FY 2023 Byrne Discretionary Grant Program: New Grantee Orientation
During this webinar, which was held on August 29, 2023, Bureau of Justice Assistance personnel provided information about the Byrne Discretionary Grant Program to new grantees. A demonstration of JustGrants system features and functions was also provided.
Transcript also available as a PDF.
DARYL FOX: Good afternoon, everyone. And welcome to today's webinar, FY 2023 Byrne Discretionary Grant Program, New Grantee Orientation, hosted by the Bureau of Justice Assistance. At this time, it's my pleasure to introduce Erich Dietrich, Division Chief of the Program Office with BJA to begin the presentation. Erich?
ERICH DIETRICH: Thank you, Daryl. Hello, all, and welcome. Most of you know me already but to reintroduce myself, I am Erich Dietrich, Division Chief in the Bureau of Justice Assistance, BJA. And I'm the Program Lead for the Byrne Discretionary Grant Program.
In addition to myself, BJA Grant Managers Nicko Taylor and Tisa Muhaddes will be presenting the Grants Management Overview content, and Lisa Hartman with the JustGrants Training Team will cover some JustGrants demonstrations.
These are the topics we'll cover today after I complete this introduction and welcome to OJP and BJA. I will briefly cover the program and the BJA Grant Manager roles. Then I'll turn it over to Nicko and Tisa for the core content of the presentation. The JustGrants Training Team will then demonstrate some actions in the system. We will share resources throughout the presentation in the slides but, at the end, we'll have some more to share.
As Daryl mentioned, you can put your questions in the Q&A function during the presentation, but we will also conclude with giving you an opportunity to ask additional questions. The slides and the recording will be posted to our website later.
The Office of Justice Programs is one of three grant-making components of the Department of Justice along with the Office of Violence Against Women, OVW, and the Office of Community Oriented Policing Services, or COPS. OJP provides grant funding, training, research, and statistics to the criminal justice community nationwide. The Bureau of Justice Assistance is one of the six program offices under OJP, which are also listed on this slide.
BJA was created in 1984 to reduce violent crime, create safer communities, and reform our nation's criminal justice system. BJA strengthens the nation's criminal justice system and helps America's state, local, and tribal jurisdictions reduce and prevent crime, reduce recidivism, and promote a fair and safe criminal justice system. BJA focuses its programmatic and policy efforts on providing a wide range of resources including training and technical assistance to law enforcement, courts, corrections, treatment, reentry, justice information sharing, and community-based partners to address chronic and emerging criminal justice challenges nationwide. Karhlton Moore is the Director of BJA.
BJA supports the criminal justice field in a variety of ways: of course directly, through our grants and cooperative agreements, but also by educating and providing training, researching and publishing what works, and consulting with convening stakeholders across the criminal justice spectrum.
At this point, we will pause for a poll that will launch in Webex. We're interested in your agency's past history with federal grants. Daryl will launch the poll, so please answer it — the questions within the — within the Webex pop-up and we'll give a few minutes to see the results.
Daryl, you can judge whether we're getting responses starting to trickle in. Feel free to close it whenever you want.
Okay. Looks like a fair number of you with past grant experience but quite a few of you — which is not surprising — with little or no experience. So this is a good opportunity. Good thing we're having this webinar to cover these topics. Thank you all for your responses.
Daryl, did you want to move on to the — to the next section?
DARYL FOX: Technical glitch on my end. I'm just negating it as we speak. Okay. There we go. Sorry about that.
ERICH DIETRICH: No problem. Thank you. In this next section, I will — I'll briefly go over the program under which you are funded and do a brief intro into the role — into the roles that Nicko and Tisa will discuss in the grants management content.
The full title of the program is the Byrne Discretionary Community Project Grants/Byrne Discretionary Grants Program. So understandably, we usually use the shorter version, and you also may hear the terms “congressionally directed” or “earmark,” which have also been used historically to describe the program.
Last year, members of Congress solicited community projects in need of funding from their constituents. And after a lengthy review and budget approvals process, the program was authorized, and funds were appropriated upon the President's signing of the 2023 Consolidated Appropriations Act. On this slide, we include the language from the act. The first thing to note is that funding was appropriated as a grant program, which is the reason that you had to submit your application to us even though you had already submitted another application to your sponsor. We needed a federal grant application so we could issue the grant award for the appropriated project.
Second, the purpose of the funding must be used to improve the criminal justice system to include juvenile justice and victims of crime. The bolded and underlined statement emphasizes that only the projects designated in a Joint Explanatory Statement or JES can be funded and only in the amounts listed. I'll go into that more on the next slide.
This slide has an image taken directly from the Joint Explanatory Statement or JES and it has the project titles and the amounts circled. This is the information that is incorporated into the public law. We will emphasize throughout this presentation, as we did during the application webinar and the solicitation, that funds can only be used for costs and activities that clearly support the project title as listed in the public law. This is a matter of public law that cannot be changed.
Moving on to some slides to give you background on roles you will hear about during the presentation. Your BJA Grant Manager, which is listed in your award — in the award record in JustGrants, is the primary point of contact for you. The BJA Grant Manager is there to provide assistance and to review and approve grants management actions that you submit, such as reports and award modifications, which we'll discuss in detail later. And they will also connect you to resources you may need to help in the management of your award. The BJA Grant Manager will help ensure your project is successful but also stay as compliant with the award conditions and administrative requirements from start to finish.
Another office we mention frequently is OJP's Office of the Chief Financial Officer or OCFO. OCFO provides grants financial management support to all of OJP and its grantees. Specifically related to your award, OCFO will be involved in clearing the budget — which we'll discuss later — any additional changes to your budget, and the financial closeout, just to name a few. OCFO's customer service contact information is listed on this slide.
By now, you are hopefully familiar with the roles in JustGrants that individuals from your agency will fulfill in acceptance and management of the grant, but we've included them on this slide since we will be mentioning them often. The Entity Manager — or Entity Administrator is usually the same person as the SAM electronic business point of contact, will manage the roles in JustGrants, such as inviting new members and assigning them to the award. The Authorized Representative is the person with authority to sign award agreements on behalf of your agency and must complete the award acceptance in JustGrants. The Grant Award Administrator or GAA will be your main point of contact for the award, and they will be responsible for submitting performance reports, award modifications, and the closeout in JustGrants. The Financial Manager will submit the quarterly financial reports.
An individual can serve in multiple roles in JustGrants, if it is appropriate based on your agency's needs and requirements, with the understanding that you will be maintaining proper internal controls on all actions. Lastly, it is important that you keep the roles up to date in the system to minimize lapses in communication or access to funds. So if someone is planning on leaving, you should reassign the affected role or roles in advance. And with that, I'm going to turn the presentation over to Nicko Taylor who will start us off with the real meat of this presentation, that being the Grants Management Lifecycle. Nicko.
NICKO TAYLOR: Thank you, Erich. Hello. Hello, all and congratulations on your award. My name is Nicko Taylor, and I am a Grant Manager in the BJA Programs Office. I will begin the Grants Management content and then pass it over to my colleague Tisa. In this presentation, we will give an overview of the entire post-award grants management lifecycle, covering award acceptance, how to access funds, award conditions, and financial requirements. We will highlight some of the most important administrative requirements, to include the reporting. Additionally, we will go over the process for requesting changes, grant award modifications, and the monetary activities that OJP will complete on your award. And lastly, we will discuss the award closeout process when the project is complete.
When your agency accepts the grant award agreement, it is entering into a legally binding contract with the federal government. Therefore, it is important that you read the terms and conditions thoroughly before accepting the award. As previously mentioned, the Authorized Representative is the person in your organization with authority to sign and enter into a grant agreement. The Authorized Representative will accept the award electronically in JustGrants but before doing so, there must be some key role assignments made which we'll go into — which we will go into detail on the next slide.
You may have received communication that the award must be accepted within 45 days. This is not a hard deadline, and the agreement will remain available indefinitely. If you need more time to accept, please let your Grant Manager know and give an estimate of when you expect it to occur. Hopefully, no one will be [unintelligible] in declining the award agreement, but if you are, please contact your Grant Manager to discuss.
In this slide, we go into each step of the award acceptance process. At step one, the award will have a status of Pending Award-External Assignee. This mezans the Entity Administrator must confirm the Authorized Representative and assign a Grant Award Administrator and Financial Manager to the award. At this stage, if the Authorized Representative needs to be changed from who is listed in the application, the Entity Administrator can do so prior to the award being accepted. We have links to detail — we have links to detailed instructions on this slide.
After the role assignments are made, the award agreement will be in the Authorized Representative's worklist in JustGrants. The Authorized Representative will need to review each section, acknowledge having read the award conditions, and then accept the award. After the award is accepted, the status will change to PENDING-ACTIVE if your agency has already registered in the payments system or will say PENDING-ASAP NOTIFICATION SENT if this needs to be completed, which we will discuss in the next slides.
You will access funds in the U.S. Treasury's Automated Standard Application for Payments, otherwise known as ASAP, system. But there are usually additional steps after your — after the award acceptance before funds will be available for drawdown. In addition to the award acceptance, your agency must be registered in ASAP in order for the account to be established. I'll cover this in the next slide. Additionally, there may be withholding award conditions, which will prevent access to funds until certain actions are completed. We will cover them shortly. If you've requested a project [unintelligible] start date that was prior to the award issuance, you may be required to submit quarterly financial reports for the previous quarters. Again, we will cover the reporting requirements later in the presentation.
If your agency was already registered in ASAP, you do not need to complete that step again. If your award status says PENDING-ACTIVE after accepting the award, this means you are registered in ASAP and a specific account for the grant has been established. If your agency was not previously enrolled in ASAP, within 24 hours of the award’s acceptance in JustGrants, the Entity Administrator will receive emails from the ASAP system with the links — with links to information about enrolling.
If your award has a status of PENDING-ASAP NOTIFICATION SENT and the Entity Administrator did not receive the invitation emails from ASAP or if the links have expired, you should contact the OCFO customer service staff to request that the ASAP invitation emails be re-sent to you.
As previously stated, the award agreement is a contract, and you are responsible for adhering to the award conditions. So it is important you read and understand the applicable conditions. OJP applies 30 award conditions to all its grants agreements. These covers — this covers various requirements such as your agency's responsibility to adhere to the DOJ Grants Financial Guide and the uniform requirements found in 2CFR part 200 as one example. The link on this slide has details on the legal requirements contained in these award conditions.
The award conditions starting at number 31 are conditions applied specifically to this program and conditions particularly to your award. One or more of these awards may withheld — withhold funds. Withholding award conditions prohibit expenditure or drawdown of funds until a specified action or document is approved, and the Grant Manager submits an Award Condition Modification to remove the associated hold.
Withholding conditions may be applied for various reasons. Most commonly, if we cannot approve or clear your budget prior to award, there will be a condition requiring you to address these questions about your budget. We'll cover this in more detail in the next slide. Likewise, if your application had a missing or insufficient mandatory attachment, there may be a hold on funds until this is provided — for example, if the required proposal narrative was missing. In some cases, the type of project may require a hold of funds until more information is provided, such as projects that have an environment impact. One of the roles of the BJA Grant Manager is to communicate with you the reason for any withholding conditions and assist you in addressing them.
This slide explains the budget clearance process. If OJP cannot clear your budget prior to the award issuance, we will send the budget back for changes via a Budget Clearance Grant Award Administrator — Grant Award Modification, sorry, otherwise known as GAM. The most common reasons we cannot clear a budget are listed on this slide.
We mentioned the role of OCFO earlier and, in this process, they are the ones who initiate a Budget Clearance GAM, which will include detailed comments on what needs to be addressed. The Budget Clearance GAM will then be Change Requested in JustGrants and assigned to the Grant Award Administrator for action. It would be in the Grant Award Administrator, otherwise known as GAA, work list. The Grant Award Administrator will be responsible for making the requested changes in the GAM and resubmitting it. It would then go to the assigned Grant Manager, who will review it and either send it back if the
changes were not made or approve it to OCFO. OCFO will then review and do the same until final approval is granted. After the budget is approved as final in JustGrants, the Grant Manager will remove the holds associated with it.
Project cost must be allowable, reasonable, allocable, and necessary to the project. Allowability is governed by federal-wide requirements for all grants and program for agency-specific requirements. This slide lists some costs that are unallowable. First and foremost, under this program, all costs must clearly support the project title that was appropriated funding. Additionally, funds cannot be used for security enhancements or equipment to any nongovernmental entity that is not engaged in criminal justice or public safety. Using federal funds for fundraising, lobbying, and supplanting are strictly prohibited. The gold box refers to guidance that is new for fiscal year '23, which we will cover in the next two slides.
Executive Order 14074 on Advancing Effective, Accountable Policing and Criminal Justice Practices to Enhance Public Trust and Public Safety was signed in May of 2022. OJP has issued a policy implementing the EO for all grants issued after May of this year. On this slide, we list the items that are strictly prohibited from being purchased with OJP grant funds. There are not many projects that involve this type of equipment, but if you have a project funding law enforcement equipment purchases, please review the list and the [unintelligible] that is posted on the OJP website at the link provided here.
Instead of being prohibited, certain — instead of being prohibited, certain costs are controlled by policy, which means you must request prior written approval before you can make the purchase. This slide lists the controlled items. Contact your grant manager if your project has any of these items in the budget. At the next slide, we'll cover administrative requirements related to your grant award.
The Grant Award Administrator and Financial Manager assigned to your award must complete a Grants Financial Management Training within 120 days of grant acceptance if they had not previously completed the training on or after October 15, 2020. For some recipients, the award condition for this requirement will withhold funds until the training is complete. The training can be completed online. It is self-paced and generally can be completed within eight hours total, with the ability to save progress and return until completed. There is a link on this slide for where you can register and complete the training. Email the certificate of completion to your — to your BJA grant manager once done. If a new Grant Award Administrator or Financial Manager will be assigned to the award later, they also will be required to complete — to complete the training within 120 days.
If you plan to use grant funds to engage third parties for goods and services related to the project that will be classified as either a subaward or a procurement contract, different grants administrative requirements apply, so it is important for recipients to properly classify the relationship. The substance of the relationship should be given greater consideration than the form of the agreement. Generally, a subrecipient performs a portion of the federal award whereas a contract that is providing goods and services to the recipient itself. The uniform guidance lists characteristics of subawards versus contracts, which are listed on this slide. On the link provided, OJP has a checklist, which you can use to document the classification.
We'll pause here for another poll, which Erich will open in Webex for you to respond to. We would like to know whether you will be using your grant to issue a subaward, a contract, both, or neither. I'll give everyone a few minutes to respond. Maybe we'll take a few more seconds before we close the poll. Okay. So it's good to know that 84 — looks like 84%, the majority of you all have either non or not sure, 55% is procurement contracts, 22% is subawards, and 64% did not answer.
Next slide, please.
This slide includes some details on requirements for subawards. All subawards require prior federal approval. If you have a subaward in your budget with sufficient detail, all issuance of the award and budget [unintelligible] is the approval of your subaward. However, if the subaward did not have details on the subrecipient or work to be done, or if you later want to add a subaward to your project, this will require separate approval from us.
Pass Through Entities are required to have policies and procedures in place to manage and monitor all subrecipients consistent with federal requirements. We list a few of those requirements on this slide, but you should refer to the full requirements in the DOJ Grants Financial Guide, Chapter 3.14. Pass Through Entities are required by the Federal Funding Accountability and Transparency Act, also known as FFATA, to submit a specific report on each subaward over $30,000 by the end of the month following day of issuing the subaward. You will not submit the FFATA report through JustGrants but instead through a separate portal on the FSRS.gov website. Refer to the resources on this slide on how to submit the FFATA report.
The requirements for procurement contracts are listed in the DOJ Grants Financial Guide Chapter 3.8. This slide provides just a few — just a brief overview. Procurement contracts must be conducted in a manner to provide open and free competition. States and territories are exempt from the federal requirements or competition, but instead must follow their own procurement standards. For all others, if you are proposing to use federal funds to issue a sole source, non-competitive procurement contract over $250,000, you must seek prior written approval from the grant-making agency. The guide lists the information needed to support such a request, which must be submitted in JustGrants as a sole-source approval grant award modification. Please refer to the guide for the full requirements on procurement contracts.
Now, I will turn it over to my colleague, Tisa, and thank you and congratulations again.
TISA MUHADDES: Thank you, Nicko. Hello, my name is Tisa Muhaddes, and I am a grant manager at BJA. Congratulations on your awards. We will continue with administrative requirements.
The National Environmental Policy Act or NEPA requires that federal grant-making agencies evaluate if projects they will be funding have environmental impacts. For most projects under this program, if we determine in reviewing applications that there were no impacts, we issue a categorical exclusion to NEPA. For projects there was an activity with NEPA impacts or where we did not have enough information, we will place award conditions. The important thing to note is that if your project is subject to NEPA review, our NEPA contractor will be contacting you and providing assistance with the process.
Next slide, please. Thank you.
This slide — we’ll continue with NEPA. This slide provides some more details on the types of activities that require NEPA review and documentation. For example, constructions, major renovations, projects involving chemicals such as DNA testing and drug disposal are some examples. We also list here the types of projects that generally will receive a categorical exclusion. Again, our contractor will work with you to provide the necessary documentation if it is needed.
DNA testing. Projects involving DNA testing, in addition to being subject to NEPA review, also have additional requirements. This slide covers the three general types of DNA activities that might be funded, and the requirements. I won't read all of the text but if your project involves DNA testing, please make reference to your award document, which will include conditions above these requirements. I will, however, point out, if your projects is funding rapid DNA testing of crime scene samples, which is the third bullet on this slide, BJA will be reaching out to you soon to schedule a separate meeting with the forensic team to discuss the unique rules related to rapid DNA use for this purpose.
Body-worn camera policy. Projects funding body-worn cameras will have an award condition that specifies recipients must have policies and procedures in place related to BWC equipment usage, data storage and access, privacy considerations, and training prior to purchase. BJA has a BWC Toolkit, which is linked on the site, which is on the deck below where you can find model policies and a wealth of other best practices related to BWCs.
This presentation is not long enough nor is it intended to cover every possible administrative requirement that may be applicable to your project. We list a few other requirements on this slide, to include the requirement to report any waste, fraud, and abuse of grant funds — if you become aware of it — as well as a requirement for suitability determinations if your project involves services to minors. If your project is funding a website or publication, there is a requirement to include a disclaimer statement, which is included in the award conditions. As a reminder, you should thoroughly read your award
agreement and the conditions to understand any administrative requirements that may be applicable.
Payments. As mentioned earlier, you will make payment request in the U.S. Treasury ASAP system. Under this grant program, you are not allowed to drawdown all funds in advance, instead, you are — you are subject to the rule requiring you to minimize federal cash on hand, meaning you should only draw down what is needed for your immediate needs. Any federal funds drawn down but not disbursed or reimbursed within 10 days must be returned to OJP. If you're drawing down on a reimbursement basis, you can do so on a schedule that works for your agency. Please note that the ASAP system suspends all accounts the last three business days of each month except September, when it will be suspended for five business days in advance of the transition to the next federal fiscal year.
The Grants Financial Management Training that you must complete will cover the full requirements of your accounting system and procedures, but in the next few slides, we will cover this at a high level. I encourage you to review the full requirements in the Financial Guide, chapter 2.3. As noted, your financial management system must be fully auditable, must be able to track grant funds separately, and must accurately account for the receipt obligation expenditure of grant funds. An accounting system that is adequate for meeting the grants financial management requirement is one that has specific features, some of which that are listed on this slide. To summarize, it must be able to track, record, and control all use of the grant funds. Again, the full list of what an adequate accounting system must be able to do is in the Financial Guide. Your accounting systems will be subject to review if your award is selected for in-depth monitoring.
Commingling and supplanting of grant funds are prohibited. Regarding commingling, although federal regulations do not specify physical segregation of cash deposits, your accounting system must ensure grant funds are not commingled with other funding sources. Supplanting means that federal funds cannot be used to replace non-federal funds that were budgeted for the same purpose. Federal funds can supplement other funding streams but cannot replace them.
Reporting. We will now cover the reporting requirements for your grant. You're required to submit semi-annual performance reports and quarterly financial reports. Both types of reports will be submitted directly in JustGrants, with the Grant Award Administrator, or GAA, responsible for performance reports and the Financial Manager responsible for the financial reports. The regular performance and financial reports are due 30 days after the reporting period ends, with the dates listed on this slide. There is a 14-day grace period for performance reports. After the 30-day — after the 30-day period ends, pending reports will be marked delinquent. The final performance and financial — the final performance and financial reports are due within 120 days after the project end date. This slide includes links to the JustTraining resources for both types of reports.
Here are some important reporting tips. For financial reports, you will report the cumulative total of federal obligations and expenditures, not the drawdown amount each quarter. Reports are required even if there was no activity. Similarly, the semi-annual performance reports are also required even if no activity took place. We expect you to report the progress made on your goals and objectives specific to your project for each reporting period. For the final performance report, we expect details on the overall project accomplishments. You have the option to include additional information and attachments to the performance reports. It is important that you submit reports on time in JustGrants. Your ASAP account will be suspended if a report is marked as delinquent and your access to funds or drawdown will be prevented until your ASAP account is restored, which only happens once you submit the pending reports. A pattern of delinquent reports is a risk indicator and could increase your chances of being selected for in-depth monitoring.
A Grant Award Modification, or GAMs, should be submitted if you're requesting a change to your project or budget. It is important to note that you will not be allowed to change the project title, as this was listed in the public law, and you cannot use any funds for any activity or cost that does not contribute to the project title. That said, if the changes are in support of the project and otherwise allowable, you can submit a GAM for our approval of the changes.
This slide lists the different types of GAMs. The Programmatic Costs GAM is for specific costs that require prior approval, such as paying an individual consultant more than the OJP daily threshold of $650 per day. The Change Scope GAM is to request a change to the project activities, approval for a new subaward, or changes in key personnel. A Budget Modification GAM is required if you want to move 10% or more of the total award between budget categories or to move any amount of funds into a category that previously had zero allocation in your approved budget. Nicko mentioned the Sole Source Approval GAM, which is required for non-competitive contract over $250,000.
You can also submit a Project Extension GAM, which is also known as a No-cost Extension GAM. Please note a Project Extension GAM, if approved, does not grant you additional funds, just more time to complete your program activities. You may require — you may request a one-time Project Extension GAM up to 12 months if you need more time to complete your project. You will need to provide a justification for the delay and a revised task timeline as part of the extension GAM. OJP will consider additional extension request or request for longer than 12 months on a case-by-case basis, but they require an exception to our policy and require additional justification. Please reach out to your grant manager for any questions regarding extension GAMs.
In-Depth Monitoring. So, the BJA grant managers monitor the progress and compliance of each grant through communication with our grantees, review of reports and GAMs, and by completing annual desk reviews. However, OJP is required to conduct in-depth monitoring on 10% of its total awards each year, and it uses risk factors and other tools to select which awards to monitor. If your award is selected for in-depth monitoring, you will receive a formal letter with proposed dates and then a list of all the documents that are needed to be sent for review. In-depth monitoring can either be remote or at your location onsite. After the monitoring event, OJP will issue a letter with the results, to include any issues that needs to be resolved.
On this slide, we listed some of the issues that are usually identified during monitoring. Generally speaking, the issues that crop up tend to be about not following award conditions or obligating expending funds prior to approval, such as before the budget has been cleared, or it can be inadequate accounting policies and procedures.
Also a few other issues to be aware of are inadequate subrecipient monitoring policies and procedures or lack of subrecipient monitoring, misclassification of costs or incurring costs without seeking prior approval if it was required. One of the reasons we hold this webinar and stress to you about reading the award agreement and the requirements in the Financial Guide is to set you up for success at the beginning. If your award is monitored and these issues are identified or flagged, we will work with you to address and resolve them to ensure that you are able to successfully complete the program.
I know this has been a lot of information, but we are the last stage of the post-award grant's lifecycle, which is the closeout. The closeout must be completed 120 days after the project end date. Although if the project is finished earlier in an early reporting period, you can complete — you can complete the closeout requirements ahead of time too. All costs must be properly obligated prior to the project end date, but the 120-day liquidation period after the end date is to allow any remaining expenditures to be made for authorized costs that were properly obligated.
The grant-funded activities must be completed by the project end date with the only exception being a project evaluation, which can be completed during the liquidation period. The grant closeout is processed upon completion of the project, submission of all final programmatic and financial reports, and drawing down of funds, and then the actual submission of the closeout via JustGrants. There is a link on this slide to the JustGrants training resource on closeout.
And with that, we have completed the Grant Management Overview. Thank you for your attention and congratulations again. And I am going to pass the presentation on to Lisa and with her JustGrants training team. Thank you.
LISA HARTMAN: Thank you, Tisa. I appreciate the introduction and again, congratulations on your award. I'm happy to be able to follow up Nicko and Tisa with some demonstrations in JustGrants on the many topics that they just discussed. So hopefully this will allow you to see a little bit more about what it looks like in JustGrants to process your award.
So the purpose of today's session is to learn how to onboard users and manage critical tasks for your award using JustGrants. Now, we'll discuss award acceptance and take a look at the onboarding Grant Award Administrator and the Financial Manager. We'll briefly review ASAP enrollment and then direct you to training resources on that subject. We'll also look at Federal Financial Reports as well as grant award modifications. And all of these the ladies have discussed from an overview standpoint, which is terrific. And lastly, we’re going to show you where you can go to help — go for help as you navigate through JustGrants.
So, during this session, we can address any questions — I can address any questions you might have related to JustGrants, the rules and processes to accept and maintain an award, or other general questions related to JustGrants. But the Q&A function allows you to ask questions about JustGrants, as well as it allows you to ask questions of the BJA staff in terms of policies and the like.
Now, if you'll be receiving funding, your entity will also — will need to then formally accept the award to begin using those funds. So accepting or declining funding is the sole responsibility of the organization's Authorized Representative. And again, the Authorized Representative must be legally authorized to enter into an agreement with the Department of Justice and they will be responsible for agreeing to the award terms and conditions. And we'll take a look at that process now.
Now, when an award is ready to be accepted, the Application Submitter, Entity Administrator, and Authorized Representative will all receive an email that an award has been made. Now, 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 that the correct Authorized Representative is assigned to the award so that the award can be accepted or declined.
So, prior to the Authorized Representative being able to accept an award, the Entity Administrator must assign a Financial Manager, a Grant Award Administrator, and must review and confirm that the Authorized Representative assigned at the time of application is still correct for each award. Now, the person assigned as the Authorized Representative must have the authority to accept awards on behalf of the entity. This includes binding the organization to the terms and conditions of the award. The award is accessed from the Entity Administrator's worklist and the award notification email is the indicator that the Entity Administrator must sign in and begin that acceptance process.
So the award review and acceptance process takes place in JustGrants. All of the award package information is going to be available to you on one screen. The award acceptance status is an important indicator of work that may need to be completed prior to accepting the award. So here are the status codes for your award and what they mean. If you have an award in Pending-Award External Assignee status, it indicates that the Entity Administrator has not yet assigned a Financial Manager or Grant Award Administrator, and they need to review the status of the Authorized Representative.
If your status is Pending-Award Acceptance that indicates that the Entity Administrator made all of the needed assignments and the funded award is now routed to the assigned Authorized Representative for award acceptance. The Authorized Representative at this point can locate and view the award in their worklist in JustGrants.
If your award is in Pending-Account Creation status, it indicates that the Authorized Representative has accepted the award and that acceptance triggers a notice to the automated standard application for payments for ASAP system for that award account creation. Grant funds are deposited in ASAP so that grantees can make payment requests. ASAP is not a JustGrants function; it's a separate system managed by the Department of the Treasury. Any questions about ASAP must be directed to the Treasury Department. We will provide information how to access ASAP in this training and how — and we'll show you how to find help in this session.
Now, if your award is in Pending-ASAP Enrollment status, it indicates that you are a new ASAP user and you're a recipient of DOJ funds. And typically the enrollment is performed by the person in your organization primarily responsible for drawing down funds.
If your award is in Pending-Active status, this indicates that all technical aspects have been completed. At this time, the Grant Award Administrator should review all the award conditions to see if any items need action by the recipient. And please note, this doesn't 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, expending, drawing any funds, or starting any activities. And please remember, accepting or declining an award can only be accomplished through JustGrants.
So now that we talked a bit about it, let's go through a demonstration of the award acceptance process. For awards with Pending-Award External Assignee status, the Entity Administrator needs to open the award, review the current assignees for each role, and make the appropriate update. If the logged in Entity Administrator is not the person listed as the correct Entity Administrator for this award, you're going to need to contact our technical support office for assistance. This is a problem we had a little bit last year. We don't anticipate it this year, but if that is the case, please don't hesitate to contact our technical support office.
Now, once the award has been opened using the Begin button in the Entity Administrator's worklist, the assigned contributors page opens. If all the listed roles are correct, you'll click the Submit button at the bottom of the list. But if you need to update a role, select the title of the role to be assigned from the Assigned Contributors dropdown list. A new role will populate the list if the 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. Now, when all roles have been assigned, you'll select the Submit button at the bottom of the list.
Now, the Authorized Representative assigned to an award will receive the award package in the My Worklist section of JustGrants. The Authorized Representative can select the case ID to open the award package. Now, once the award package opens, the Authorized Representative needs to review each section of the package and agree to each section separately. The first section includes the award letter information and details. And once confirmed that the information is correct, the Authorized Representative will check the box at the end of the section to indicate that information is correct. And we'll show you what that looks like here.
Scrolling down a bit, you want to read through the project information first, and then once you've reviewed the information to confirm it's correct, then the Authorized Representative will need to check the box indicating their agreement of the information’s correctness.
Now, the financial section includes the current budget. In the Budget Detail view, you'll expand the caret next to the budget category for a list of the line items associated with that category, and check the box to indicate agreement to the financial section. And this is what that looks like here.
DARYL FOX: Lisa, I hate to interrupt you there.
LISA HARTMAN: Yes.
DARYL FOX: But we're — that image is very blurred on our end, so we can't see what you're actually talking to. But for the audience members, we will be posting that to the BJA website where you'll be able to make out that slides, but...
LISA HARTMAN: Let me see if I can make that a little bit better.
DARYL FOX: Okay.
LISA HARTMAN: Does this appear to be better?
DARYL FOX: Yes, hundred percent.
LISA HARTMAN: Okay. I'm sorry about that. That was a bad slide.
All right, so I believe we're still — we'll continue on. Thank you for letting me know.
So this is the budget. You can see the individual budget categories and you can click the little caret here to open up the individual line items to review. All right. And then again, at the end of the financial category, you can check the box to indicate that you agreed to all of the information there.
Now, the final receipt, so you want look in the Other Award Documents section and the Award Conditions. You will have to agree to all the conditions as a group. You're not going to be able to agree to some but not others. And you'll check the box at the end of this section to indicate agreement to the content.
Now, the final section is Award Acceptance. And the example shown here is specific to the Community Oriented Policing Services, also known as the COPS office, this is not a BJA — not a BJA example. BJA will have one Authorized Representative while the COPS office displays two.
Now, if you choose to accept the award, you're going to select Accept. And just select Decline if you wish to decline the award. A pop-up window will appear asking for a reason if the award is being declined. Now, for OJP or BJA awards, accepting the award will change the status to PENDING-ACTIVE and you will begin then to be able to manage the award.
Now, one step that's often missed when onboarding a user is assigning a user to a specific award or application. Without this step, that user will not be able to take an action on the award in JustGrants. Now, this critical step, again, is often overlooked, but it's easy to resolve. The entity admin will make these assignments. So from the awards venue on the left, the Entity Administrator will see the Show/Hide Roles button at the top and select the three required roles: Grant Award Administrator, Authorized Rep, and Financial Manager.
Now, when the Entity Administrator submits this request, columns for each of these roles appear. You're going to select the awards that you want to update the role. And once you do, you can use the Choose Role dropdown menu at the bottom, and you select the role that you want to assign first. Once you do that, you'll get an Assign To — an Assign To dropdown: a list of people in your organization that have that role. And you'll assign — you'll use the Assign button to assign them. Now, we're going to go ahead and assign a Grant Award Administrator as well. And when you are able to complete this, you'll see that all of the fields are filled in and there is an appropriate assignment in each of those fields.
Now, if somebody's leaving, for instance, the Grant Award Administrator, and you want to reassign all of their awards, you can do that very easily by selecting multiple awards, and then reassigning to a new person.
Now, a previous grant management system processed award acceptance using a file upload. JustGrants doesn't 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's a fully digital process that uses the Authorized Representative's electronic signature to complete.
Now, we do get some questions about award acceptance. For instance, what happens if an Authorized Representative doesn't see the application in their worklist? And typically, if they don't see this in their worklist, it means that it's not assigned to them yet. And the Entity Administrator must complete the activities assigned to them before it can be assigned to the Authorized Representative.
Now, what happens if these Authorized Representative changes from the time the application was submitted and the award received? This happens fairly often. Sometimes it can be five or six months. In this case, the Entity Administrator will need to update the Authorized Representative in JustGrants. However, no grant adjustment is needed. The Authorized Representative will — the Entity Administrator will need to either invite the new Authorized Representative to join the JustGrants system as assigning authority, or they'll need to add the Authorized Representative's role to the existing user's profile if they have the authority to serve in that role.
So after being invited, the new user creates and authenticates their new account. The new user will then appear in JustGrants, and the Entity Administrator will be able to assign the user to the Authorized Representative role to accept the award. Now, the user accepting the award will be shown on the award package details.
So we'll take a moment to just look a little bit at enrolling an entity in ASAP. Now, the Department of the Treasury Bureau of the Fiscal Service, ISIM PP, will send two emails to the entity’s System for Award Management, or SAM.gov, Electronic Business Point of Contact — also known as the E-Biz Point of Contact — and one will contain a username and the other will contain a temporary password and a link to create a new password.
Once receiving both emails, that user must complete the following steps. They're going to use the provided username and temporary password to log in to the ISIM system to change the password and complete the security questions. Then log in to ASAP using the new username and password. You'll need to accept the ASAP terms. And then you'll select an option that says, "1 notification awaiting review." You're going to select "Unread" from the Notification Status dropdown menu, and then select "Continue." You'll select the magnifying glass on the right side of the screen to view the enrollment notification. And to learn more about the ASAP registration process, please see the ASAP registration checklist.
So now, we talked a little bit about financial reports, let's take a look at accessing those from the worklist. Now, only Financial Managers will submit FFR. All current FFRs will appear in the Financial Manager's worklist for easy access. To complete an FFR, you want to select one from the worklist by selecting the Case ID. The FFR will automatically open in edit mode. Now, the first page of the FFR is read-only information pulled from the entity profile. You’ll want to verify the award number in the second entry and review the rest of the information for accuracy. Once you've done that, you'll select the Continue button in the bottom right, or you can scroll to the top and select the Report Information tab at the top of the page. Either of these options will move you to the next page.
All right. On the next page, this is where the entry begins. The Recipient Account Number is an optional field, and this is reserved for an identifying number assigned to the award by your organization, perhaps to match up, you know, with a report or an accounting system. The Report Type will default to either quarterly or final, depending on the applicable grant period. The reporting period is indicated in a later step. You'll select the Basis of Accounting that's used in your organization. DOJ does not determine that. And DOJ also does not use the Federal Cash section of the report.
So as we scroll down, there's three entries that are grayed out. And you can see here the Project Period and the Reporting Period listed in the top section of the FFR. Now, scrolling down, these three fields, again, are grayed out because DOJ does not use this section of the Federal Financial Report. You'll want to note the red asterisk in the entry field for 10e.
This indicates a required field. And note that all entries in this report, as mentioned earlier, are cumulative.
Now, you'll notice that JustGrants performed some automatic calculations based on your entry. And we'll just let the system, you know, roll through and you can see which entries are entered by yourself and which, you know, are automatically popping in based on your entries. Again, remember, this is cumulative from the beginning of the award to the end of this reporting period.
So, as we scroll down, you'll see additional fields. And again, with the red asterisk, it indicates that you must put something in those fields. It might be zero, but it must be populated. And the ones without the red asterisk are not required fields.
We'll move down a little bit to the next couple of lines, and then we will talk about entering Indirect Expenses. All right. To enter these Indirect Expenses, you're going to click that plus Add button on the bottom left. Then you want to — that will open up a new line item for you. You want to enter the information in all fields for each Indirect Expense that you're reporting. Now, when you finish entering your total, at that point, you'll select Continue to open the last page of the report. But I want you to notice that as you are entering information, below the bottom line item, you'll see a series of numbers. And this will be the total amount of Indirect Expenses that you're entering. So, once we finish entering one line, the JustGrants will total that and if you were to enter additional lines, you'll see the total of all lines in those fields at the very bottom. All right. And now, once we're finished, again, we're going to select the Continue button then to open that last page of the report.
Now, on the last page, you'll use the additional information field to add comments. And you'll notice that we have an option to upload supporting documentation as well. I'm going to move the demo forward just a little bit because this is a little time-consuming and I don't think we need to necessarily spend time on that. This is — this is what we're doing, looking for an attached file that can be uploaded. So, you’d have the option to upload what you need.
And then at the bottom, we have a Certification and you'll see that it displays the name and contact information for the submitters. And then once you have selected Submit, then that support is designated in the submitted status and it's sent to UFMS — which is the Universal Financial Management System, that's DOJ's Financial Management System — where it will be validated, and it will stay in that status for up to 24 hours typically. And then it will be forwarded to the financial office.
Now, it's important to remember that all entries in the Federal Financial Report are cumulative. And when entering data in field 10e, there's going to be a pop-up that appears confirming that you've entered a cumulative total. If you answer yes to this question indicating that you did enter a cumulative amount, you'll be directed to the next data field. However, if you've not entered a cumulative total and you answered no, you'll be directed back to field 10e to correct it.
Now, if the amount that's entered in 10e is less than previously reported amount, you're going to receive a message indicating that you need to be sure the amount is correct. If it is, you'll be required to provide an explanation in block 12, that text box that was labeled Additional Information.
So, to locate a list of pending and submitted financial reports, you want to open the funded award and navigate to the Federal Financial Report section. You can open any report by selecting a report number in the left column.
So, let's take a few minutes also to discuss Grant Award Modifications, also known as GAM. Now, GAMs are completed and submitted by the assigned Grant Award Administrator on the award. And all GAMs must be approved by DOJ personnel. Now, one of the questions we get from grantees is what types of GAMs can be submitted in JustGrants? And there are three categories of GAM. There's the Programmatic GAM, the Financial GAM, and the Project Period Extension. And I know that these were mentioned earlier in the presentation.
There are two types of programmatic GAMs and there's Scope Change and Programmatic Cost. There are also two types of financial GAMs. There's Budget Modification and Sole Source GAM. And finally, there's a Project Period Extension GAM. And this modification type is typically used to request an extension on the project end date.
Now, another question we see is how can a grantee initiate and submit a GAM? And again, GAMs are initiated and submitted by the Grant Award Administrator. And that person must open the funded award and navigate to the Grant Award Modification tab to initiate a GAM. Once that GAM has been initiated, it will appear in the — in the assigned Grant Award Administrator's worklist for updates or further work. And it will stay there until it's submitted. Now, in some cases, DOJ personnel can initiate a GAM on behalf of a grantee. However, it is expected that grantees are the primary initiators of any modifications to the award.
So, I'm going to do a short video demonstration on how to initiate a GAM. And there are a couple of steps that might be a little confusing. Now, as we saw, there are multiple types of GAMs. And in the interest of time, we're going to demonstrate how to initiate any type of GAM. And then I'll show you screenshots of the Budget Clearance GAM set.
Now, all GAMs are initiated from the Grant Award Modification tab of the funded award. And before this option's available, all required roles need to be linked to the award as we discussed earlier. And now, what — we're going to go ahead and open this award. And you'll notice here that there are a number of different assignments, each with a Begin link. To open a GAM, you need to open the Programmatic Begin link. This is going to open the entire award to be edited by anything that a Grant Award Administrator can do. And you'll see that there are links to open performance reports specifically, but the Programmatic GAM will allow you to edit any aspect of the award that you can.
Now, when you open the GAM selection dropdown menu, you'll see those three categories of GAM. When you select either Programmatic or Financial, so the second dropdown appears and allows you to select that subtype. Now, Project Period Extension GAM will open when it's selected, although there are some validations that happen upon selection. So, if you open a Project Period Extension GAM less than 30 days from the project period end date, your grant manager is going to have to initiate that for you. You will no longer be able to access that. Now, if a GAM is in progress, you are not going to be able to initiate a new GAM of that subtype until the one in progress has been resolved.
So now, we'll take a look at the steps to submit a Budget Clearance Grant Award Modification. And the reason we look at this is because as mentioned earlier, the budget may not have been cleared prior to sending you notification of your award. And in that case, the financial office will issue a Budget Clearance GAM to you. They will initiate it and send it to you. So, the financial office will need you to update details of the budget before it can be approved. And it's going to be sent to the worklist of the assigned Grant Award Administrator.
Now, when a Grant Award Administrator locates a Budget Clearance GAM in their worklist, they must open it to update the budget. And you can see in the image on the upper left, the green box is the link that you would click to open that GAM. And notice that the status of the GAM is Pending Change Request. So, you can use the sort and filter features to locate a GAM in Pending Change Request status, then select that case ID to open it.
Once you do, in the second image up there on the upper right, you'll navigate to the Grants Management comment section. This is where you're going to find the information that you need to update in the budget. And then you'll navigate to the Budget Detail Summary Review and open the caret responding to each category that you need to update in the line item.
Now, once you open the line item that needs to be edited, you'll modify the contents of that line item. You can add a new line item by selecting the Add button. To delete line item, select the trash can item. You're just following the steps requested by the — in the Grant Management comment. Now, information in the Additional Narrative field is required for any budget category with a line item.
Once you've updated the line items, you'll navigate to the bottom of the Budget screen and select Save. And then the Budget Summary will automatically be updated with any changes you made. Then you'll navigate a little farther down to the Total Project Cost section, and you're going to revise Federal Funds Match Amount of Program Income fields as necessary. And it's important to note that the Federal Funds, plus the Match amount, plus the Program Income amount must equal the Total Project Cost.
Now, if you're asked to upload documentation, you can do that one of two ways. You'll navigate through the Budget Financial Documentation section to upload an attachment, if necessary, and then you'll either select the Entity Doc to upload an attachment from your entity's document library — which is contained in JustGrants — or you'll select the Upload Docs to upload the document from your computer.
Now, if the Entity Doc is selected, you're going to see this screen on the right and you'll put a checkmark in front of the entity document that you want to select, and you'll click Submit. Now, if you use Upload Doc and you're uploading something from your computer, the Attach Files window is going to appear. You'll select the files. To choose, use the Select Files option to choose a file from your computer.
Then you'll need to select the document category from the Category dropdown. Now, the category selection should match a category displayed in the GAM except for the Additional Attachment section. But if you — if you are uploading, for instance, an Indirect Cost Rate Agreement, if that's the request, then you're going to need to match the category Indirect Cost Rate Agreement with the request. So JustGrants stores all attached files based on the category, so if you choose the wrong category, it will still be uploaded into JustGrants, but it will appear in a completely different section of the GAM.
Once you've uploaded it with the correct category, you'll select Attach, and then the attachment's going to appear in the corresponding section. And then you'll select Submit. The GAM is going to appear in the Grant Manager's worklist for review, so it goes back to DOJ for review. Now, the Grant Award Administrator will receive an email when the GAM is approved, and they will be able to view the GAM in that completed GAM section.
So, just to tie up now here a little bit, we hope you gained some insight from what we presented today on how to manage your award in JustGrants. Before we close, I do want to provide you with some additional resources that you can access to move through the process. So now, embedded in this slide deck, we have links to all the information we covered today. And the Justice Grants website there at the top houses all of our training materials that you can — that you will need as you manage your grant. And we placed direct links here to the entity management and experience, as well as the User Roles Guide. And all of these can be found on the Justice Grants website.
Now, to an applicant for an award recipient for an OVW — well, this is not an OVW group. So to contact the JustGrants technical support desk, please email to [email protected] or call 833-872-5175, Monday through Friday from 7:00 a.m. to 9:00 p.m. Eastern or on weekends and holidays from 9:00 a.m. to 5:00 p.m. Eastern. And please do use that email or phone line for any issues you may have in JustGrants.
Now, we did talk a little bit about the online site for training materials and this is what that JustGrants training website looks like, where you can find a wealth of information about JustGrants at https://justicegrants.usdoj.gov. And I know that Daryl put this link in the chat. I saw that — I saw that he's been linking to quite a few of our training materials, so I thank you for that. Now we'll focus on the training link today, but please take some time to look through the whole website because there's a lot of useful information about JustGrants.
Now, when you open the training link, you'll see a list of training topics displayed. And it's a good idea for everyone to start with the Entity User Experience Guide, because that covers navigating in JustGrants. And the Entity Administrator must be very familiar with the Entity Management Guide. And then once you’ve selected the topics to explore, you can open the Training Resources page dedicated to that topic that typically you're going to find a Job Aid Reference guide or JAR as we call them, and links to step-by-step videos. These are very short videos. They're meant to be used while you're working, so don't feel like you need to set aside a lot of time to view them. And they can really help you if you're in the middle of a task in JustGrants and you want to verify the next steps. The Job Aid Reference guide provides step-by-step instructions with screenshots to help you walk through the task and you can print them or view them on a screen, whatever you like.
Now, we do offer virtual Q&A series every week. And the link shown here is where you can get more information. Oh, that went too fast. Sorry. So fast. So we offer our Post-Award Management sessions from 1:00 p.m. to 2:30 p.m. Eastern on Mondays. And this is covering a great deal of what we covered today: GAMs, closeout, performance reports, and financial reports. On Tuesdays, we have a session just for the Entity Administrator and that happens on Tuesdays from 2:00 to 3:00. For next application season, we do offer an Application Mechanics session 2:30 to 4:30 — there's a great deal of information in that session. And then finally, for Authorized Representatives, we have an Award Acceptance session from 2:00 to 3:00 on Thursdays, and those are all Eastern Time.
And with that, I'd like to turn the — turn the presentation back over to Erich and Daryl for — to close up.
ERICH DIETRICH: Thank you, Lisa.
Yeah, in the next section, we're just going to finish up by sharing some more resources. I know we've shared quite a lot already in this presentation, so we'll just click through these real quick and then we can ask some more questions.
I know this was shared previously and including in Lisa's presentation, but this has the kind of the jumping off page for all JustGrants-related resources from the trainings, the user support, everything that Lisa mentioned, so that's on this page as well. And we, of course, are providing the links in the chat.
And we mentioned, the DOJ Grants Financial Guide, which is a very important document, in particular for those of you that are--that are responsible for ensuring the compliance with award conditions and allowable costs in the, you know, account management. Here's a link to the landing page for the Financial Guide and all of the different sections. There's also a PDF version if you'd like to download a version.
We encourage you to stay in touch with OJP, whether you have multiple awards from us, or this is your first OJP award. The information on this slide is where you can text us and link with us in social media and you'll receive news releases and new funding — new funding announcements and a wealth of other information related to criminal justice.
And same thing on this page for BJA. Get in touch, stay in touch with BJA about our funding opportunities. We've got a lot of great content on our social media page, our YouTube page, so stay in touch and see what other resources we have that will be useful for you, maybe not necessarily for this grant, for any other projects that you have.
And with that, I know we've been trying to keep up with questions in the Q&A, but, Daryl, if you wanted to read some out loud that we couldn't get to or if somebody wanted to ask one verbally, we can certainly do that now.
DARYL FOX: Thanks, Erich. Just generally for everybody on today's call, I want to reiterate that the PowerPoint transcript and recording along with the Q&A will be posted to the BJA website. If you need to go back to anything, you'll have that opportunity to do so. Once everything is posted, you'll be sent an email with the email address you registered with today. So that will be something to look out for within the next seven to ten business days.
Is there going to be another session specific on B-SCIP?
ERICH DIETRICH: On SCIP? Is that--what was the question?
DARYL FOX: I believe it is. It's just an acronym.
ERICH DIETRICH: Yeah. Yeah.
DARYL FOX: B-SCIP.
ERICH DIETRICH: Yeah. Yeah. You're referring to the Byrne SCIP Program. The Byrne SCIP program is a totally different program and we — this is on — this webinar is unrelated to it. We did have a webinar related to Byrne SCIP last year. Brenda could speak to that, but that is on our website. The Byrne SCIP information is on our website. Contact your grant manager if you need a link to the SCIP information.
DARYL FOX: And perhaps this is directed towards the JustGrants team. Is there a place where one can see on JustGrants what reports are due and when?
LISA HARTMAN: So I can address that one. So when a — when a reporting period is coming up, for instance, if the reporting period ends December 30th, 31st, then the follow — 10 days prior to that end of the reporting period, that report will appear in the appropriate users' worklist. So if you're the Grant Award Administrator, you'll see in your worklist 10 days prior to the end of the reporting period your Performance Report automatically generated by JustGrants; the same with the Financial Managers. So it's 10 days prior to the quarterly reporting period for financial reports, you'll see that in your worklist as a Financial Manager.
DARYL FOX: Thanks, Lisa. Can you...
LISA HARTMAN: Uh-hmm.
DARYL FOX: ...briefly explain the difference between subawards versus procurement in relation to the budget?
ERICH DIETRICH: Sure. So, generally a subaward is to — when you're issuing funding to a third party that is completing, you know, a significant portion of the federal award. Your “partner agency” is one of the words. If you have a partner agency and you're issuing them funds, that generally would be considered a subaward. Whereas a procurement contract is one where you're issuing funds to a third party, which is just providing goods and service — goods and services for your agency to complete some portion of the work, maybe without even being, you know — not respective of the grant terms and conditions.
There is gray area in the characteristics and so I would encourage you to look at the information in the DOJ Grants Financial Guide chapter 3.14, which has full details on the distinctions between the two. And then ultimately, it's up to your agency to make the distinction between the subaward and the procurement contract. And then of course, follow the appropriate requirements for each.
DARYL FOX: And if one was awarded a project in which they make a purchase that's then distributed to other law enforcement agencies within their jurisdiction, are they considered as subawardees?
ERICH DIETRICH: It depends; if they're — if they're purchasing the equipment itself and then giving it to the other agencies, I wouldn't necessarily — wouldn't necessarily categorize that as a subaward. But if they are take — or they're actually taking the funds and giving them to the other agency to make the purchases, then that would be a subaward. But I would suggest for any questions like that for — contact your Grant Manager if you need assistance in terms of the correct classification.
DARYL FOX: Can cost incurred prior to acceptance of the grant, but after the begin date indicated on the award letter, be allocated with this funding?
ERICH DIETRICH: They can, as long as those costs are authorized. And in doing so, they would be obligating at your own risk. So authorized costs would be ones that are going to be approved under the project budget. So to the extent that they are authorized costs — costs that would be under the approved budget — you can use local funds to obligate them within the project period before you accept the award. Then you would be able to reimburse for that. But like I said, it would be at your own risk.
DARYL FOX: Seems to be the end of questions in the queue at this time. We'll just hang on. We have a few more minutes left in today's session.
If you are already using ASAP to receive funds from another grant, do you have to create a new account for this particular grant?
ERICH DIETRICH: No, as long as that's under the same Unique Entity Identifier or UEI, the same SAM registration, then you don't need to enroll in ASAP again. What will happen is once the award is accepted, there will be a — usually takes 24 hours where there's an automatic notification sent from JustGrants to ASAP, which associates the new award with your ASAP account and it creates a separate account for that.
DARYL FOX: There was just a mention just that ASAP's implementing a multifactor authentication, which requires Social Security numbers and driver's license or passports. With it being highly sensitive information, are they looking to perhaps create another form of MFA moving forward?
ERICH DIETRICH: Yeah. I don't know the information to that. I do know that there's been a lot of communication sent out recently from OJP about the multifactor process. And I can't speak to the actual details on what ASAP is enacting. So all I can do is refer to the communications that are on our website, the JustGrants page about multifactor and see if there's an answer to that there or through ASAP directly.
DARYL FOX: Is there a template — a contract template for subawardees? Are there documents required to be completed for procurement contractors?
ERICH DIETRICH: Yes. I would — in both cases, I would refer to the DOJ grants Financial Guide and the linked guidance within there to 2 CFR 200. Both subawards and procurement contracts have specific requirements based on federal regulations on the content that must be in the actual document itself, as well as the requirements for monitoring performance. So, you have to look at the Financial Guide, the respective chapters for each.
DARYL FOX: Okay. Thanks so much, Erich.
So we're at 3:30. Is there anything in closing — before we close out today you want to mention?
ERICH DIETRICH: I just wanted to thank everybody, for our presenters, as well as everybody that attended. And just to reiterate, as you work through onboarding your award and getting used to it, feel free to contact your BJA Grant Manager for any questions. And, you know, hope this was useful for you, and we certainly will send out the resources and the slides and the recording as soon as we can afterwards. So thank you all for your attendance and your time.
DARYL FOX: So on behalf of the Bureau of Justice Assistance, our panelists, and the JustGrants team, we want to thank you for joining today's webinar. This will end today's presentation.
Opinions or points of view expressed in these recordings represent those of the speakers and do not necessarily represent the official position or policies of the U.S. Department of Justice. Any commercial products and manufacturers discussed in these recordings are presented for informational purposes only and do not constitute product approval or endorsement by the U.S. Department of Justice.