For all BJA events, the forms should be sent to:[email protected] All other OJP event forms should be sent to:[email protected]. As part of the organization's subrecipient monitoring process, it is important to develop systems, policies, and procedures to ensure that subrecipient reviews are conducted in accordance with Federal program and grant requirements, laws, and regulations. Regardless of the allocation method used by the organization, the following "direct cost" bases may be used as a distribution base: When a non-Federal entity seeks reimbursement for indirect costs, total lobbying costs must be separately identified in the indirect cost rate proposal and thereafter treated as other unallowable activity costs in accordance with the procedures in 2 C.F.R. Designate the award recipient as a high-risk recipient under the DOJ high-risk policy; Withhold future awards for the project or program; or. Copies of statements signed by the informant (unsigned copies will be placed in appropriate investigative files). Be sure to read ALL the special conditions in the award carefully! 2 C.F.R. The purpose of subrecipient monitoring is to ensure that the subaward is being used for the authorized purpose, in compliance with the federal program and grant requirements, laws, and regulations, and the subaward performance goals are achieved. See 2 C.F.R. Funds will not be obligated for construction until OJP has been contacted and assisted in satisfactorily completing any applicable OJP procedures by complying with the National Historic Preservation Act, the National Environmental Policy Act, and other related Federal environmental impact analysis requirements. Following such notification, and based on documentation, the agency will be required to submit a statement detailing the investigative costs it incurred. This prohibition applies to all activity, even if currently allowed within the parameters of the existing  OMB guidance. The system has automatic verification features in place that prevent drawdowns if all the required reports have not been submitted. Make sure a signed ACH Enrollment form with current banking information has been submitted. Any cases that do not have the corresponding court and arrest records will not be considered for funding. Indirect Costs resource document [PDF – 32KB], Confidential Funds Certification form [PDF - 116 KB], 2 C.F.R. At the end of this period, VOCA funds will be deobligated. The pass-through entity must have established written policies on subrecipient monitoring, as described in 2 C.F.R. Once an event is approved, how do we handle any increases and/or decreases in the amount of attendees originally proposed on the cost analysis spreadsheet submitted to DOJ for approval? This also provides the grant manager with notification. 810 Seventh Street, N.W. § 200.407) and as discussed in Chapter 3.6: Costs Requiring Prior Approval. Additionally, the COPS Office will contact the recipient during the last quarter of the award period to determine whether a no-cost extension is needed; extensions will not be processed prior to 90 days of the grant end date. § 200 Appendix III C.2 (IHE);  2 C.F.R. Debarment and Suspension - verification not performed or not properly documented. Where appropriate, lease versus purchase analysis should be performed as well as other appropriate analysis for determining the most economical method for obtaining items or services. DOJ funds generally cannot be used for land acquisition unless specifically permitted under the awarding program or terms of the award. However, cooperative agreement recipients should work with the relevant program office to ensure that any costs authorized are reasonable and minimal. Disposition. In the authorization the supervisor must specify the information to be received, the amount of expenditures, and the assumed name of the informant. The account information from the check will be scanned and stored. Which types of events DO NOT require prior approval? OJP, OVW, or COPS) to include the award number (COPS Office recipients must also includ eORI and vendor/EIN number; A cover letter or voucher containing the grant award number for the refund, the unobligated balance, and an itemization of funds (e.g., the amount to be applied to excess payments, interest-income, program income, questioned costs, and so forth); and. The seller is also eligible for limited sale and handling costs of $500 or 10% of the proceeds, whichever is less. Treasury will deposit payments into the bank account designated on the signed and filed ACH form. More information on overtime exemptions under the Fair Labor Standards Act is available on the Department of Labor's website at https://www.dol.gov/whd/overtime_pay.htm. Each recipient must designate officials responsible for the following tasks: The awarding agency monitors the audit report requirements for commercial organizations through its audit tracking system. The following situations are considered to be restrictive and should not take place: Written procedures for procurement transactions must ensure that all solicitations incorporate a clear and accurate description of the technical requirements of the material, product or service to be procured. Many awards require prior approval for changes in key staff. § 3789. Enhance coordination and communication among agencies that are in pursuit of criminal conspiracies determined to be interjurisdictional in nature. § 200, Appendix III.C.2 (Indirect costs - IHE);  2 C.F.R. All award recipients must submit, no later than 90 calendar days after the end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the award. See 2 C.F.R. (subject to the applicable policies and restrictions of the U.S. Department of Housing and Urban Development). A GAN may be initiated to request a change to the organization's mailing address. Each Project Director must record and maintain on file the assumed name and signature of all informants to whom member agencies make payments from project funds for all transactions involving P/I. An official website of the United States government, Department of Justice. During this time, it will not be possible to log into GPRS until receipt of an approval email from GPRS with the login information. Question 21: On the DOJ Conference & Events Submission Form, Item #19 Reporting Period under A. Where grant recipients work on multiple grant programs or cost activities, documentation must support a reasonable allocation or distribution of costs among specific activities or cost objectives. Don't forget to include all applicable contract provisions described in Appendix II to Part 200 in any procurement contracts. Purchase of Specific Information (P/I). The conference has not occurred and additional costs have been identified. When an independent audit is being conducted, recipients of OJP/COPS Office grant funds should email audit confirmation requests to [email protected]. Payments for these expenses may be either lump-sum or as they occur and should not exceed the amounts authorized by law enforcement employees for these activities. Conference Policy Last Updated March 18, 2013. The following border State and county governments are eligible to receive funding under the border prosecution initiatives: Northern border: Alaska, Idaho, Maine, Michigan, Minnesota, Montana, New Hampshire, New York, North Dakota, Ohio, Pennsylvania, Vermont, Washington, and Wisconsin, Southwest Border: Arizona, California, New Mexico, and Texas. The requirements for subrecipient monitoring can be found in 31 U.S.C. With prior approval, supplement the award-supported project with program income dollars. The award period is established for each award and is included in the award document. § 200.80. See 42 U.S.C. Written policies and procedures must be in place to address confidential funds. All OJP/COPS Office funding recipients must thoroughly review all planned conference costs to ensure that such costs are reasonable and absolutely necessary. Costs related to contractors of the recipient who are acting in the capacity of a "Conference Trainer/Instructor/Presenter/Facilitator" are considered participant support costs. Cooperative agreement recipients should pay particular attention to the two areas listed below to ensure that the application of indirect cost rate is in compliance with the existing requirements of the Government-wide grant rules set out by the Office of Management and Budget (OMB): $25,000 Subcontract/Subaward Limitation. § 200.330; 2 C.F.R. § 200 Appendix VII C.2.c (State and local). Remittances must include pertinent information of the payee and nature of payment in the memo area (often referred to as "addenda records" by financial Institutions) to assist in the timely posting of interested earned on federal funds. § 200.430. Consultants can play an important role in award programs; however, recipients and subrecipients, you must ensure that their work conforms to all regulations governing a fair consultant selection process, reasonable pay rates, and specific verifiable work product. After the liquidation period, recipients are unable to draw down any additional funds on the award. These requirements apply to recipients and subrecipients of awards and cooperative agreements and to any manager of a construction project acting on their behalf. 2 C.F.R. Note: After the prior approval portion of the submission form has been approved, a copy of the submission form which contains the OJP/COPS Office event identifier will be returned to the submitter. Pour protéger les PME de litiges, complications judiciaires ou redressement fiscal/social, Protection Juridique Vision Entreprise de Gan Assurances propose aux chefs d'entreprise des prestations adaptées information, conseil, aide et assistance. It includes all inmates, regardless of their status, citizenship, disposition, or length of stay, including inmates held at contract facilities. Minimizing costs must be a critical consideration when determining the city and facility in which to hold a conference. Office of Community Oriented Policing Services If meals are included in your event submission, please remember that attendees must subtract the meal costs from the M&IE reimbursement for the days on which the meals will occur. Office of the Chief Financial Officer Cost of ownership expenses for a publicly owned building are allowable where "rental rate" systems, or equivalent systems that adequately reflect actual costs, are employed. § 200, Subpart E - Cost Principles, 2 C.F.R. After submission of a GAN, OJP and OVW recipients should monitor the system for returned or change requested GANs in case additional information or changes are required. All conference costs for events held by cooperative agreement recipients or contractors costing over $20,000, or where more than 50% of attendees are DOJ employees, must be reported within 45 calendar days after the last day of the event. If the auditor becomes aware of illegal acts or other irregularities, he or she must give prompt notice to the recipient's management officials above the level of involvement. However, costs during suspension or after termination are allowable if: Closeout  means the process by which the Federal awarding agency or pass-through entity determines that all applicable administrative actions and all required work of the Federal award have been completed and takes actions as described in 2. Conference & Events Submission Instructions, Quick Reference Guide to Conference Cost Policy and Guidance, 2 C.F.R. Use. Prepared financial statements which are presented fairly and in accordance with generally accepted accounting principles. Part 200b Appendix. Les contrats d’assurance vie sont des contrats de Groupama Gan Vie, Société Anonyme au capital de 1.371.100.605 euros (entièrement versé) - 340 427 616 RCS Paris - APE :6511Z. See 2 C.F.R. The Project Director will then verify the receipt by comparing the signature of the informant payee on the receipt with the signature maintained by the project in a secure and confidential file. Develop a request for applications (proposals) that clearly defines the work to be accomplished in furtherance of the Federal award purpose(s). GANs may be submitted by the recipient, grant manager, or automatically generated by the Grant Management System (GMS). A budget modification is required. If funds are obligated (e.g., enter into a contract) prior to the start of the project period, that obligation may not be an allowable expense, unless the award recipient notifies the awarding agency in advance in writing and receives prior written approval from the awarding agency. Deduction of meals from requests for Meals and Incidental Expenses reimbursement (M&IE). Recipients often provide conference planning services either through their own staff and resources, or through contracted external conference planners. The non-federal entity provides the goods and services within normal business operations; The non-federal entity provides similar goods or services to many different purchasers; The non-federal entity normally operates in a competitive environment; The non-federal entity provides goods or services that are ancillary to the operation of the Federal program; and. If the item to be disposed of has a current per-unit fair market value of $5,000 or less, the item may be retained, sold, or otherwise disposed of with no further obligation to the awarding agency. See 2 C.F.R. Act with integrity when applying for and reporting the actual use of funds. Explanation of why it is necessary to contract non-competitively, including at least one of the four circumstances listed above. See Chapter 3.10: OJP/COPS Office Conference Approval, Planning, and Reporting for more information. If any of these data elements change during the period of performance, the changes must be included in subsequent subaward modifications. Disposition must occur in accordance with 2 C.F.R. § 200.315(c). Placing unreasonable requirements on firms in order for them to qualify to do business; Requiring unnecessary experience or excessive bonding; Noncompetitive pricing practices between firms or between affiliated companies; Noncompetitive contracts to consultants that are on retainer contracts; Specifying a "brand name" product instead of allowing "an equal" product to be offered; and, Any arbitrary action in the procurement process. Once a request has been made, GPRS checks several items, including but not limited to: Whether funds are available to be drawn on the award; Whether all withholding special conditions have been met; and. Are there meeting room costs that will be paid for with DOJ federal or match funds? Informant files should be kept in a separate and secure storage facility and under the exclusive control of the Project Director, manager, or an employee designated by him/her. Once audit reports are received through the DOJ single audit process, OJP will track the reports until the audit has been resolved and officially closed by the Office of the Inspector General. This provision does not restrict the authority of Federal agencies to identify taxes where Federal participation is inappropriate. § 200.330 (Subrecipient and Contractor Determinations), https://cops.usdoj.gov/pdf/2019AwardDocs/ctas/SF_425_Helpful_Hints_Guide.pdf, 2 C.F.R. In no case is dual compensation allowable. Subrecipient's prior experience with the same or similar subawards; Whether the subrecipient has new personnel or a new or substantially changed system; The extent and results of Federal awarding agency monitoring. This knowledge is the best way to reduce or even eliminate the risk of fraud.