FY 2022 Byrne Discretionary Grant Program Grantee Orientation and Training

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DARYL FOX: Good afternoon, everyone, and welcome to today's webinar, “FY 2022 Byrne Discretionary Grant Program Grantee Orientation and Training,” hosted by the Bureau of Justice Assistance. At this time, it's my pleasure to introduce Erich Dietrich, Division Chief with the Bureau of Justice Assistance, for some welcoming remarks and to begin the presentation. Erich.

ERICH DIETRICH: Welcome, and congratulations on your awards. I know your communities have been waiting a long time to receive this funding. We appreciate your work on submitting applications and your patience as we process awards. This orientation webinar will provide guidance on how to successfully administer your grant award.
As you see from the agenda, there's a lot of information, so after a brief introduction, I will turn it over to the subject matter experts. First, Nicko Taylor and Tammy Lovill with BJA and Ted Robinson with NIJ will cover the post-award grant management process, from award acceptance to closeout. Then we will turn it over to Michael Williams with OJP's Office of the Chief Financial Officer or OCFO to address grants financial management requirements. Finally, Bridget with the Office of Audit, Assessment, and Management or OAAM will demonstrate how to complete grants administrative actions in JustGrants. We will hope to have time to take questions at the end, but, as Daryl said, please feel free to put your questions in the Q&A during the presentations and we will respond to them in writing.

Before I turn it over to the experts, I wanted to briefly introduce the Office of Justice Programs for recipients who did not have any previous grants with the Department of Justice. OJP is one of the three grant-making offices within DOJ, along with the COPS Office and the Office of Violence Against Women. Under OJP, there are six bureau or program offices that administer the various OJP grant programs, four of which issue awards under this program, the Byrne Discretionary Grant Program. These offices are the one that I work for, Bureau of Justice Assistance, BJA, National Institute of Justice, NIJ, Office of Victims of Crime, OVC, and the Office of Juvenile Justice and Delinquency Prevention, OJJDP. We also have BJS and the SMART Office under OJP, but they did not issue any awards under this program. OJP also has support offices to include OCFO and OAAM. Principal Deputy Assistant Attorney General Amy Solomon is the current head of OJP.

On this slide, I included the summary of the FY22 Byrne Discretionary Grant Program. This program is funding individual community criminal justice projects that received a direct appropriation from Congress in the 2022 Consolidated Appropriations Act. The funding was appropriated under a grant program. OJP issued grant awards in the
amounts and for the stated purpose in the public law, and we will work with you to ensure the project is implemented successfully. And that's where I'll turn it over to the team to cover the grant management lifecycle and requirements. Nicko Taylor with BJA will start us off. Nicko.

NICKO TAYLOR: Hello and welcome. I am Nicko Taylor, and, as Erich stated, I am a Grant Manager in BJA who manages the BJA Byrne Discretionary Grant in Ohio. The OJP Program Office, and specifically your assigned Grant Manager, works with grantees to ensure grant-funded projects are implemented successfully and in compliance with all relevant program-specific and federal requirements. Your Grant Manager is your primary point of contact for any grant administrative questions or actions. This slide shows the grant management lifecycle and the topics that will be covered. We will begin with award acceptance and award conditions. Then I will address the budget crimes process and access to funds.

After that, I will summarize the reporting requirements before I turn it over to Ted, who will detail the specific reporting requirements for NIJ's award. My colleague, Tammy, will then cover administrative requirements, award modifications, monitoring and compliance, and the closeout process.

Every grant award is entered into the form of a legal agreement between your agency and the federal government. Before the award is accepted, it is important that you review and understand the terms of the agreement, which will include conditions you are responsible for adherent to the management and implementation of the award. The individual in your agency with the authorized representative role that you assigned to the application will be responsible for accepting the award electronically in JustGrants. However, before doing so, your agency Entity Administrator must assign a Grant Award Administrator, now SFGAA, and Financial Manager to your award. Bridget with the JustGrants team will discuss this in more detail later. And she will also explain how you can change the authorized representative if you need to before accepting the award. OJP includes standard award conditions which apply to all awards.

This slide includes a few examples, which includes the requirements to adhere to the DOJ Grants Financial Guide and the Uniform Requirement, which are the Federal Grant Regulations and 2 CFR Part 200. The OJP standard conditions are numbered one through 29 in your award agreement. The link on this slide has details on the legal requirements for fiscal year 2022 awards related to these conditions. Your awards also have program-specific award conditions, which begin at number 30 in the award agreement. These will differ slightly by which OJP program office issued your award. All awards will have this Byrne-specific award condition, which states that you have the authority to obligate non-federal funds on or after the first day of the project period but prior to award acceptance and removable of all the conditions at your own risk. Any costs incurred must be authorized in the approved budget and can only be incurred within the project period. Please talk to your Grant Manager if you have any questions about this condition or any other award conditions.

Your award may have one or more withholding award conditions that prevent expenditure or drawdown of your award funds until certain actions are completed. For example, if OJP identified issues with the budget, the conditional clearance withholding award condition is added. This condition will withhold all funds until OJP approves or clears the budget. I'll explain this more in a minute. Other withholding conditions may have been applied due to missing or insufficient information from your application that must also be addressed. New OJP recipients will have a withholding condition for completion of grant financial management training, which I will also discuss in a later slide.

You should work with your Grant Manager to provide the missing information needed to remove the hold associated with any withholding award conditions. If OJP did not clear your application budget post-award, the budget will be sent back or "change requested" with comments on what information or revisions are needed. A Budget Clearance Grant Award Modification, otherwise known as GAM, will be assigned to the Grant Award Administrator. The GAA will need to make the necessary changes to the budget and then resubmit the GAM to OJP for review.
As a reminder, in addition to the costs listed as unallowable in the DOJ Grants Financial Guide, the listed cost on this slide are unallowable under your award. This information is also listed in the solicitation. An award condition requires the Grant Award Administrator and Financial Manager assigned to your award must complete training within 120 days of grant assessments. Successful completion on or after October 15th, 2020 fulfills this requirement. This is a requirement for all recipients, but, as I mentioned, if your agency has not had a previous award or if your agency is identified as being higher risk, there will be a withholding the version of this award condition on your award. Therefore, I recommend new recipients start this training as soon as possible. There's also a link to the online training on this slide. You will need your UEI number and award number to register. You can also send your certificate of completion to your BJA Grant Manager when done.

About 20 or so projects funded under this program potentially involve use of chemicals for construction and therefore the requirement to access any environmental impact under the National Environmental Protection Act, known as NEPA, may apply. Award conditions were added to these awards to include a withholding condition so we can get the necessary information related to the NEPA requirements. Generally, this will require you to fill out forms and provide additional information about your project. Your award letter lists the NEPA Coordinator who can provide you with additional information. And for BJA awards, the NEPA Coordinator is Mr. Orbin Terry.

This slide details the steps you will need to take in order to access award funds. You must accept the award and resolve any withholding conditions or delinquent reports. You must also be registered in the U.S. Treasury's ASAP system, which is the system you will use to make draw down requests. Please note that unlike the Justice Assistance Grant Program, some of you may be familiar with, this program does not allow you to draw down all of the funds in advance. The standard rules for payment, as detailed in the DOJ Grants Financial Guide, if you draw down funds in advance, you can only draw down enough for 10 days of future cash needs, and any assets not spent in 10 days must be returned to OJP. There are no limitations on making reimbursement drawdowns. You can process reimbursements on a frequency that works for your agency.

This slide includes more details on the ASAP system. If you are a current OJP grantee with an active ASAP registration, you do not need to take any other actions in ASAP for this award. However, if you are a new OJP recipient, you will need to be registered in ASAP before you can draw down funds or submit reports in JustGrants. After your authorized representative accepts the award, the Entity Administrator for your agency will receive two emails from ASAP with instructions for registering. My colleague, Brenda—Bridget, I'm sorry—will talk about the ASAP registration process later.

And on this slide, we have the contact information for OCFO Customer Service with the contact if you need to request that the ASAP emails be resent to you if you need assistance registering.
Here are the semi-annual performance and quarterly financial report and deadlines for your awards. The assigned GAA is responsible for submitting the performance reports in JustGrants. Also, Grant Award Administrators can edit reports but not submit them. The assigned Financial Manager is responsible for submitting the quarterly federal financial reports in JustGrants. Both types of reports are due within 30 days of the end of the reporting period with the exception of the final reports which are due within 120 days of the project end date.

The BJA performance reports will have questions that will need to be answered within the report in JustGrants. Recipients are encouraged to attach any supporting documents to the report as well, especially the final report, what should have a narrative about the full accomplishment and the goals and objectives of your project. Ted with NIJ will cover the NIJ reporting requirements in a few minutes.

OVC and OJJDP recipients should consult their Grant Managers regarding their performance reports. It is very important to note that you can submit the final reports at any time during the project period if the project is finished early. Please keep in mind that JustGrants will automatically suspend the ASAP account if a report is delinquent and a pattern of delinquent reports will increase the chances your award will be selected for in-depth monitoring, so it is important to submit reports on time.

At this point, I would like to turn it over to my colleague, Ted Robinson with NIJ, who will cover some requirements that are specific to awards funded by NIJ and on the topic of research requirements on the grants.

THEODORE ROBINSON: Thank you so much. Yes. So, just before I get started, I just want to make sure to reiterate that these are exclusive to NIJ awards under this program. So if you're not an NIJ awardee under this program, don't get too wrapped up on these because they do not apply. I don't want you guys to start thinking of additional reporting requirements that you need to do or anything like that. So next slide please.

Just going over this, just starting on our reporting, it's not terribly dissimilar from what has just been discussed. You know, we have our Semi-annual progress reports, the Final report, and the Final Research Report. Next slide please.

And so, as noted, our Semi-annual progress reports—as NIJ is the research arm of the Justice Department, we've adopted the Research Performance Progress Report format or RPPR format. We have that detailed on our website. And it's also—I believe there's a link to that in the guidance that I sent in the kick-off email to you all. Thank you, Tammy. And so all of our progress reports and the final report are in that format. They're for every six months. So, as noted in the previous slides, they're generally due at the end of July and the end of January, given that these awards had a weird start date. The first ones are actually, I believe, due at the end of January. You have quite a bit of time still. And then the semi-annual progress reports every six months. The final report is due 120 days after the end date of the project and it's basically a semi-annual progress report that just encompasses the entire project period. Next slide please.
And then sort of our final deliverable is going to be the Final Research Report, which is a fairly concise document. Thank you for letting me know. [INDISTINCT] So our Final Research Report, it's a fairly concise document. There's details which are outlined on our website, which again is in the kick-off email. And if you have any questions, let me know. That's due at the end of the project period. It's still quite a ways off. But it's basically an amalgamation of the project activities. Next slide please.

And, as noted, NIJ, we have to follow regulations related to human subjects and privacy concerns. All of these projects have already been reviewed by our Human Subjects Protection Officer. And, again, in my kick-off email that I sent to you all, what we might need from you all at this point, related to satisfying those regulations, should be with you. But if you have any questions, please let me know. Next slide please.

And so, in this slide, we have a number of resources that go to our decision-making on what constitutes research or human subjects research. And, again, our Human Subjects Protection Officer has already reviewed all of this stuff. And if you need any guidance on how to get these within compliance—human subjects—please let me know. And next slide please.

And tying in with that is privacy concerns, of course. So the Privacy Certificate is another component of our application. And it goes hand in hand with the human subjects documentation. And, again, there's a link on this slide to what we might need from you all. And, again, refer to your kick-off email. And then the next slide please.

And then, in some cases, if a project does include human subjects, generally will require a review from an institutional review board who will review the project against the relevant policies and procedures and make a ruling sort of—research to take place. Once that's all in place, I will route that to our Human Subject Protection Officer who can review all of the documentation and just sort of get all of that in line before any of the activities sort of take place. And that's all I've got. Otherwise—sending it back to my BJA colleagues. If you have any questions related to any of the NIJ-specific requirements for these projects, please feel free to contact me. I'm more than happy to help. Thanks.

TAMMY LOVILL: Thank you, Ted. That is great information. I am Tammy Lovill with BJA. I currently manage the Byrne Discretionary Grant in Missouri. On this slide, I will cover an important administrative distinction between subawards and procurement contracts made under grants. The requirement for each differs significantly so it's important that you understand how that properly classify any third parties that you will pay with grant funds. It is the nature of the relationship that determines whether it is a subaward or a contract. For grant administrative processes. For example a non-profit partner agency who will be responsible for completing a portion of the projects to meet the goals and objectives would likely be a subrecipient, whereas a for-profit vendor that is providing goods and services for your agency is likely a procurement contract. This slide includes a link to OJP's websites with resources you can use, including a checklist, to make that determination.

This slide summarizes the procurement contact requirements and includes links to the full requirements. Two things to highlight include the requirement to seek prior approval from OJP for a sole source contract over $250,000. The DOJ Financial Guide includes the criteria for when this may be allowable, a template for submitting your request to OJP.

The other point is that you need to follow your own agency procurement policies, but those policies must be consistent with the federal requirements and any contracts must include provisions required by 2 CFR 200 Appendix II.

This slide lists some but not all the requirements related to subawards. This includes assessing the risk of all potential subrecipients before issuing subawards, including all required information in the subaward agreement and passing on award conditions to them, as well as monitoring all subrecipients to route the subaward period. And to pass through Entities, you must have policies and procedures in place for making and monitoring subaward agreements consistent with federal requirement, which are linked on the slide.

Character entities are required to report any subaward in the amount of $30,000 or more in FFATA reporting portal. You must submit the FFATA report regarding a subaward the month after entering into the agreement. This slide has links to the site as well as additional information.

On this slide, I highlight a few other administrative requirements that may apply to your award. The first one applies to all awards, and that is your responsibility to report any waste, fraud, abuse, or other misconduct related to the grant. Projects with participating minors will require your agency to make determinations on the suitability of any employee working with them. See the link on this slide for additional details.

Ted, already covered the requirements related to research. The last three bullets related to BJA requirements for certain costs or activities as well as publications funded under your award. Again, please refer to your award agreement and the conditions. I understand that the grant administrative requirements can be overwhelming, especially to new grantees. So, at this point, I wanted to reassure you that your Grant Manager is here to help navigate through them. Please reach out to us with any questions.

You can request changes to your grant award as needed. In JustGrants, they are called Grant Award Modifications, or GAMs. Nicko mentioned the Budget Clearance GAM earlier, which is a GAM that must be initiated by OCFO. The types of GAMs that you can initiate are listed here. Only the Grant Award Administrator or the GAA on your award can initiate a GAM. It is a good idea to run any proposed changes by your Grant Manager before submitting the GAM.

Since your Byrne Discretionary Grant Program is funding specific projects according to the details published in the public law, there are limitations on the changes you can propose.

This slide includes language we included in the solicitation. Basically, you cannot change the purpose of a project, such as the costs or activities do not support the programs that are listed in the public law. You can make changes to the costs and activities if they clearly support the project that was funded. We give two examples here.

In the first, the proposed change is clearly a change to the project purpose and would not be allowed. However, in the second, the proposed changes are clearly in support of the project and therefore can be approved. Again, reach out to your Grant Manager to discuss any changes.

The uniform requirements and OJP policy generally limit grants to one project period extension not to exceed 12 months in duration. It must be requested at least 30 days in advance. Cannot be requested only to expend the remaining funds and the recipient must not have any serious performance or compliance issues. OJP will make exceptions to this policy on a case-by-case basis if there are extraordinary circumstances that cause additional delays.

OJP conducts compliance monitoring on all of its grant awards. We do this in our dayto-day review of reports and GAMs, talking to recipients, and in completing test reviews. We also select a certain number of awards each fiscal year to conduct in-depth monitoring, which is completed either onsite or remotely. The purpose of in-depth monitoring is not to be punitive. It is to assist our grantees in properly administrating the award and being successful in meeting program and project goals. It helps maintain the integrity of our programs to ensure the public is receiving the benefits intended. If your award is selected for in-depth monitoring, you must work with OJP to provide the necessary documentation and communicate with us throughout the review.
This slide lists common issues that we identified during in-depth monitoring and that require resolution. Occasionally, resolution will involve returning funds to OJP or, in rare cases, suspension, termination of the award. In most cases, they can be resolved with additional documentation and/or updates to your agency's policies.

Once the grant project is completed, it is time for the final stage of the grant lifecycle, which is closeout. This consists of completing all obligations for project cost within a project period. After the project period, you have up to a 120 days to liquidate remaining funds for the costs that was properly incurred before the end date. You will need to submit the final performance report and final FFR in JustGrants and complete the final drawdown of funds in ASAP, with the final balance matching the amounts reported on the final FFR. After this is completed, the Grant Award Administrator submits the closeout in JustGrants.

Note that as soon as the closeout is submitted, the ASAP account is suspended, which is why you should do this as the last step. The ASAP account will also be suspended if the closeout is not submitted within the 120 days of the project end date, at which point, OJP will complete the closeout. If additional funds are owed to OJP or to you, OCFO will outreach for financial reconciliation. As a reminder, you do not need to wait until the project end date to complete the closeout. If the project is completed earlier, you should follow these closeout steps at that point.

On this slide, we include some helpful links, many of which were provided in other slides. You will receive copies of these slides with the active links as well.

Here are some additional links with a special note of the JustGrants training resources that are available. Thank you for your participation in the webinar. And, again, please reach out to your Grant Manager with any questions. I'm going to now turn it over to Michael Williams with OCFO, who will present the financial management information.

MICHAEL WILLIAMS: Thank you, Tammy. Good afternoon, everyone. My name is Michael Williams from the Office of the Chief Financial Officer. Let me say that I am confronted with a similar dilemma. I have more information to present to you than I have actual time. So with that, we'll make sure that we get it done.

What I would like to start talking about is what I'm going to cover in this particular presentation. I'm going to start off talking about the agency's requirements or your agency's requirements in reference to the entire grant program. I am big on internal controls so I'll try to go through that but I may spend some time on that. I want to talk about supplanting, how we look at an organization that may be supplanting federal funds with their own funds. And then I'll talk about commingling of funds, because this is something that we find from time to time. And then I'll wrap this up with subrecipient monitoring or your roles under subrecipient monitoring. Next slide please.

Again, I'm going to start off with the agency requirements. The agency requirements consist of the financial management system. The information here can be found in the Uniform Guidance under 2 CFR 200.302. With any accounting system, it is important that the system is designed where it can establish and maintain accounting records. Those accounting records need to be auditable. And what I mean by that that whether it's the auditor for your organization or the Office of Justice Programs coming out and looking at your program, we should be able to perform an audit or a trail of those funds that have went through your system. I always say when I talk about accounting systems, that there needs to be a process to the point where this information is being reviewed and approved prior to being inputted in the system, because I normally say bad information in the system will produce that bad information out. So, again, the information needs to be accurate.

One of the requirements under OJP grant programs is that those funds need to be identified in your accounting system separately. It cannot be shown with other federal grant programs. So, again, you want to make sure that these funds can be identified in your accounting system separately. There should be, in your accounting system, various types of accounting codes in order to do that. So, in other words, when I'm looking at your particular grant program, I need to be able to see the federal grant program's funds separately, any match that may be associated with that grant program separately, and then program income.

Program income can be generated intentionally with the grant program and in some cases unintentionally. So if that's the case, you always want to reach out to your Program Manager and discuss ways of spending that money. If not, then you'll need to return it. Next slide please.

This has already been covered but I'll go over it real quick too. When you receive federal funds, there is no requirement that you have to create a new or separate policy and procedures in order to implement the grant program. You should follow and maintain your own policy and procedures for the federal grant program just like you would for your own agency. The only thing that you have to keep in mind is that, yes, if this is the first time that you've received a federal grant program, it's more than likely that those federal requirements would need to be merged or incorporated into your current policy and procedures. I'd say that when you're looking at federal grant programs, you want to use the most restrictive policy possible. And, in most cases, it is always your agency's policy and procedures.

Here's what I mean by that. The federal definition for equipment is that the equipment must have a useful life of more than one year and an acquisition cost of $5,000 or greater. Based on the size of an organization, if we're looking at what, let's just say, a small nonprofit, the first part of that is probably correct, where equipment must have a useful life of more than one year. But based on the size of the organization, the second part may not be consistent with the federal guidelines. Their acquisition costs will probably be somewhere around what, $750, maybe $1,000. So that's what I mean when I say that you want to use the policy and procedures that is most restrictive. Next slide please.

The accounting system should be able to provide you the information that you need in order to do any type of reporting that you need. It is your responsibility with these funds to exercise the proper stewardship over those particular funds. And, again, you want to make sure that your accounting system is utilizing these funds or reporting these funds in the most efficient and effective manner as possible. Next slide please.

Again, the accounting system should be able to present and classify those costs. And that's what I'm talking about, those accounting codes within your organization. For the most part, what we normally like to see is, in the accounting system, that budget that you submitted, that information should be identified in the accounting system and then the actual cost that was actually charged against that program. So here's what I mean by that. In the accounting system should be the personnel cost that you identified in the application and then what you actually charge against personnel for that particular grant program. In some cases, there may be cost underrun or cost overrun. By identifying it in your accounting system, in that manner, you can determine whether or not you need to possibly move funds from another budget category into that particular category to accommodate that shortfall or you may need to move money out again to another budget category. Again, when I'm talking about this moving money, I'm talking about the 10% rule for those approved budget category. So keep that in mind too.

Again, if the federal grant program allows you to purchase equipment with the grant program, you want to identify this equipment separately from your own. Again, we're talking about what, accounting codes or barcodes associated with your agency that will be different from your agency, so you're able now to identify the federal equipment separately.

And then the most important thing, the accounting system must be able to identify those special conditions associated with the award. So here's what I mean. If there is a special condition on your award that says that you cannot expend, obligate, or draw down funds until something happens, your accounting system should not allow you to bring up that grant program and incur costs under that until you receive, and we talked about this—or you've heard about this in this session—a GAM in order to clear whatever that special condition is. Your accounting system, again, needs to be able to not allow you to incur costs if there's a special condition that has not been cleared yet. Next slide please.

Again, the accounting system should be able to provide you the information in order to meet any type of reporting requirement. So whether we're talking about the financial report and/or the progress report, that information should be pulled from the accounting system so that now you're accurately reporting to the federal agency what has transpired on that grant program. Your accounting system should be able to provide you with the information that you need in order to generate these reports to allow management to do any type of future planning or measuring of the success of that particular grant program. So, in other words, I'm saying that the accounting system should be able to keep track of all of that direct and indirect costs associated with that program. Next slide please.

I said all of that to say this: the heart of the agency, to me, is the financial management system. We are looking forward to be able to do three things: to keep track of receipts, all of the funds that come into the organization. The obligations. All of the obligations that have been charged against a particular grant, so whether we're talking about salary and/or equipment, those obligations. And then, ultimately, the expenditures or paying for those salaries or paying for that equipment. So the accounting system should be able to perform these three steps accurately within your agency. Next slide please.

Now I want to move on to talk about internal controls. Next slide.

Internal controls. I really like this clip art that talks about internal controls, because I believe it has all of the major components when we're talking about internal controls, but I would probably change this because I think that—I want to say it's out of order. And it's just me saying that it's out of order. But we want to start with the vision of the organization. What is the vision of the organization? What is it that you're in business to do? So whether it's victims assistance or law enforcement, that's the vision of that particular organization. Once we—or you've established that to me, I believe that we would want to jump down to risk assessment. And I'm saying that because once I understand the vision of my organization, what are those things that can hamper me from being successful? So that's why I said I would move risk assessment next. Once I understand those areas that can hamper my success, I believe now I'm in a better position to draft what I want to call quality policy and procedures for my organization.

Policy and procedures, and I'm always asked this question, how frequently should they be updated? I can't really answer that and I don't want to say that it will depend on the size of the organization but policy and procedure should be flexible enough whereas you can update them based on changes within your organization or federal grant program, whatever the case is. They need to be flexible enough in order to do that. Then we want to communicate these policy and procedures to our staff so that they understand the requirements for doing things within our organization and any repercussions that may happen, if they're not following these policy and procedures. Then we want to monitor what's going on with these policy and procedures, again, to see whether or not there needs to be any—policy and procedures. Next slide please.

When I think of internal controls, I'm always thinking about the segregation of duties. Not one person being responsible for any type of transaction from start to finish. I believe that strong internal controls can allow an organization to operate their business successfully. There is no guarantee that strong internal controls and people within your organization being savvy enough to, let's say, undermine them. It won't happen. But I think the stronger the internal controls, the frequency in which—that you look at them, puts you in a better chance of being able to truly protect those federal funds.

When I talk about segregations of duty, and I realized this, not every organization has enough staff where you can assign different folks to different components within any type of transaction. This is excessive but I'm saying this in order to hopefully drive home the point. No one individual within your organization should be responsible for generating a purchase order, contacting the vendor to purchase whatever that item is, receiving the equipment, let's say, once it comes in, paying for that equipment, maintaining that equipment throughout its useful life, and then ultimately disposing of that equipment. That is entirely too much control for any one individual to have within that organization, because as you can see, they now—have the ability to conceal or misdirect those federal funds, and that's something that we do not want to happen. Next slide please.

I truly believe that all of you have outstanding policy and procedures. I did include these two references here just as resources for your agency. If you have time, look at these. These are policy and procedures for the federal government. The first one we call the Green Book. And the next one, we call COSO which is the Internal Control Integrated Framework. So I think that these are two good documents that you can look at and then maybe information in there that could work within your agency policy and procedures. But, again, I included these strictly for resource material for you. Next slide please.

Now I want to talk about supplanting. Next slide.

When I talk about or think about supplanting, the deal is is that grant funds should be used to enhance or further what your organization is capable of doing and not replace. I'll give you an idea. When I think of grant programs, grant programs should be allowing an organization to bring up a particular program that's needed for their community that they have the funds for or bring up a program within their agency that they have funds for but not enough to actually address that particular issue. So that's what I mean when I talk about supplementing. So they apply for grant funds in order to do more. So grant funds should never replace your funds within your organization. One thing that I normally find that appears to be supplanting is that an organization applied for a federal grant program and then they moved a staff into that position in order to implement a work on that particular grant program. If you do not backfill that position where you move that individual from, that could be a potential case of supplanting. So, again, you always want to backfill. Next slide please.

So, in other words, the definition for supplanting would be to deliberately reduce your state or local funds just because of the existence of a federal grant program. And I also included an example here in order to give you an idea, again, of what I'm talking about in replacing. Next slide.

Now let's move in and start talking about commingling of funds. Now, when I think of commingling of funds, I think of there being good commingling or bad commingling, okay? So we always want to do good commingling. Here's the thing in reference to the Uniform Guidance. The Uniform Guidance does not specifically state that an organization needs to physically separate their cash deposits. Their accounting system—and I talked about the importance of the accounting system when I first began this presentation. The accounting system should be able to distinguish those multiple grant programs from each other. If that is not the case, and in some cases I've seen where the accounting system was capable but the organization wasn't using it for its full potential. So, again, if the accounting system is capable of separating those funds, you want to make sure that it's actually doing that. The recipient and/or subrecipient must, again, track these awards separately. Again, recipients and subrecipients are prohibited from commingling funds from either a program-by-program or project-by-project basis. So that means that even though I have similar grant programs, I will pull the funds from this particular program and put it on this particular grant program so I can bring this particular grant program up and running. So you can't do that under the commingling requirement. The deal is that funds specifically budgeted and/or received for one project must be used for that one and no other particular project.

So for recipient or subrecipients, automated accounting system does not comply with the requirements for separation of funds. The federal government does have the right to ask that you put these funds in separate accounts. Here's where we normally find the bad commingling, is that the organization, and based on ASAP, the funds that you can draw down from multiple grant programs are going all into one account. The deal is is that the accounting system should be able to identify that amount that was requested by you and distinguish the amount for each grant program separately that you drew down on those grant funds. If not, then the federal government will require that once those funds hit the financial institution, then you move the grant funds out and place them in a separate account. Next slide please.

Subrecipient monitoring. I think I'm doing good on time, so let's talk about subrecipient monitoring. Some of the things that Tammy had talked about kind of go in hand with this particular presentation. For subrecipient monitoring, the pass-through entity must have written policy and procedures for the entire life cycle of that particular subaward. So how will subawards be made? How—announcement and everything? How will they be managed throughout the entire life cycle of that? So that should be in your written policy and procedures. The most important thing is when we're passing money down to another organization—so this slide does talk about subrecipients but it's also applicable to contractors. You must go into SAM.gov and make sure that they are not suspended or debarred from doing business with the federal government.

I've always been asked this question because a couple times I've been confronted with grantees that initially looked in SAM.gov and made sure that the organization was not suspended or debarred but never went back in throughout the life cycle of that particular subaward or contractor. So, again, I encourage this for both. Somewhere throughout the life of that particular contract, I am really encouraging you to, at least, go in again and look and make sure that that organization is still in good standing because you may look at the beginning of your award program and that organization could be in the process of being added to the suspension and debarment. So I have dealt with a couple of grantees where that actually happened. Next slide please.

When you're doing subrecipient monitoring, you have to be mindful that this is an annual process. Why? Because you have to do a risk assessment of that portfolio. Based on that, there are subrecipients that come into your organization this year and then some that leave your organization. So that's why I say that this plan needs to be done annually because what you're looking at is the potential risk that that subrecipient organization could have on those federal grant funds. There are multiple ways to classify these but I listed here a low, high, and medium. So, you know, whether or not you're assigning a number factor to them, that's fine, but they should result in some type of low, medium, high ranking. The thing to keep in mind about the low, medium, and high, you have to come up with a monitoring plan for all three, okay? We're not doing monitoring for only the highs because the deal is is that we want to look at those folks that are in the low risk because we don't want them to move to medium. The folks that are in medium, we would like to look at them to move them to low and avoid them to go into high. And, naturally, we want to get the folks off of high to a medium and/or low.

So what are the different types of monitoring that you can do? You can either do onsite, and I know that a lot of folks are kind of leery about the onsite because of the pandemic situation that we're in, but that is an option. Or in-house or what we call a desk review. The Uniform Guidance does not specify any particular method here of doing monitoring but they're saying that, based on the risk assessment that you do, it should give you the information to determine whether or not you can be comfortable with doing an in-house desk review or whether or not you need to go onsite. The effect of doing this monitoring plan should give you the information, or hopefully it's given you the information, to determine whether or not there are some potential risks and some other things that you may need to do or add as a special condition to the subaward in order to, and I'll use this term, to keep that subaward recipient down the straight and narrow. Next slide please.

Again, in preparation for a review to do either a desk review or onsite, there are certain things that you want to look at. So, again, you want to look at the application. What does the subrecipient apply for, okay? Look at the written agreement. And I'll give you an example. It's important with the written agreement or that subaward agreement to cover yourself, to make sure that you put as much information that's going to cover you and the federal grant funds as possible.

I'll give you an example real quick of something that happened where this particular organization was very mindful of the information that they put in the agreement. I received a call from an individual who asked me to explain the 10% rule. So I went through the process of explaining the 10% rule and how it worked. So the person on the phone said, you know, I thought that that was the requirement, but the state said that I can only move 5%. So as the pass-through organization, they had that ability to reduce how much the subrecipient could move between approved budget categories. The only thing that I struggled with was how did a subrecipient receive my telephone number and call me? Look at the progress report and financial report prior to going out there or that's what you're going to be doing, doing a desk review. And then the history of payments with the subrecipient. Are they drawing down enough money or what's the status of that particular program?

And then you want to look at any audits. When you're looking at audits, the most important thing that you want to look at is what I call cross-cutting issues. In the audit, there may be something that is specific to a program, and let me give you an idea. Let's just say that there's a finding that is specific to an HHS award. So that wouldn't have any impact on the DOJ grant. However, let's just say that there is an audit finding that I consider cross-cutting, that they're saying that the organization accounting system lacks the proper ability to keep track of several funds. So even though it was noted on an HHS grant, that is something that also can filter over to an DOJ grant program.

Again, the results of the review should allow the organization to come up with any additional requirement that need to be imposed on the subrecipient. Next slide, please.

Just as a best practice, whether we're talking about a desk review and/or site visit, these are some things that you want to keep in mind. You always want to notify the subrecipient that you're beginning a desk review or you intend to come out and look at that particular program. Number two, entrance conference. So if I'm coming out, I want to make sure that I have an entrance conference with those folks that need to be in the room so that they understand why I'm out there, what I'm going to be looking at, and my estimated time in order to do that.
Supporting documentation, want to make sure that the subrecipient has the proper supporting documentation to justify all the cost that's been charged back against the grant. If I'm on site, I want to do an exit conference. If there's any outstanding issues that are not resolved by the time I leave or at the end of my desk review, I need to do a follow up, so I need to make sure that the subrecipient knows what these discrepancies are and how to go about resolving that. I'm going to be looking for number six, a corrective action plan from them, in order to do that. And whenever I'm talking about a site visit and/or desk review, once everything has been resolved, I can now close out that review. Next slide, please.

Good. That concludes my presentation and I'll be around to answer any questions at the end. Thank you. Turn it back over to the host.

DARYL FOX: Okay. Thanks so much, Michael. Yes. We're just transferring to—now going to the JustGrants portion of the presentation. Bridget Mealia will be leading that effort. Just getting her set up here.

BRIDGET MEALIA: Welcome to the Fiscal Year 2022 Byrne's Discretionary Grant Program Training session. We hope to provide you with foundational knowledge about accepting your award, onboarding key users, and managing post-award activities. The session is being recorded and the recording will be available to you after the session.

The purpose of today's discussion is to learn more about how to onboard users and manage critical tasks for your award using JustGrants. We will discuss Award Acceptance and take a look at Onboarding a Grant Award Administrator and a Financial Manager. We will briefly review ASAP Enrollment and direct you to training resources on that subject. We will look at the Federal Financial Reports, as well as Grant Award Modifications. Lastly, we will show you where to go for help as you navigate through JustGrants.

During the session, we are eager to address any questions you may have related to the JustGrants system, the roles and processes to accept and maintain an award, or other general questions related to JustGrants.

Please use the Q&A function to submit your JustGrants related questions, and we will do our best to address as many of those questions as possible. If you will be receiving funding, your entity will need to formally accept the award to begin using those funds. Accepting or declining funding is the sole responsibility of your organization's Authorized Representative. The Authorized Representative must be legally authorized to enter into an agreement with the Department of Justice and will be responsible for agreeing to award terms and condition.

Let's look at the process now. When an award is ready to be accepted, the Application Submitter, Entity Administrator, and Authorized Representative will receive an email that has an award has been made. In addition to receiving the notification email, the Entity Administrator will also be the first Entity User to take action on the award by assigning the appropriate people to the award. The Entity Administrator must verify the correct Authorized Representative is assigned to the award so that the award can be accepted or declined.

Prior to the Authorized Representative being able to accept an award, the Entity Administrator must assign a Financial Manager, a Grant Manager, and a Grant Award Administrator, and review and confirm that the Authorized Representative assigned at the time of the application is still correct from each award. The person assigned as the Authorized Representative must have the authority to accept an award on behalf of its entity. This includes binding the organization to the terms and conditions of the award. The award is accessed from the Entity Administrator's worklist. The award notification email is the indicator that the Entity Administrator must sign in and begin the acceptance process.

The award review and acceptance process takes place within JustGrants. All of the award package information is available on one screen. The award acceptance status is an important indication of work that may need to be completed prior to accepting the award. Here are the status codes and what they mean.

Pending-Award External Assignee. This indicates that the EA, your Entity Administrator, needs to assign a Financial Manager and a Grant Award Administrator and review the status of the Authorized Representative.

Pending-Award Acceptance. This status indicates that the Entity Administrator made all of the needed assignments and the funded awards and is now routed to the assigned Authorized Representative for award acceptance. The Authorized Representative can locate and view the award in their worklists.

Next, Pending-Account Creation. This status indicates that the Authorized Representative accepted the award, which triggers a notice to the automated Standard Application for Payments, or ASAP, for award account creation. Grant funds are deposited in ASAP so that grantees can make payment requests. ASAP is not a JustGrants function. It is a separate system managed by the Department of Treasury. So any questions about ASAP must be directed to the Treasury. We will provide information how to access ASAP training and help in this session.

Pending-ASAP Enrollment. This indicates that your entity is a new ASAP user and is a receipt of DOJ funds. Typically, this is performed by the person in your organization primarily responsible for drawing funds.

Pending-Active. This status indicates all technical aspects have been completed. At this time, the Grant Award Administrator should review all award conditions to see if there are any items need action by the recipient. Please note, this does not mean you can begin activities. The Grant Award Administrator should monitor their worklist for a change requested budget. Contact your DOJ Grant Manager before obligating, expanding, drawing any funds, or starting any activities. Please remember accepting or declining an award can only be accomplished through JustGrants.

Let's go through a demonstration of the Award Acceptance Process. For awards with a Pending-Award External Assignee status, the Entity Administrator needs to open the award, review the current assignees for each role, and make appropriate updates. If logged in, the Entity Administrator is not the person listed as the correct Entity
Administrator for the award, you will need to contact our Technical Support Office for assistance.

After the award has been opened by the "Begin" button in the Entity Administrator's worklist, the Assigned Contributors page opens. If all the listed roles are correct, click "Submit" button and the bottom of the list. To update roles, select the title of the role to be assigned from the Assigned Contributors dropdown list. A new role will populate the list if a contributor is not already assigned to that role. Select the user that you want for the role and click the "Okay" button associated with that line. If a role was assigned incorrectly, select the new user and click the "Okay" button. When all roles have been assigned, select the "Submit" button at the bottom of the list.

VIDEO DEMO: The Authorized Representative that's been assigned to an award will receive the award in their My Worklist. They'll need to click the case ID to open the award package. Once the award package opens, they have to review each section of the package and agree to each section separately. First section will include the award letter. Then they'll see the award information followed by the award details. After reading through this information and confirming that it is correct, they'll see a checkbox at the end of the section. They'll need to click that checkbox to indicate that they agree that the information it contains is correct.

Next, they'll need to read through the project information. After reviewing the information it contains, once again, they will need to click the checkbox to indicate their agreement that the information it contains is correct.

Next is the financial section. This includes the current budget. You can open a caret next to a budget category in this Budget Detail View. This will allow you to see a list of line items that are associated with that specific category. In this particular case, let's take a look at the Travel section.

Once you have reviewed this information, you need to check the box to indicate agreement that the information it contains is correct. Next, you'll need to review any attached documents, any other awards, documents section. Then you need to be sure to read through each of the award conditions. You need to agree to all of the conditions as a group. You will not be able to agree to some and then not others. Following this, you'll need to check the box at the end of the section to indicate agreement.

The final section is Award Acceptance, and the example shown here is specific to the Community Oriented Policing Services, or COPS Office, which typically requires two Authorized Representatives to accept an award, or packages for OJP or OVW will only display a single Authorized Representative. Once you check the box indicating agreement, your name and contact information are going to appear as the person accepting the award on behalf of your entity. Now, if you wish to select "Decline," a popup window will appear asking you to enter a reason that you wish to decline. But if you choose to accept the award, you select "Accept." For COPS Award, the next Authorized Representative will be expected to open the award package and accept all sections as done here. But for all OVW or OJP awards, accepting the award this one time will change its status depending active, and you will begin to be able to manage your award.

BRIDGET MEALIA: One step that is often missed when onboarding a user is assigning a user to a specific award or application. Without this step, the user will not be able to take action in JustGrants.

VIDEO DEMO: This is a critical step that does get overlooked, but it's fairly simple to resolve. The Entity Administrator that will make these assignments from the awards menu on the left, the Entity Administrator will see the Show/Hide roles at the top of the list. It can select the three required roles, Grant Award Administrator, Authorized Representative, and Financial Manager. They submit this request, they're going to see columns for each of these roles appear next to each award. They can locate any awards that contain missing information. Bottom of the screen, you'll see the roles that you wish to assign. And once you select the role, JustGrants will provide a list of users that have been assigned that role. Then you can select the user you would like to assign to the award and click the assign button.

Now, in this particular example, there's also a Grant Award Administrator missing. Once again, you can select the user that we wish to assign to this award and then click the "Assign" button. Now, if someone is leaving and you wish to assign multiple awards to another person, you can do that as well by selecting multiple awards at once and then clicking to make the assignments.

BRIDGET MEALIA: All previous Grant Management Systems, processed award acceptance using a file upload, JustGrants does not work that way. In JustGrants, you must follow the steps shown in the previous demonstration since JustGrants does not process award acceptance using file uploads. It is a fully digital process that uses the Authorized Representative's electronic signature to complete.

So what happens if an Authorized Representative does not see an applicant in their worklist? This means it's not assigned to them and that the Entity Administrator must assign the application to them. Also, what happens if an Authorized Representative changes between the time of the application submission and award work receipt? The Entity Administrator will need to update the Authorized Representative in JustGrants. However, no grant adjustment is needed. The Entity Administrator will need to either invite the new Authorized Representative to join the JustGrants system as the signing authority for the organization, or add the Authorized Representative role to an existing user's profile if they have the authority to serve in the Authorized Representative role.

After being invited, the new user creates and authenticates their new account. The new user will appear in JustGrants and the Entity Administrator will be able to assign the users to their Authorized Representative roles to accept the award. The users accepting the award will be shown on the award package details.

Next, let's go over ASAP Enrollment. The Department of Treasury's Bureau of the Fiscal Service, ISIM PP, will send two emails to the entity's System for Award Management, SAM, Electronic Business Point of Contact, E-Biz Point of Contact, one contains a username and the other contains a temporary password and a link to create a new password. After receiving both emails, the user must complete the following steps.

One, use the provided username and temporary password to log in to the ISIM system to change your password and complete the security questions. Two, log into ASAP using your username and new password. Three, accept the ASAP terms. Four, select "1 notification awaiting review." Five, select "Unread" from the Notification Status drop-down menu, then select "Continue." And six, select the magnifying glass on the right side of the screen to view the Enrollment Notifications. To learn more about the ASAP registration process, please see the ASAP Registration Checklist. Now let's look at accessing financial reports from My Worklist.

VIDEO DEMO: Only financial managers submit FFR's. So, all current FFR's appear in their My Worklist to make them easy to locate. To complete an FFR, select the one that you're working on from My Worklist by clicking the Case ID. That FFR will open in edit mode automatically. This first page of the FFR is read-only information pulled from the Entity Profile. Want to verify their award number in the second entry and review the rest of the information for answers.

Let's review. You can either select the "Continue" button or you can scroll up and click the "Report Information" tab at the top of the page. Either option will open the next page of the report. Now the Recipient Account Number is an optional field and it's reserved for an identifying number that's been assigned to the award by your organization. The Report Type will default to either Quarterly or Final depending on the grant period for which it applies. And you want to select the Basis of Accounting. Then you'll find the Reporting Period indicated in item nine.
Now the DOJ does not use the Federal Cash section of the report. So as we scroll down, you'll see that those entries are grayed out. Now you'll notice next to item 10e that there's a red asterisk. A red asterisk indicates a required field. All entries in this report are also cumulative. You'll also notice as entries are put in here that JustGrants automatically performs calculations based upon those entries. Now if you need to enter Indirect Expenses, you can select the Add button.

You’ll need to enter the information in all fields for each of the Indirect Expenses for which you're reporting. As we go through this, you can notice once again that JustGrants will do all the calculations for you. You can see here the JustGrants has done the calculation based upon that base amount. Now when you're finished entering your totals, you can select the "Continue" button and that will enable the last page of the report to open. Here you'll see the Additional Information field which allows you to add comments as needed. The section of the report also allows you to upload any supporting documentation.

As we move to the Certification section, you'll notice that this section displays the information for the financial manager that's filling out the report. When you click "Submit," you'll see that that report moves from Pending UFMS status to UFMS. UFMS is the DOJ Financial System. All FFR's are validated in the financial system prior to being routed to the Grant Manager for review. You'll typically see the FFR stay in this status for about 24 hours. Once again, we want to remind that all totals here are cumulative. That means from the beginning to the end of the reporting period. Now again, cumulative expenditures must be put in those 10e, 10j, 10f, 10m, and 10n lines.

BRIDGET MEALIA: It is important to remember that all entries in the Federal Financial Reports are cumulative. When entering data in field 10e, there will be a pop-up that appears confirming that you have entered a cumulative total. If you answered yes to this question, indicating that you did enter a cumulative amount, you'll be directed to the next data field. If you have not entered a cumulative total and answer no, you will be directed back to field 10e to correct that. If the amount that entered in 10e is less than the previous reported amount, you will receive a message indicating that you will need to be sure to correct that the amount is correct. If it is, you will be required to provide an explanation in block 12, which is a text box labeled Additional Information.
To locate a list of pending and submitted financial reports, open the Funded Award and navigate to the Federal Financial Report section. You can open any report by selecting the "Report Number" in the left column.

Now, let's take a moment to discuss Grant Award Modifications, also known as GAMs. Grant Award Modifications are completed and submitted by the assigned Grant Award Administrator on the award. All GAMs must be approved by DOJ personnel. One of the questions we get from grantees is, “What type of GAMs can be submitted in JustGrants?”
There are three types of GAMs, Programmatic, Financial, and Project Period Extension. There are two types of Programmatic GAMs, which are Scope Change and Programmatic Cost. And there are also two types of Financial GAMs, Budget Modifications, and Sole Source GAMs. Finally, there is a Project Period Extension GAM. This modification type is typically used to request an extension on a project end date.

Another question we receive is, “How can a grantee initiate and submit a GAM?” Again, GAMs are initiated and submitted by the Grant Award Administrator. You must open the Funded Award and navigate to the Grant Award Modification tab to initiate a GAM. Once the GAM has been initiated, it will appear in the assigned Grant Award Administrator's Worklist for updates or further work. In some cases, DOJ personnel can initiate a Grant Award Modification on behalf of the grantee. However, it is expected that grantees will be the primary initiators of any modifications to the award. So how do you initiate a GAM?

VIDEO DEMO: As we saw, there are multiple types of GAMs. And in the interest of time today, we're going to demonstrate how to initiate any type of GAM, and then we'll show you the Budget Modification GAM specifically. Now, all GAMs are initiated from the Grant Award Modification tab of the Funded Award. Now again, before this option is available, all of the required roles will need to be linked to the award as demonstrated earlier. And when you open the GAM Selection drop-down menu, you'll see three types of GAMs available. When you select either Programmatic or Financial, a Project Period Extension GAM will open when you select that, although there are some validations that happen upon selection. Now you'll notice in this case that the award is less than 30 days from the project period end date. Now in this case, your Grant Manager will actually need to initiate it. Now it's also notable that if a GAM is in process, you will not be able to initiate a new GAM of that subtype until the one in progress has been resolved.

BRIDGET MEALIA: Now let's take a look at Submitting a Budget Clearance Grant Award Modification.

When a Grant Award Administrator locates a Budget Clearance GAM in their worklist, they must open the GAM to update the budget. Use the "Sort and Filter" feature to locate the GAM and then select the Case ID link to open it. Navigate to the Grant Management Comment section to see what changes were requested. Navigate to the Budget Detail Summary View and open the caret corresponding to each category to “Edit Line Items.”

Once you open the line item that needs to be edited, you will be able to modify the content of the line item. You can add a new Line item by selecting the "Add" button. To delete a line item, select the Trash icon. Information in Additional Narrative field is required for any budget category with a line item. Navigate to the bottom of the Budget screen and select "Save." The Budget Summary will automatically update with any changes made in the Budget Detail Summary View. Navigate to the Total Project Cost section and revise Federal Funds, Match Amount, or Program Income Fields as necessary. Note that the Federal Funds, plus Match Amount, plus Program Income Amount must equal the Total Project Costs.

Navigate to the Budget Financial Document section to upload an attachment. If necessary, then select either Entity Doc to upload an attachment from your entity's document library or Upload Doc to upload a document from your computer.

If Entity Doc is selected, the Attach Entity Document window will appear. Select the checkbox corresponding to the document and then select "Submit." If Upload Doc is selected, the “Attach Files” windows will appear. Use the “Select Files” option to choose a file from your computer. Select the “Document” category from the “Category” drop-down. Please note, the category selection should match a category displayed in the GAMs.

Except for the Additional Attachments section, if you want to upload a document to the Additional Attachments section, select the Budget Other category. Select "Attach," the attachment will appear in the corresponding section. Select "Submit," the GAM will appear in the assigned Grant Manager's worklist for review. Note that the Grant Award Administrator will receive an email when the GAM is approved and we'll be able to view the GAM in the completed GAM section.

We hope that you have gained insight from the material we've presented today. Before we close, we would like to provide you with additional resources to guide you through the process.
Enabled within these slide decks are links to all of the information covered today. The Justice Grants website houses all of the training material that you will need to work your way through JustGrants. We have placed direct links here to Entity Management and experience, as well as the User Role Guide, which can be found on the Justice Grants website. If you are an applicant or an award recipient for an OVW award and need assistance, email the OVW Support Desk at [email protected], or call 866-655-4482. To contact the JustGrants Technical Support Desk, email [email protected], or call 833-872-5175 Monday through Friday from 5:00 AM to 9:00 PM Eastern Time, or on weekends and holidays from 9:00 AM and 5:00 PM Eastern Time. Please use the JustGrants Support email or phone line for any issues you may have when working in JustGrants.

We've talked a bit about the online site for training material. This is what the JustGrants training website looks like. You can find a wealth of information about JustGrants at https://justicegrants.usdoj.gov/. We are going to focus on the training link today, but please take time to look through the website for useful information.

When you open the training link, you will see a list of training topics displayed. Not all topics apply to everyone, so use the helpful table on the right to see which topics apply to you. It's a good idea for everyone to start with the Entity User Experience Guide, which covers navigation in JustGrants. The Entity Administrator must become very familiar with the Entity Management Guide. Once you've selected a topic to explore, open the Training Resource page directed to that topic. Typically, you will find a Job Aid Reference Guide, or JARG, and links to step-by-step videos. These are short videos. They are meant to be used when you are working so you don't feel like you need to set aside time to view them. They can be helpful if you're in the middle of a task in JustGrants and want you verify the next steps. JARGs provide step-by-step instructions with screenshots to help you complete a task. You can print the JARGs or view them on their screen, whichever you prefer.

We offer our virtual Q&A series every week. Use the links shown here for more information. Post-Award Management sessions are held on Mondays from 1:00 to 2:30 PM. On Tuesdays, we hold our Entity Management sessions, which primarily focus on topics for Entity Administrators between 2:00 and 3:00 PM. On Wednesdays, we hold our Application Mechanics sessions which focus on submitting an application between 2:30 and 4:00 PM. And on Thursdays, we offer sessions on Award Acceptance from 2:00 to 3:00 PM. All classes are on Eastern Time.

Thank you for attending today's session. We'd like to thank you for your participation and hope you have a great remainder of your day. Now turning it back over to the host.

DARYL FOX: Great. Thanks so much, Bridget, and thanks to all the panelists today. There was a lot of information to get through. Hopefully it was beneficial to everybody on today's webinar. Just a note, as mentioned earlier that everything will be sent to you and posted to the BJA website in about seven to ten business days, depending when those items will be available. So you'll be able to go back and reference everything that was discussed today. We do still have some time left scheduled to about 4:00 PM Eastern. So I know everybody's been entering questions in the Q&A panel. Thank you for that. And staff have been feverishly going through those and answering those as they best could. If you do have a question, enter it in there. We can perhaps ask it verbally and answer it here today.

Everything seems to have been caught up in the Q&A at this point. But hang on a few more moments. If you do have a question, please enter that in there. And if you could, as you enter those, if it's for the JustGrants team, if you could just put JG and then start your question, that'd be helpful and I'm parceling those questions out to all the panelists today.
There's a question I can kind of address to the panel, whoever would like to answer this. "It was said that performance reports may differ by program office. Is there instructions for the report content for each of those deliverables?"

ERICH DIETRICH: This is Erich. If you're an NIJ recipient, Ted presented earlier in the slides the format for the NIJ performance reports. If you're a BJA recipient, the performance report question sets will be in JustGrants when your first performance report is due, and that won't be until January, because the reporting period will run through December 31. But there will be an actual question set within JustGrants that you will fill out and submit. The basic information is in the solicitation if you would like to refer to that. And we may add additional questions depending on the nature of the project, but generally, it's going to stick to the performance measures that were in the solicitation. And like I said, they will be populated in JustGrants and you'll submit from your first performance report in January.

DARYL FOX: Okay. Thanks for that, Erich. Kathleen, good to see that you're able to see the questions and answers entered by everybody else, so hopefully that's helpful to
those because I'm sure a lot of the questions are going to be familiar and want to be asked by most of you all. And Jen, thanks for your question on OJP Financial Management and Grant Administration Training. Ted had answered that with the online, the actual URL for that training. We can go ahead and post that in the chat as well. So, Erich, this question may be relevant to many attendees today. It's been answered in the Q&A, but I'll just ask it for the record. "Are grants for procurement contract for body worn cameras, if the contract maintenance agreements extend past the grant period, are we able to get an extension on that?" And the answer…

ERICH DIETRICH: This is Erich. I'm sorry. Go ahead, Daryl.

DARYL FOX: No. Please. I was going to just read your answer aloud, but since you're— since you're on, go ahead.

ERICH DIETRICH: So you can request an extension just to make sure that the performance of the contract doesn't exceed the grant period. We do have the policy where you can request up to one time of up to 12 months extension.

THEODORE ROBINSON: Just a general additional guidance on this if I could jump in. I'm pretty sure the requirements, those request generally needed to put in with at least 30 days remaining in the project period so you don't want to be putting that in right at the last minute.

DARYL FOX: All right. Thanks for that clarification, Ted. This question has been answered, but "What's the funding period?" That's just a general question that could be answered.

THEODORE ROBINSON: That'll be listed on the award package as the project period. But it's going to vary from project to project. In relation to the question about completing the training, what's the date—the date in which, you know, the training had been completed by that date, and it was still valid. It's only valid for a certain amount of time. But let me find that exact date, give me one minute. Sorry. I don't have this right in front of me right now. So, if you've completed the previous training courses on or after January 1st, 2019 will satisfy the conditions. So if you completed it in 2020 for your question, you should still have the certificate. If not, we might be able to pull up a record of completion of it. But just I would suggest following up with your Grant Manager on that.

DARYL FOX: This question came in. The original grant applicant is no longer at the agency. So, the person is wondering, “How soon can I, the new administrator, need to submit a budget adjustment?”

THEODORE ROBINSON: Wait a second, I'm going to find the—let me look at this question again. Sorry.

DARYL FOX: Ted, it's in the chat actually.

THEODORE ROBINSON: So that makes sense. Let me see here. The original grant applicant is no longer at the agency. “How soon can I, the new administrator, need to submit a budget adjustment?” So that depends if the budget has already been reviewed and approved by our OCFO. I know at least for the NIJ Awards, they have not all yet been reviewed. I don't know about your particular work, so it's probably likely still waiting for our Financial Office to take a look at the application. At which point you'll be contacted to submit for the budget changes to, based on their comments, or there's a possibility that they approve whatever has been submitted with the application. You likely need to wait for OCFO to complete review of the application.
If they've already completed their review and that they've requested that you address things related to the budget that was submitted with the application, you can submit that to the Grant Manager or to the OFCO person, I believe, just do it quickly. It's always better just because, especially this time of year, everybody tends to get a little bit pretty busy as this isn't really our prime award making season. So, if you have to respond to requests to changes on a budget, it's always better to do that sooner rather than later.
But at least for the NIJ Awards, I can only speak to those, I know we're still waiting for the Financial Office to review them. So, I hope that's helpful. But original grant, I would recommend, you know, I'm sure that the appropriate officials are assigned for the applicant or whoever is left is making sure that you have that spot filled with somebody who's going to be in there so they can continue to receive all the notifications and updates through JustGrants and all that kind of stuff. I would, again, sort of recommend getting in touch with the Grant Manager.

DARYL FOX: And the next question that's come in, "Can we assign more than one Financial Manager on an award? And is that done through ASAP?”

THEODORE ROBINSON: Goodness. I'm pretty [INDISTINCT]

ERICH DIETRICH: Hi, this is Erich.

THEODORE ROBINSON: Please go ahead.

ERICH DIETRICH: You can have multiple financial managers with that role in your organization, but only one of them can be assigned to the grant. But you can have multiple people signed up as a Financial Manager and reassign them so that they can do different parts of the work. And that's not done in ASAP, that is done in DIAMD and JustGrants. ASAP has its own rules, though, as far as people that can draw down funds. You can have multiple people in ASAP to draw down funds and you would do that in ASAP.

DARYL FOX: This is likely a question for the JustGrants team. Particular person grantee cannot find their submission in JustGrants. Who do you recommend they contact at email or phone to resolve that issue?

THEODORE ROBINSON: Not sure what submission it might be in reference to. I would be [INDISTINCT] to say there was always the first step because they at least [INDISTINCT] make sure you get in touch with the right person.

DARYL FOX: Your audio was a little cut out at that point, just the ending part of [INDISTINCT]

THEODORE ROBINSON: I'm sorry. I'm not sure exactly what submission that might be referring to. If he could clarify, I can get more info. But I would say, yeah, just contacting the Grant Manager is always a good first step. So they can at least direct you to the right party in most cases. Anthony, I would suggest contacting the JustGrants Help Desk, most likely. They can probably dig it up and figure out where it is exactly. And I'll put their contact info into the Q&A here.

DARYL FOX: Okay. We have a few more moments in. And thanks, Ted, for putting that in. So, yeah, the number's 833-872-5175 or you can email them at [email protected] for that question, particular Anthony finding that submission. We have a few more moments as we are doing. Please go ahead and ask your question in the Q&A. At the moments we have left, we are certainly glad to answer those. And once we do conclude, if we haven't got your question or think of something afterwards, you can certainly follow up with program manager or the JustGrants Support Desk as listed. And as mentioned again, the PowerPoint, recording, everything we've gone over today will be sent to all the registrants registered with and posted to the BJA website. Okay. That seems to be the end of the question queue at this time. I'll go ahead and turn the other program [INDISTINCT] all right?

THEODORE ROBINSON: I'm sorry.

DARYL FOX: Is there anything in closing? Oh, Ted, did you have something?

THEODORE ROBINSON: All right. So I saw Roxanne Ramos had a question about vendors in SAM.gov. Being suspended or debarred. I'm not sure if that had been answered. If a party is suspended or debarred, they are immediately listed on SAM. So you probably should do your due diligence on it. But if they aren't listed on there as suspended or debarred, you should be okay under most circumstances.

DARYL FOX: And related to—"Is there a procedure for excluded entities in SAM.gov?”

MICHAEL WILLIAMS: Sorry, you said for SAM.gov, is there a procedure?

DARYL FOX: To look for excluded entities, just referring to the…

MICHAEL WILLIAMS: There’s a a link on SAM.gov known as the Excluded Parties List from federal contracts. So you have to go in SAM.gov, pull up that particular link, and then the process to me is pretty easy. So you're just putting in the individual or agency's name. If nothing comes back, then that's what you want because that means that they're not in the system. For most audit requirements you want to print that page as proof that you did go in and look, and then if the person is in there, then naturally you can't do business with that individual or organization.

DARYL FOX: Thanks for that, Mike. Okay. So with that, we are at time today. Erich, is there anything in closing you wanted to mention before we close the program up?

ERICH DIETRICH: No. I just wanted to thank everybody for participating. And, again, if you have any questions, try to go to your grant manager that's assigned to you at JustGrants, also on your award record. Feel free to reach out to me, too, if you're having trouble with something. And I want to thank all participants and you, Daryl, for presenting here today. Thank you so much.

DARYL FOX: Wonderful. So on behalf of the Bureau of Justice Assistance and our panelists, we want to thank you for joining today's webinar. This will end today's presentation.