VOCA Subrecipient Monitoring Department of the Attorney Generals

VOCA Subrecipient Monitoring Department of the Attorney General’s CRIME PREVENTION AND JUSTICE ASSISTANCE DIVISION (CPJAD) GRANTS AND PLANNING http: //ag. hawaii. gov/cpja/gp/

VOCA Grants & Planning Branch VOCA Branch Chief Calleen J. Ching Calleen. J. Ching@hawaii. gov Criminal Justice Planning Specialist Randi U. Barretto Rima A. Spight Randi. U. Barretto@hawaii. gov Rima. A. Spight@hawaii. gov

Today’s Agenda n Federal and State Definitions - OMB Circular, Part 200 requirements - Subrecipient vs. Contractor - Roles & Responsibilities of the Subgrantee/Subrecipient n Monitoring Requirements I. On-site Monitoring Activities II. Collecting and Submitting Supporting Documentation III. Reporting Oversight (Fiscal, Federal/State reporting) IV. Follow up n Helpful Resources - Monitoring Attachments

Essential Subrecipient Questions n Why do we need to monitor? n What constitutes a subrecipient versus a contract? n How and what do we monitor? n What problems can be identified in monitoring? n What are the potential outcomes of monitoring? n Why is this so important now? !? !

Federal/State Definitions

Department of Justice Programs OMB Circular, U. S. C. Part 200 The purpose of subrecipient monitoring: 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. DOJ 2017 Financial Guidelines

Federal Definitions Subrecipient Monitoring n n n Pass-through Entity – a non-federal entity that provides a subaward to a recipient to carry out part of a Federal program (2 CFR 200. 74). Subaward – an award provided by the pass-through entity to a subrecipient, for the subrecipient to carry out part of a federal award received by the pass-through entity (2 CFR 200. 92) Subrecipient – a non-federal entity that received a subaward from a pass-through entity to carry out part of a federal program (2 CFR 200. 93) DOJ 2017 Financial Guide

Federal Definitions Determining a Subrecipient vs. Contractor Subrecipient n n n Determines who is eligible to receive what Federal assistance Has its performance measured in relation to whether objectives of a Federal program were met Has responsibility for programmatic decision-making Is responsible for adherence to applicable Federal program requirements specified in the Federal award Uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing good and services for the benefit of the passthrough entity Contractor n n n Provides goods and services Provides similar goods or services to many different purchasers; Normally operates in a competitive environment Provides goods and services that are necessary to the operation of the federal program Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons.

State Definitions (CPJAD) Grantee Refers to the Department of the Attorney General/Crime Prevention Justice Assistance Division (CPJAD) Subgrantee Grant recipient with whom the Grantee contracts services Subrecipient Grant recipient with whom the Subgrantee contracts services

Subgrantee Responsibilities n n Establish policies and procedures on how subaward will be made and subrecipients are managed; Ensure subrecipients use grant funds in accordance with all federal and program guidelines Oversee the day-to-day operations of subrecipients to ensure they achieve performance objectives on schedule and within budget If problems arise, take the appropriate actions to get the subrecipient back on track

Subgrantee Responsibilities (cont’d) n Must have established written policies and procedures for subrecipient monitoring, as described in 2 CFR Part 200. 331. n A risk-assessment of each subrecipient must be performed for noncompliance with Federal requirements and the terms and conditions of the subaward, which can help to determine the level of monitoring needed. n Required to Conduct (1) on-site monitoring per contract period 2 year award w/ FY 2015/FY 2016 = (1) on-site monitoring per award year 2 year award w/ FY 2016 = (1) on-site monitoring (Year 1)/ Optional Enhanced Desk Review dependent on results of Risk Assessment (Year 2)

Subrecipient Responsibilities n Maintain program and fiscal files in accordance with agreements n Submit required federal and state reports to Subgrantee in a timely manner n Expend federal funds accurately and in a timely manner n Forward concerns and respond to requests from the Subgrantee/Grantee in a timely manner n Maintain property records for equipment and perform physical inventory of equipment purchased with VOCA funds

Audit Requirements 200 CFR Uniform Guidance n n n Agencies that expend $750, 000 or more in Federal funds (from all sources) in the organization’s fiscal year shall have a single organization-wide audit conducted in accordance with OMB Circular A-133 (Federal financial and compliance audit). Audits are due for each fiscal year with an end date of June 30 Allow auditors, Federal agencies, the Grantee, & Subgrantee access to program and fiscal records

What Else Should the Subrecipients Know? All subrecipient communication regarding the project will be directed to the Subgrantee, not the Grantee (CPJAD); Unless additional technical assistance is requested by the Subgrantee.

Monitoring Requirements

What is Subrecipient Monitoring? n The process of providing proper oversight of subawards distributed to subrecipients n It is required by any institution that is the recipient of federal funds n Subgrantees are required to conduct (1) on-site monitoring 1 x per grant year, per subrecipient

What problems can be identified? n Recurring programmatic and/or fiscal issues n Low and untimely expenditures to date n Concerns with data tracking n Timesheets do not track actual VOCA time and activity

What are the potential outcomes of monitoring? n Assist with developing effective systems for tracking program and fiscal outcomes n Effective working partnerships n Project sustainability and potential expansion

On-site Monitoring Activities n Subgrantee will coordinate with the Subrecipient PD and FO to schedule an on-site monitoring n Review programmatic, administrative, and basic financial information on grant n Collect and review all supporting documentation n Interview project staff n Issue monitoring report to subrecipient

Review Tracking Systems n n n Client Data Tracking Systems Performance Outcomes (contract goals and objectives) Timely and accurate submittal of Federal Reporting - Performance Measurements Tool (PMT) - Subgrant Award Reports (SAR) - Grantee Reports Time and Activity Sheets for federally funded staff Financial Reports (i. e. Financial Ledgers, Purchase orders, receipts, invoices, etc. )

Source Documents Required by OJP n Award letter n Executed Contract n General Ledger (Direct/Indirect) n Personnel and Payroll Ledgers n Source Documents supporting Accounting Transactions

Examples of Source Documents Cash Receipts Cancelled Checks Invoices Sent and Received Credit Memos/ Reimbursements *Approval Correspondence/ Completed Travel Documents VOCA Employee Time and Activity Sheets *Seek prior approval from CPJAD via the subgrantee for certain costs (i. e. Conference/Trainings, Publications, etc. )

Happy Place, Inc. Jane Doe Activity must be allowable under the grant & reflect the project Fringe benefits allowable under the grant 3/2018

Other Source Documents Contract Amendments Monthly/Quarterly Financial Reports Sole Source Documents/ Approved CPJAD Certification MOU/MOA (requirements will vary for each county/agency) Approved VOCA Volunteer Waivers & Supporting documents (ie. Policy of confidentiality) CPJAD Approved Indirect Costs forms & Supporting documents

Other Source Documents: CPJAD Approved Indirect Costs forms & Supporting Documents 1. Federally approved rate agreement/ CPJAD Approved 10% De Minimis Certification form 2. Approved budget with Administrative Indirect Costs line item 3. CPJAD Indirect Costs Computation Worksheet Allowable under the VOCA grant; different from the direct costs. NOTE: All supporting documents must be reviewed and approved by CPJAD

The Monitoring Report

Monitoring Reports What must a monitoring report include? n File Organization & Correspondence -Programmatic & Fiscal files n Budget Activity -Fiscal Reporting -Supporting Documentation (i. e. PO’s, receipts, invoices, indirect costs docs, equipment) n Project Progress -Grant Compliance/Goals & Objectives -Client Tracking/ Federal Reporting n Concerns and/or Accomplishments n Follow up

Monitoring Report Example

Monitoring Report: File Organization

Monitoring Report - Budget Items

Budget Items (cont’d)

Monitoring Reports – Personnel/Equipment

Monitoring Reports – Fiscal Reports

Monitoring Reports – Updates on Goals and Objectives Is the subrecipient meeting the expectations of the grant/contract?

Monitoring Reports – Problems Are there any problems or accomplishments that need acknowledging? NOTE: If problems are identified during the monitoring be sure to provide the subrecipient with technical assistance and support to resolve the issue.

Monitoring Reports – Follow up n A completed monitoring report will be forwarded to the Subrecipient to file; n Any concerns or problems found during the monitoring must be addressed by the Subrecipient and followed up by the Subgrantee

In Summary n Understand our roles and responsibilities as the monitoring agency n Develop strategies and approaches to successful subrecipient monitoring n Set our goals on sustaining programs that work to benefit the victim service community

Helpful Resources

Resources to Assist You… Department of the Attorney General, CPJAD Grants & Planning http: //ag. hawaii. gov/cpja/gp/ 2017 DOJ Financial Guide https: //ojp. gov/financialguide/doj/pdfs/DOJ_Fin ancial. Guide. pdf Office for Victims of Crime (OVC) www. ovc. gov Office for Victims of Crime Training & Technical Assistance (OVCTTAC) https: //www. ovcttac. gov/

Other Attachments n CPJAD Monitoring Report (Sample) n CPJAD Time and Activity Sheet (Sample) n Justification for Non-Competitive Procurement (Sole Source Justification (AG_CPJAD #21 n Indirect Costs Computation Worksheet n VOCA Volunteer Waiver (AG_CPJAD #39) n DOJ Subrecipient vs. Contractor Checklist

Questions and Answers All questions entered in the Go To Meeting chat box will be recorded answered then forwarded to all of today’s participants.