JAG Recovery Act Financial and Administrative Training for Existing Subgrantees District Attorneys...

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JAG Recovery Act JAG Recovery Act Financial and Administrative Financial and Administrative Training for Existing Training for Existing Subgrantees Subgrantees District Attorneys Council District Attorneys Council Federal Grants Division Federal Grants Division 421 N.W. 13 421 N.W. 13 th th St., Suite 290 St., Suite 290 Oklahoma City, OK 73103 Oklahoma City, OK 73103 405/264-5008 405/264-5008 www.ok.gov/dac/ www.ok.gov/dac/

Transcript of JAG Recovery Act Financial and Administrative Training for Existing Subgrantees District Attorneys...

JAG Recovery Act JAG Recovery Act Financial and Administrative Financial and Administrative Training for Existing Training for Existing SubgranteesSubgrantees

District Attorneys CouncilDistrict Attorneys Council

Federal Grants DivisionFederal Grants Division

421 N.W. 13421 N.W. 13thth St., Suite 290 St., Suite 290

Oklahoma City, OK 73103Oklahoma City, OK 73103

405/264-5008405/264-5008

www.ok.gov/dac/www.ok.gov/dac/

New Recovery Act New Recovery Act Requirements and ChangesRequirements and Changes

Recovery Act PurposeRecovery Act Purpose DUNS NumberDUNS Number CCR RegistrationCCR Registration Multi Year AwardsMulti Year Awards Special ConditionsSpecial Conditions Certifications and Standard AssurancesCertifications and Standard Assurances Accountability and TransparencyAccountability and Transparency

New Recovery Act New Recovery Act Requirements and ChangesRequirements and Changes

Financial Reporting RequirementsFinancial Reporting Requirements Programmatic Reporting RequirementsProgrammatic Reporting Requirements Reporting Fraud, Waste, and Abuse Reporting Fraud, Waste, and Abuse Access to RecordsAccess to Records A-133 AuditA-133 Audit

Recovery Act PurposeRecovery Act Purpose Projects supported under the Recovery Projects supported under the Recovery

Act must adhere to the primary principles Act must adhere to the primary principles of the Act: of the Act: 1) creation of jobs; 1) creation of jobs; 2) preservation of jobs; and,2) preservation of jobs; and, 3) promotion of economic growth. 3) promotion of economic growth.

The Recovery Act places emphasis on The Recovery Act places emphasis on accountability and transparency in the use accountability and transparency in the use of taxpayer dollars. of taxpayer dollars.

DUNS NUMBERDUNS NUMBER

A DUNS number is a unique nine-digit number that is the universal standard for identifying and keeping track of entities receiving federal funds.

It is recommended that each DAs Office It is recommended that each DAs Office have their own DUNS number and utilize have their own DUNS number and utilize the State’s Tax ID number.the State’s Tax ID number.

CCR RegistrationCCR Registration

The CCR database is the repository for standard information about federal financial assistance applicants, recipients, and subrecipients.

Applicants must update or renew their CCR registration at least once per year to maintain an active status..

CCR registration must be active during the CCR registration must be active during the entire life of the award. entire life of the award.

Multi-Year AwardsMulti-Year Awards The JAG Board approved the ability to The JAG Board approved the ability to

modify and renew the award for 12 months modify and renew the award for 12 months contingent upon the subgrantees fiscal contingent upon the subgrantees fiscal and programmatic performance and with and programmatic performance and with the submission of appropriate paperwork.the submission of appropriate paperwork.

Multi-year awards are contingent upon the Multi-year awards are contingent upon the availability of U.S. Department of Justice availability of U.S. Department of Justice funding.funding.

Special ConditionsSpecial Conditions Under the Recovery Act, the number of Under the Recovery Act, the number of

special conditions increased from 24 in special conditions increased from 24 in 2008 to 36 in 2009. 2008 to 36 in 2009.

It is important to READ and It is important to READ and UNDERSTAND the Special Conditions. UNDERSTAND the Special Conditions.

Special Conditions – Civil Rights Special Conditions – Civil Rights Compliance (#11)Compliance (#11)

$Civil

Rights Obligation

s

Obligation of State Obligation of State Administering AgencyAdministering Agency

It is the responsibility of a State AdministeringAgency to ensure that its subgrantees arecomplying with all applicable federal civil

rights laws.

It is the responsibility of a State AdministeringAgency to ensure that its subgrantees arecomplying with all applicable federal civil

rights laws.

The Office for Civil Rights The Office for Civil Rights EnforcesEnforces

Title VI of the Civil Rights Act of 1964Title VI of the Civil Rights Act of 1964 Program Statutes (e.g., Safe Streets Act, Program Statutes (e.g., Safe Streets Act,

Victims of Crime Act, JJDPA) Victims of Crime Act, JJDPA) Section 504 of the Rehabilitation Act of 1973Section 504 of the Rehabilitation Act of 1973 Title II of the Americans with Disabilities Act of Title II of the Americans with Disabilities Act of

19901990 Age Discrimination Act of 1975Age Discrimination Act of 1975 Title IX of the Education Amendments of 1972Title IX of the Education Amendments of 1972

Special Conditions – Special Conditions – HIDTA Deconfliction (#18)HIDTA Deconfliction (#18)

HIDTA DeconflictionHIDTA Deconfliction The subgrantee agrees to use the HIDTA Deconfliction The subgrantee agrees to use the HIDTA Deconfliction

Program maintained and operated by the Oklahoma Program maintained and operated by the Oklahoma Bureau of Narcotics and Dangerous Drugs.Bureau of Narcotics and Dangerous Drugs.

Must use both Event Must use both Event ANDAND Subject Subject DeconflictionDeconfliction

JAG Board will be reviewing reports – funding JAG Board will be reviewing reports – funding may be terminated in the future if the number may be terminated in the future if the number of investigations don’t jive with the number of of investigations don’t jive with the number of Deconfliction ReportsDeconfliction Reports

Special Conditions – Accountability Special Conditions – Accountability and Transparency (#28)and Transparency (#28)

Separate Tracking and Reporting ofSeparate Tracking and Reporting ofRecovery Act FundsRecovery Act Funds The subgrantee agrees to track, account for, The subgrantee agrees to track, account for,

and report on all funds from this Recovery and report on all funds from this Recovery Act award (including specific outcomes and Act award (including specific outcomes and benefits attributable to Recovery Act funds) benefits attributable to Recovery Act funds) separately from all other funds, including separately from all other funds, including DOJ award funds from non-Recovery Act DOJ award funds from non-Recovery Act awards awarded for the same or similar awards awarded for the same or similar purposes or programs. purposes or programs.

Special Conditions Special Conditions – – Accountability and Transparency (#28)Accountability and Transparency (#28)

Accordingly, the accounting systems of the subgrantee must ensure that funds from this Recovery Act award are not commingled with funds from any other source.

The subgrantee further agrees that The subgrantee further agrees that all all personnel personnel whose activities are to be charged whose activities are to be charged to the award to the award will maintain timesheetswill maintain timesheets to to document hours worked for activities related document hours worked for activities related to this award and non-award related to this award and non-award related activities. activities.

Special Conditions – Special Conditions – Reporting Fraud, Waste, Error and Reporting Fraud, Waste, Error and Abuse (#31)Abuse (#31)

Each subgrantee is to promptly refer to an Each subgrantee is to promptly refer to an appropriate inspector general any credible appropriate inspector general any credible evidence that a principal, employee, agent, evidence that a principal, employee, agent, contractor, subgrantee, subcontractor, or contractor, subgrantee, subcontractor, or other person has submitted false claim under other person has submitted false claim under the False Claims Act or has committed a the False Claims Act or has committed a criminal or civil violation of laws pertaining to criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, or gratuity, fraud, conflict of interest, bribery, or gratuity, or similar misconduct involving Recovery Act or similar misconduct involving Recovery Act Funds.Funds.

Special Conditions – Special Conditions – Reporting Fraud, Waste, Error and Reporting Fraud, Waste, Error and Abuse (#31)Abuse (#31)

Misuse of grant funds may result in a Misuse of grant funds may result in a range of penalties, including range of penalties, including suspension of current and future funds, suspension of current and future funds, suspensions or debarment from federal suspensions or debarment from federal grants, recoupment of monies provided grants, recoupment of monies provided under a grant, and civil and/or criminal under a grant, and civil and/or criminal penalties.penalties.

Special Conditions – Special Conditions – Reporting Fraud, Waste, Error and Reporting Fraud, Waste, Error and Abuse (#31)Abuse (#31)

You must report potential fraud, waste, You must report potential fraud, waste, abuse, or misconduct to the U.S. abuse, or misconduct to the U.S. Department of Justice, Office of the Department of Justice, Office of the Inspector General (OIG) by:Inspector General (OIG) by: MailMail Email: Email: [email protected]@usdoj.gov Hotline: (contact information in English and Hotline: (contact information in English and

Spanish): (800) 869-4499Spanish): (800) 869-4499

Special Conditions – Special Conditions – Reporting Fraud, Waste, Error and Reporting Fraud, Waste, Error and Abuse (#31)Abuse (#31)

The Recovery Act provides certain protections against reprisals for employees of non-Federal employers who disclose information reasonably believed to be evidence of gross management, gross waste, substantial and specific danger to public health or safety, abuse of authority, or violations of law related to contracts or grants using Recovery Act funds.

Special Conditions– Additional Special Conditions– Additional Requirements and Guidance (#36)Requirements and Guidance (#36)

The subgrantee agrees to comply with The subgrantee agrees to comply with any modifications or additional any modifications or additional requirements that may be imposed by requirements that may be imposed by law and future OJP (including law and future OJP (including government-wide) guidance and government-wide) guidance and clarifications of Recovery Act clarifications of Recovery Act requirements. requirements.

Financial and Programmatic Financial and Programmatic Reporting RequirementsReporting Requirements

DON’T SHOOT

THE MESSENGER!

Financial Financial Reporting RequirementsReporting Requirements

New A-7 Form. Download new form off New A-7 Form. Download new form off the website. the website.

Will request you resubmit on the new Will request you resubmit on the new form if you use the old one. form if you use the old one.

Fiscal reporting dates will not change Fiscal reporting dates will not change but will not coincide with the but will not coincide with the programmatic reporting dates.programmatic reporting dates.

Financial Financial Reporting RequirementsReporting Requirements

Due Dates:Due Dates:July 15thJuly 15thOctober 15thOctober 15thJanuary 15January 15thth

April 15thApril 15th

Programmatic Programmatic Reporting RequirementsReporting Requirements

Two Reports:Two Reports: J-2 Semi-Annual Progress ReportJ-2 Semi-Annual Progress Report Performance MetricsPerformance Metrics

Programmatic Programmatic Reporting RequirementsReporting RequirementsFORM DUE DATE

FORM J-2 JAGPROGRESSREPORTProgrammatic progress report thatis due bi-annually. This reportincludes narrative data related tothe approved goals and objectivesof the project.

July 1through December 31

Due February 1, 2010

January 1through June 30

Due August 2, 2010

Programmatic Programmatic Reporting RequirementsReporting Requirements

As the state administering agency, DAC As the state administering agency, DAC is required to provide subgrantee is required to provide subgrantee performance metrics data reports to BJA performance metrics data reports to BJA ten (10) days after the end of the quarter:ten (10) days after the end of the quarter: July 31July 31 Due August 10Due August 10 October 31October 31 Due November 10Due November 10 January 31January 31 Due February 10Due February 10 April 30April 30 Due May 10Due May 10

Programmatic Programmatic Reporting RequirementsReporting Requirements

FORM DUE DATE

PERFORMANCEMETRICSNumerical dataelements must bereported on aquarterly basis.

July and August Due September 15, 2009

September, October,and November

DueDecember 15, 2009

December, January,and February

Due March 15, 2010

March, April, and May

Due June 15, 2010

June Due September 15, 2010

Access to RecordsAccess to Records

The DAC, the Office of Justice The DAC, the Office of Justice Programs, and the State Auditor have Programs, and the State Auditor have the right to access subgrantee records the right to access subgrantee records pertaining to the grant award. pertaining to the grant award.

Access to RecordsAccess to Records

This access extends to any books, This access extends to any books, documents, papers and other records of documents, papers and other records of the subgrantee that are necessary for the subgrantee that are necessary for audits, examinations, excerpts and audits, examinations, excerpts and transcripts. The subgrantee has the transcripts. The subgrantee has the same right of access to pertinent records same right of access to pertinent records of subcontractors for similar purposes. of subcontractors for similar purposes.

A-133 AuditA-133 Audit

Non-federal entities that Non-federal entities that expend expend $500,000 or more in federal funds (from $500,000 or more in federal funds (from all sources including pass-through all sources including pass-through subawards) in the organization’s fiscal subawards) in the organization’s fiscal year (12-month turnaround reporting year (12-month turnaround reporting period) shall have a single organization-period) shall have a single organization-wide audit conducted in accordance with wide audit conducted in accordance with the provisions of OMB Circular A-133.the provisions of OMB Circular A-133.

A-133 AuditA-133 Audit

An A-133 Audit can cost $30,000 so it is An A-133 Audit can cost $30,000 so it is important to understand the ramifications important to understand the ramifications of this requirement. of this requirement.

Federal Grants DivisionFederal Grants Division

Becky HacklerBecky Hackler

JAG Program SpecialistJAG Program Specialist

405/264-5008405/264-5008

[email protected]@dac.state.ok.us

Karen Hess (as of 8/5/09)Karen Hess (as of 8/5/09)

Drug Task Force CoordinatorDrug Task Force Coordinator

405/264-5008405/264-5008

[email protected]@dac.state.ok.us

Federal Grants DivisionFederal Grants Division

Virginia EzzellVirginia Ezzell

Grants Fiscal AnalystGrants Fiscal Analyst

405/264-5008405/264-5008

[email protected]@dac.state.ok.us

DeLynn FudgeDeLynn Fudge

Federal Grants Division DirectorFederal Grants Division Director

405/264-5008405/264-5008

[email protected]@dac.state.ok.us

www.ok.gov/dacwww.ok.gov/dac

Federal Grants DivisionFederal Grants Division

Subgrantee ToolboxSubgrantee Toolbox

Federal Grants DivisionFederal Grants Division