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JAG Recovery Act Financial and Administrative Training for Existing Subgrantees

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

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JAG Recovery Act Financial and Administrative Training for Existing Subgrantees

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

  2. New Recovery Act Requirements and Changes • Recovery Act Purpose • DUNS Number • CCR Registration • Multi Year Awards • Special Conditions • Certifications and Standard Assurances • Accountability and Transparency

  3. New Recovery Act Requirements and Changes • Financial Reporting Requirements • Programmatic Reporting Requirements • Reporting Fraud, Waste, and Abuse • Access to Records • A-133 Audit

  4. Recovery Act Purpose • Projects supported under the Recovery Act must adhere to the primary principles of the Act: • 1) creation of jobs; • 2) preservation of jobs; and, • 3) promotion of economic growth. • The Recovery Act places emphasis on accountability and transparency in the use of taxpayer dollars.

  5. DUNS 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 have their own DUNS number and utilize the State’s Tax ID number.

  6. CCR 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 entire life of the award.

  7. Multi-Year Awards • The JAG Board approved the ability to modify and renew the award for 12 months contingent upon the subgrantees fiscal and programmatic performance and with the submission of appropriate paperwork. • Multi-year awards are contingent upon the availability of U.S. Department of Justice funding.

  8. Special Conditions • Under the Recovery Act, the number of special conditions increased from 24 in 2008 to 36 in 2009. • It is important to READ and UNDERSTAND the Special Conditions.

  9. Special Conditions – Civil Rights Compliance (#11) $ Civil Rights Obligations

  10. Obligation of State Administering Agency It is the responsibility of a State Administering Agency to ensure that its subgrantees are complying with all applicable federal civil rights laws.

  11. The Office for Civil Rights Enforces Title VI of the Civil Rights Act of 1964 Program Statutes (e.g., Safe Streets Act, Victims of Crime Act, JJDPA) Section 504 of the Rehabilitation Act of 1973 Title II of the Americans with Disabilities Act of 1990 Age Discrimination Act of 1975 Title IX of the Education Amendments of 1972

  12. Special Conditions – HIDTA Deconfliction (#18) • HIDTA Deconfliction • The subgrantee agrees to use the HIDTA Deconfliction Program maintained and operated by the Oklahoma Bureau of Narcotics and Dangerous Drugs. • Must use both Event AND Subject Deconfliction • JAG Board will be reviewing reports – funding may be terminated in the future if the number of investigations don’t jive with the number of Deconfliction Reports

  13. Special Conditions – Accountability and Transparency (#28) Separate Tracking and Reporting of Recovery Act Funds • The subgrantee agrees to track, account for, and report on all funds from this Recovery Act award (including specific outcomes and benefits attributable to Recovery Act funds) separately from all other funds, including DOJ award funds from non-Recovery Act awards awarded for the same or similar purposes or programs.

  14. Special Conditions – 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 all personnel whose activities are to be charged to the award will maintain timesheets to document hours worked for activities related to this award and non-award related activities.

  15. Special Conditions – Reporting Fraud, Waste, Error and Abuse (#31) • Each subgrantee is to promptly refer to an appropriate inspector general any credible evidence that a principal, employee, agent, contractor, subgrantee, subcontractor, or other person has submitted false claim under the False Claims Act or has committed a criminal or civil violation of laws pertaining to fraud, conflict of interest, bribery, or gratuity, or similar misconduct involving Recovery Act Funds.

  16. Special Conditions – Reporting Fraud, Waste, Error and Abuse (#31) • Misuse of grant funds may result in a range of penalties, including suspension of current and future funds, suspensions or debarment from federal grants, recoupment of monies provided under a grant, and civil and/or criminal penalties.

  17. Special Conditions – Reporting Fraud, Waste, Error and Abuse (#31) • You must report potential fraud, waste, abuse, or misconduct to the U.S. Department of Justice, Office of the Inspector General (OIG) by: • Mail • Email: oig.hotline@usdoj.gov • Hotline: (contact information in English and Spanish): (800) 869-4499

  18. Special Conditions – Reporting Fraud, Waste, Error and 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.

  19. Special Conditions– Additional Requirements and Guidance (#36) • The subgrantee agrees to comply with any modifications or additional requirements that may be imposed by law and future OJP (including government-wide) guidance and clarifications of Recovery Act requirements.

  20. Financial and Programmatic Reporting Requirements DON’T SHOOT THE MESSENGER!

  21. Financial Reporting Requirements • New A-7 Form. Download new form off the website. • Will request you resubmit on the new form if you use the old one. • Fiscal reporting dates will not change but will not coincide with the programmatic reporting dates.

  22. Financial Reporting Requirements • Due Dates: • July 15th • October 15th • January 15th • April 15th

  23. Programmatic Reporting Requirements • Two Reports: • J-2 Semi-Annual Progress Report • Performance Metrics

  24. Programmatic Reporting Requirements

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

  26. Programmatic Reporting Requirements

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

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

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

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

  31. Federal Grants Division Becky Hackler JAG Program Specialist 405/264-5008 Becky.Hackler@dac.state.ok.us Karen Hess (as of 8/5/09) Drug Task Force Coordinator 405/264-5008 Karen.Hess@dac.state.ok.us

  32. Federal Grants Division Virginia Ezzell Grants Fiscal Analyst 405/264-5008 Virginia.Ezzell@dac.state.ok.us DeLynn Fudge Federal Grants Division Director 405/264-5008 DeLynn.Fudge@dac.state.ok.us

  33. Federal Grants Division www.ok.gov/dac • Federal Grants Division • Subgrantee Toolbox

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