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State Cyber Crime Grant (SCCG) 2018 Compliance Training

Learn about SCCG program guidelines, funding information, budget costs, grants, and reporting requirements. Contact our program managers for more information.

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State Cyber Crime Grant (SCCG) 2018 Compliance Training

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  1. State Cyber Crime Grant (SCCG) 2018 Compliance Training Missouri Department of Public Safety Criminal Justice/Law Enforcement (CJ/LE) Unit July 27, 2017

  2. CONTACT INFORMATION Heather Haslag, Program Manager P: (573) 751-1318 E: heather.haslag@dps.mo.gov Troy Thurman, Program Specialist P: (573) 751-5997 E: troy.thurman@dps.mo.gov Laura Robinson, Program Representative P: (573) 526-1928 E: laura.robinson@dps.mo.gov Main Phone: (573) 751-4905 Fax Number: (573) 522-1908 Address: MO Department of Public Safety Attn: CJ/LE Unit PO Box 749 1101 Riverside Drive Jefferson City, MO 65102

  3. 2018 DPS “INTERNAL CONTACT” Unless noted otherwise, all grant reports and correspondence will be reviewed and processed by your designated Internal Contact. All questions and concerns should be directed to your Internal Contact as well! Monitoring will be conducted by the Internal Contact.

  4. OUTLINE FOR TODAY • General Grant Information • Budget Costs • Administrative & Financial Guidelines • Reporting Requirements • Monitoring • WebGrants • Questions?

  5. GENERAL GRANT INFORMATION

  6. BACKGROUND • Supports the continued operation of multi-jurisdictional law enforcement cyber crime task forces. • Prior to SCCG, the cyber crime task forces were funded with state Internet Cyber Crime Grant (ICCG) monies until May 2009 and then with federal Multi-Jurisdictional Cyber Crime Grant (MJCCG) monies until February 2013. • The overall purpose of the SCCG program retains the same mission, which is to support a broad range of activities to prevent and control internet sex crime as it relates to children.

  7. FUNDING

  8. GENERAL GRANT GUIDELINES • Project Period: June 1, 2017 to May 31, 2018 • No local match requirement • Eligible budget categories: • Personnel • Personnel Benefits • Personnel Overtime • Personnel Overtime Benefits • Travel/Training • Equipment • Supplies/Operations • Contractual

  9. SOURCE OF INFORMATION • DPS – CJ/LE Website: http://dps.mo.gov/dir/programs/cjle/ • CJ/LE Grant Calendar • DPS, CJ/LE – SCCG Website: http://dps.mo.gov/dir/programs/cjle/sccg.php • SCCG Fact Sheet • WebGrants Grantee Application Manual • DPS Financial & Administrative Guidelines • DPS Subrecipient Travel Guidelines • 2018 SCCG Solicitation • 2018 SCCG Pre-Bid Training (and Audio) • 2018 SCCG Compliance Training (and Audio) • WebGrants: https://dpswebgrants.dps.mo.gov • Opportunity (Funding Opportunity) • 2018 SCCG Certified Assurances • 2018 SCCG Solicitation • WebGrants Grantee Application Manual • Missouri State Statutes: http://www.moga.mo.gov/

  10. BUDGET COSTS

  11. PERSONNEL COSTS • Personnel costs must be supported with official payroll records and timesheets. • “Cover letters” will not be accepted to solely support expenses from member agencies; must obtain the official payroll documentation. • Agency should maintain documents to support all wages and fringe benefits claimed for reimbursement and maintain such documents in the grant files. • Timesheets should document all paid hours (including leave, overtime, etc) and should ideally be signed by the employee and authorizing supervisor. • If personnel costs (i.e. overtime) are paid from multiple funding sources, be sure to report hours clearly. • Section 285.530.1 RSMo indicates that an agency will not knowingly employ, hire for employment, or continue to employ an unauthorized alien to perform work within the State of Missouri. • Federal law requires every employer hiring an individual for employment in the United States to verify his or her identity and employment authorization through completion of Form I-9, Employment Eligibility Verification. • http://www.uscis.gov/portal/site/uscis

  12. TRAVEL/TRAINING COSTS • Funds will not be reimbursed prior to the actual travel. • Must submit a copy of the training certificate for travel/training costs to be reimbursed. If a training certificate is not provided, must create a memo. • Should have pre-budgeted for travel expenses based on the location of the travel/training (e.g. airport parking for out-of-state travel by plane). Either: • Submit a budget revision prior to travel if you foresee incurring an expense that isn’t approved in the budget • Don’t claim an expense that isn’t approved in the budget • Some travel costs may be unpredictable – use “Miscellaneous” as a line item for shuttles, taxis, parking, toll bridges, etc. Must be tied to a specific training! • Travel must be by the most practical and direct route! • All costs should be reasonable and prudence should be used when making travel arrangements!

  13. TRAVEL/TRAINING COSTS cont’d • Airfare/Baggage budget line • reimbursable costs include the airline ticket, baggage fees, and travel agency processing fees • other applicable fees are subject to review • does not allow for airport parking or transportation to/from the airport • costs must be supported by a receipt • Rental Car budget line • reimbursable for the cost of the rental car • cost must be supported by a receipt • Fuel budget line • reimbursable for the fuel for a rental car and/or fuel for a vehicle to and from the airport or training location • costs must be supported by a receipt

  14. TRAVEL/TRAINING COSTS cont’d • Mileage budget line • reimbursable based on the state’s mileage allowance • http://oa.mo.gov/travel-portal • rate calculated on cost to operate the vehicle based on fuel and wear and tear (cannot request fuel and mileage reimbursement) • standard “state” rate represents cost to own and operate a personal vehicle • “fleet” rate represents average cost of operating a fleet vehicle • must be supported by documentation (e.g. MapQuest, Google Maps) • does not include any miles involved in a normal commute • Lodging budget line • reimbursable based on the federal GSA rates as determined for the destination • http://www.gsa.gov/portal/category/21287 • the GSA rate is for the base nightly rate (not inclusive of taxes) • where possible should request the hotel to honor the GSA rate since travel is state funded • does not allow for hotel parking, room service, internet, telephone calls, maid tips, etc. • costs must be supported by the hotel statement (confirmation emails are not allowed as they are considered quotes and reservations may be cancelled)

  15. TRAVEL/TRAINING COSTS cont’d • Meal budget line • reimbursable based on the most restrictive travel policy – local or state • State travel policy allows for per diem rate based on the state CONUS rates as determined for the destination and for the particular meal (i.e. breakfast, lunch, or dinner) • Statewide meal per diems are set by region/city. If no city is listed, use the standard (Other) rate, which is the lowest listed. Reimbursement of meal expenses will be based on the location in which the meal expense was incurred. Therefore, the location of meals should be clearly identified. • http://oa.mo.gov/travel-portal • receipts not required (or requested) (unless required by your local travel policy); still need to maintain some type of record of meals being requested for audit/monitoring purposes (e.g. employee expense report)

  16. TRAVEL/TRAINING COSTS cont’d • Meals (cont’d) • State travel policy states individuals may claim the applicable per diem rate for each eligible meal while in travel status. • Travel status begins when you leave your residence or domicile to travel on business • Travel status ends when you return to your residence or domicile. • You are not in travel status if any part of your trip involves a commute. When your official domicile and residence are different, the travel status begins and ends based on whichever is less. • However, if your residence is less but it is necessary for you to travel to your domicile before your travel status begins; your travel status begins when you leave your domicile. For example, if you live in Columbia and you work in Jefferson City. If you leave from Jefferson City to go to Kansas City on business, your travel status begins when you leave Jefferson City.

  17. TRAVEL/TRAINING COSTS cont’d • Meals (cont’d) • To qualify for meal per diem when no overnight lodging is indicated, it must be documented that the individual was in travel status for 12 hours or more. Time of travel status start and travel status end must be indicated to confirm. • Eligible meal is defined as follows: • When twelve (12) hour travel status or overnight lodging is indicated: • Breakfast – on the day of departure if travel status begins no later than 7:00 a.m. • Lunch – on the day of departure if travel status begins no later than 10:00 a.m. and continues past 2:00 p.m. • Dinner – on the day of departure if travel status begins no later than 5:00 p.m. and continues past 7:00 p.m.

  18. TRAVEL/TRAINING COSTS cont’d • Meals (cont’d) • Tips on meals are part of the per diem rate and may not be claimed separately. • When attending a meeting or training, the subrecipientmay claim the applicable meal per diem for those meal times where it is documented that no meal was provided. However, the traveler must be in 12-hour travel status. • Subrecipientsbenefitting from a hotel provided meal should not claim that specific meal per diem. If the traveler cannot utilize the meal provided at the hotel, justification should be provided on the expense report or within an attached letter or memo for the request of that meal.

  19. TRAVEL/TRAINING COSTS cont’d • “Miscellaneous” budget line • Taxi or other ground transportation; includes tips for taxis/shuttles (receipt required) • To/from the airport to the hotel • To attend official events outside the hotel • To get a meal outside the hotel • Hotel parking (receipt required) • Airport parking (receipt required) • Street parking (no receipt required but must create a receipt or memo as documentation of the type of expense, amount of expense, date of expense, location of expense, and any other pertinent information) • Toll charges for bridges and turnpikes (receipt required)

  20. EQUIPMENT COSTS • Equipment is generally defined as non-expendable personal property having a useful life of more than one year and an acquisition cost of $1,000 or more per unit • Must adhere to most restrictive procurement policy • All equipment must be compatible with the current statewide system • Communication devices must adhere to the state’s interoperability plan • Portable radios, repeaters, and base stations have no specifications • Mobile radios must be P25 compliant and operate in the trunked mode at the time of purchase • List of compliant communication devices available at http://www.dps.mo.gov/dir/programs/cjle/jag.php

  21. SUPPLIES/OPERATIONS COSTS • Includes expendable property and operating costs • Costs must be directly attributable to the approved project • Must adhere to most restrictive procurement policy • Printed materials must acknowledge the funding source

  22. CONTRACTUAL COSTS • Includes contractual expenses and consultant fees • All contractual and consultant services shall be supported by written contracts stating the services to be performed, rate of compensation, and length of time over which the services will be performed, as applicable • Copy of all written contracts must be made available to DPS staff during site visit monitoring (or upon request) • Must adhere to most restrictive procurement policy • Agencies should attempt to enter into contracts that occur within the grant’s project period, where possible

  23. ADMINISTRATIVE AND FINANCIAL GUIDELINES

  24. PROJECT IMPLEMENTATION STATUS • “Operational” = beginning activities in which project-approved costs are being incurred (e.g. employing personnel, attending training, obtaining quotes/bids, etc) • If a project is not operational within 60 days of the project start date, the subrecipient must report to DPS, via the “Correspondence” component of WebGrants, the steps taken to initiate the project, the reasons for delay, and the expected start date. • If a project is not operational within 90 days of the project start date, the subrecipient must submit a second statement to DPS, via the “Correspondence” component of WebGrants, explaining the implementation delay. • Upon receipt of the second statement, DPS may decide whether to continue with the project or to terminate the subaward.

  25. FUNDS • Subrecipients must report, on a monthly basis, actual cash expenditures and request reimbursement. • Request for reimbursement will be handled via a “Claim” report. • Funds must be obligated within the project period and should be expended within 10 days following the project period end date. • Project Period: June 1, 2017 – May 31, 2018 • 10 Days Following: June 10, 2018 • Funds are obligated when a legal liability to pay a determinable sum for services or goods is incurred and will require payment during the same or future period. • When a purchase order is issued, funds are considered obligated • Travel expenses will only be allowed for events, training, and other activities held during the project period • Funds are expended when payment is made.

  26. INTERNAL CONTROLS • Subrecipients must track, account for, and report on all funds separately from all other funds • Grant funds may be used in conjunction with other funding as necessary to complete projects but tracking and reporting must be separate • Subrecipients should ensure appropriate internal controls exist for the programmatic and financial aspects of the project • Should be separation of duties (or layers) when it comes to the approval of timesheets/payroll or purchase approvals and payments • Procurement/purchasing policies generally outline selection, award, and administration of purchases

  27. PROCUREMENT General Grant Guidelines: • All procurement transactions whether negotiated or competitively bid, and without regard to dollar value, shall be conducted in a manner so as to provide maximum open and free competition. • All quotations and the rationale behind the selection of a source of supply must be retained, attached to the purchase order copy, and placed in the accounting files. • When only one bid or positive proposal is received, it is deemed to be sole source procurement. • Sole source procurement on purchases to a single vendor of $3,000 or more requires prior approval from the Missouri Department of Public Safety. • Request for approval shall be submitted via the “Correspondence” component of WebGrants with the rationale and a copy of the sole source certification letter from the vendor, if available. • Approval of the grant application does not constitute prior approval; must obtain separately. State Procurement Policy: • Purchases to a single vendor totaling less than $3,000 may be purchased with prudence on the open market. • Purchases to a single vendor totaling between $3,000 but less than $25,000 must be competitively bid, but need not be solicited by mail or advertisement. • Purchases to a single vendor totaling $25,000 or over shall be advertised for bid in at least two daily newspapers of general circulation in such places as are most likely to reach prospective bidders at least five days before bids for such purchases are to be opened.

  28. ACCOUNTING/FINANCIAL RECORDS • Establish and maintain accurate financial records and an adequate accounting system • Records must be retained for a period of five (5) years starting from the date of submission of the Closeout form within WebGrants or from the date of submission of the audit for the project period covered, whichever comes later. • Records must be retained beyond a five (5) year period if an audit is in progress and/or the findings of a completed audit have not been resolved. • Must adhere to local policy if local retention period is longer than those stated herein. • Records must be kept in an orderly manner and be available for audit purposes to DPS and/or representatives from the government of the State of Missouri • Responsible for protecting records against fire, theft, or other possible damages.

  29. PROPERTY RECORDS • Required to maintain property management records • Records shall contain copies of the purchase order and invoice • Quotes/bids ideally should also be maintained • Records shall include an inventory control listing for non-expendable property • Description of the item • Serial number or other identification number (e.g. VIN, make, model number, control number) • Source of Property (e.g. GR, RSAT Grant), including the subaward number (if grant-funded) • Identification of the title holder • Acquisition date • Cost of the property • Percentage of state and/or federal participation in the cost of the property • Location of the property • Use and condition of the property • Disposition data, including the date of disposal and sale price • Property must be tagged and identifiable for its source of funds, where feasible • “Purchased with 2018 SCCG Funds” • Subaward Number (e.g. 2018-SCCG-001)

  30. PROPERTY RECORDS cont’d • Control system shall be in effect to ensure adequate safeguards to prevent loss, damage, or theft to the property • Any loss, damage, or theft of non-expendable property shall be investigated, fully documented, and made part of the grant file • Should take a physical inventory of the property and reconcile the results with the property records at least once every 2 years. • Adequate maintenance procedures shall be established to keep the property in good condition

  31. PROPERTY DISPOSITION • Subrecipients are expected to use the approved equipment for the purpose for which it was acquired as long as needed. • If a SCCG-funded project ceases and there is still value in the property, DPS may request such property be made available for re-authorization to another SCCG-funded project. • Replacement: May use the equipment to be replaced as a trade-in, or may sell the equipment and use the proceeds to offset the cost of the replacement equipment • Purchase of replacement property must take place soon enough after the sale of property to show that the sale and the purchase are related. • Disposition: When original or replacement equipment acquired under an award is no longer needed for the original project, may dispose of the personal non-expendable property • Items with a current per unit fair market value of less than $5,000 may be retained, sold, or otherwise disposed of with no further obligation to DPS. • Items with a current per unit fair market value inexcess of $5,000 may be retained or sold but DPS shall have a right to an amount calculated by multiplying the current market value or proceeds from the sale by DPS’ share of the equipment. • The seller is eligible for limited sale and handling costs of $500 or 10% of the proceeds, whichever is less. • Records for non-expendable property acquired with grant funds shall be retained for five (5) years after final disposition of property

  32. AUDIT REQUIREMENTS • Audit is required if the subrecipientexpends $375,000 or more in state funds within the organization’s fiscal year from any state source (including, but not limited to, SCCG) • Audit must be performed organization-wide by an independent firm • Audit must be conducted with reasonable frequency, usually annually, but not less frequently than every two years • Doesn’t mean that the audit can include every other year though! • Must submit a copy of such audit to DPS via the “Correspondence” component of WebGrants, where possible • Can mail a copy to DPS if unable to scan the audit report

  33. PRINTING AND PUBLICITY • DPS encourages recipients of state funding to share success stories of their project • Award of funding • Major cases/investigations • Improvements in services • Educational training • Subrecipients are required to disclose of the source of their funding with language such as: This project was supported by funding made available through the State Cyber Crime Grantadministered by the State of Missouri and the Department of Public Safety.

  34. STATE CIVIL RIGHTS LAWS • Section 213.055 RSMo – Unlawful Employment Practices • May not discriminate on the basis of race, color, religion, national origin, sex, ancestry, age, or disability in its employment practices (e.g. hiring, compensation, conditions, or privileges) • Section 213.065 RSMo – Discrimination in Public Accommodations • May not discriminate on the basis of race, color, religion, national origin, sex, ancestry, or disability in the use and enjoyment of any place of public accommodation • It is unlawful to refuse, withhold from, or deny any of the accommodations, advantages, facilities, services, or privileges made available in any place of public accommodations

  35. REPORTING REQUIREMENTS

  36. REPORTING REQUIREMENT #1 - CLAIM • Must report actual expenditures and request reimbursement • Submitted via the “Claims” component of WebGrants • Funds must be obligated no later than May 31, 2018 • Funds should be expended no later than June 10, 2018 • Can claim an amount over the total budgeted line item • Allowed up to a 10% increase in a single budget line without a budget revision • Exceeding the 10% increase will be subject to review by DPS • Not receiving additional monies but rather “borrowing” it from elsewhere in the budget • Increases in excess of 10% require a budget revision through the “Subaward Adjustment” component of WebGrants • Will be reviewed, negotiated, and approved by your DPS Internal Contact • Payments made around the 25th of each month via EFT • Vendor Services Portal: https://www.vendorservices.mo.gov/vendorservices/Portal/Default.aspx • SCCG Prefix Payment Code = PG087

  37. CLAIM REPORT NOTES • Must submit a Claim report for each month of the project period, even if the Claim is $0.00, until your grant is closed (or until the subaward is exhausted) • Manmade “invoices” will not be accepted in place of official documentation for expenditures • Official company documents must be provided to verify costs • Must submit supporting documentation with Claim report • Reimbursement is only allowed for employer costs • Claim reports can be negotiated by DPS if determined revisions are necessary • If DPS adjusts the Claim (or has to make adjustments that do not affect the overall reimbursement amount), a comment will be displayed in the Feedback section - - check this! • If you determine that revisions are necessary once the Claim report has been submitted, contact your DPS Internal Contact to unlock the specified form(s).

  38. CLAIM REPORT NOTES cont’d • Watch your payroll and billing periods • Costs must be pro-rated by the total number of days in the billing or payroll period rather than the number of working days • Example 1: Salary of $1,200 for the payroll period of 5/22/17 – 6/4/17 • ($1200/14 days) x 10 days = $857.14 must be claimed to the 2017 SCCG grant • ($1200/14 days) x 4 days = $342.86 must be claimed to the 2018 SCCG grant • Example 2: Internet bill to AT&T totaled $100 for 5/25/17 to 6/24/17 • ($100/31 days) x 7 days = $22.58 must be claimed to the 2017 SCCG grant • ($100/31 days) x 24 days = $77.42 must be claimed to the 2018 SCCG grant • Leave the calculation in your calculator until a total is determined! • Familiarize yourself with the billings • Pre-tax deductions reduce the amount of Social Security and Medicare withholdings for the employee and employer • Help DPS in identifying which codes or lines are pre-tax deductions! • Insurance premiums are often paid the month prior to the coverage period • Help DPS in identifying the period for which the insurance is being paid • Unemployment Comp is typically paid on the first $13,000 of wages for the calendar year OR not paid at all until a claim is filed by the former employee • Workers Comp is not based on a straight job classification rate • Recommend using the Workers Comp calculator spreadsheet created by DPS for another grant program

  39. CLAIM COMPONENTS There are 5 forms to the Claim report: • General Information: used to identify the reporting period and the type of report • Reimbursement: used to identify the State Share per budget line; the totals are aggregate totals from the ‘Detail of Expenditure’ form • Detail of Expenditure: used to identify the pay check number, pay date, payee, description, total cost, percent of funding requested, and amount claimed to grant for reimbursement per cost activity • Program Income: used to identify any monies earned and/or expended as a result of the grant-funded project • Attachments: used to upload copies of documentation to support the expenditures

  40. SCCG CLAIM REPORT SCHEDULE • Only 1 Claim report should be submitted for each reporting period • The above-mentioned deadlines are extended if the subaward is not “Underway”

  41. REPORTING REQUIREMENT #2 – STATUS REPORTS • Subrecipients must report statistical data, as well as any other activities, successes, and/or obstacles as desired • Organization • Employees • Investigations/Referrals • Cybertips • Forensic Examinations • Arrest Activity • Child Victims • Search Warrants • Court Activity • Computer-Crime Prevention & Education Programs/Presentations • Narrative • Reports must be submitted via the “Status Reports” component of WebGrants

  42. STATUS REPORTS cont’d • Reminder alerts will be sent by DPS staff from WebGrants approximately 1-2 weeks prior to the deadline • Will be reviewed and approved by your DPS Internal Contact prior to review by CJ/LE Program Manager • Status Reports can be negotiated by DPS if determined revisions are necessary • If you determine that revisions are necessary once the Status Report has been submitted, contact your DPS Internal Contact to unlock the specified form • Compiled by MSHP-SAC for publications and state reporting purposes

  43. SCCG STATUS REPORT SCHEDULE • The above-mentioned deadline for #01 can be extended if the subaward is not yet “Underway” by the deadline

  44. MONITORING

  45. MONITORING • CJ/LE will conduct monitoring of the project to ensure compliance with state laws, regulations, and guidelines • Desk Monitoring – tracking telephone and email communication, as well as reviewing all grant documents, reports, and correspondence • Site Monitoring – a visit the agency’s office(s) to review policies, property records, and other documents • CJ/LE will take appropriate action if determined the subrecipient is acting inappropriately, misusing money, and/or not meeting reporting requirements • Such action may result in delay of reimbursement of funds and/or cancellation of the contract

  46. MONITORING CHECKLIST – FINANCIAL • Personnel • payroll records to support salary, overtime, and fringe benefits (submitted with the Claim already) • timesheets • Travel/Training • receipts, travel vouchers, and/or expense reports, as applicable (submitted with the Claim already) • certificate of attendance (submitted with the Claim already) • Equipment • invoices/receipts from vendor(submitted with the Claim already) • bid records and/or sole source letters, where applicable • Supplies/Operations • invoices/receipts from vendor (submitted with the Claim already) • bid records and/or sole source letters, where applicable • Contractual • invoices/receipts (submitted with the Claim already) • bid records and/or sole source letters, where applicable • contractual agreements

  47. MONITORING CHECKLIST - PROGRAMMATIC • Personnel files for grant-funded staff • Particularly whether resumes/applications are on file • Training plan for grant-funded staff • Personnel manual; SOPs for agency operations • Local travel policy • Local procurement/purchasing policy • Inventory control listing for equipment • Tags/labels on equipment • Internal controls

  48. MONITORING CHECKLIST – STATE STATUTES FOR LEAs • Section 43.505 RSMo - Monthly Uniform Crime Reporting (UCRs) • DPS will verify with MO State Highway Patrol on monthly compliance • Section 590.650 RSMo - Annual Racial Profiling Reporting • DPS will verify with the Attorney General’s Office on annual compliance • Section 513.653 RSMo - Annual Federal Forfeiture Report • DPS will verify with the State Auditor’s Office on annual compliance, where applicable • Section 590.700 RSMo - Recording of Custodial Interrogations • Must present DPS with a copy of the department’s written policy • Section 43.544 RSMo - Forwarding Intoxication-Related Offenses • Must present DPS with a copy of the department’s written policy

  49. MONITORING CHECKLIST – STATE STATUTES FOR CIVIL RIGHTS • Section 213.055 RSMo – Unlawful Employment Practices For example: • Does your agency’s job announcements and employment applications include an “Equal Opportunity Employer” statement? • Does your agency display the required labor law posters (http://labor.mo.gov/content/mandatory-posters)? • Does your agency maintain a written policy on non-discrimination and/or non-harassment in the workplace? • Does your agency maintain a written policy to notify employees on how to file complaints alleging discrimination?

  50. MONITORING CHECKLIST – STATE STATUTES FOR CIVIL RIGHTS cont’d • Section 213.065 RSMo – Discrimination in Public Accommodations For example: • Does your agency display the required labor law posters (http://labor.mo.gov/content/mandatory-posters) (e.g. Discrimination in Housing and Discrimination in Places of Public Accommodations)? • Does your agency notify its citizens or program participants that it will not discriminate in the delivery of its services (e.g. brochures, posters, website, mission statement)? • Does your agency ensure its facilities are ADA accessible? • Does your agency maintain a written policy on ADA? • Does your agency maintain a written policy to notify employees and/or citizens on how to file complaints alleging discrimination in public accommodations?

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