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2012 Compliance Webinar John R. Justice (JRJ). October 17, 2012 MO Department of Public Safety Criminal Justice/Law Enforcement (CJ/LE) Unit. DEPARTMENT OF PUBLIC SAFETY CRIMINAL JUSTICE/LAW ENFORCEMENT UNIT. Eric Shepherd, Program Manager (573) 751-5997 eric.shepherd@dps.mo.gov
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2012 Compliance WebinarJohn R. Justice (JRJ) October 17, 2012 MO Department of Public Safety Criminal Justice/Law Enforcement (CJ/LE) Unit
DEPARTMENT OF PUBLIC SAFETYCRIMINAL JUSTICE/LAW ENFORCEMENT UNIT Eric Shepherd, Program Manager (573) 751-5997 eric.shepherd@dps.mo.gov Heather Haslag, Program Specialist (573) 751-1318 heather.haslag@dps.mo.gov Nancy Capps, Program Representative (573) 522-4094 nancy.capps@dps.mo.gov • Main Phone: (573) 751-4905 • Fax Number: (573) 522-1908 • CFDA #: 16.816 • https://www.cfda.gov • MO Department of Public Safety • Attn: CJ/LE • PO Box 749 • 301 W. High Street, Room 870 • Jefferson City, MO 65102 Nancy Capps is the Internal Contact for the JRJ Program and is the primary point-of-contact. Please direct your questions and concerns to Nancy.
OUTLINE FOR TODAY • General Grant Information • Service Commitment & Tax Obligation • Payment Information • WebGrants • Questions?
OVERVIEW • Authorized by 42 U.S.C 3797cc-21 • Administered by the U.S. Department of Justice (DOJ), Office of Justice Programs (OJP), Bureau of Justice Assistance (BJA) • Criminal justice system faces a challenge of retaining qualified prosecutors and public defenders • Student loan debt is consistently cited as the overwhelming reason why attorneys decline or leave positions as prosecutors and public defenders – the vast majority of law students borrow to finance their legal education but both prosecutor and public defender salaries have failed to keep pace with the escalating cost of education • Created to encourage qualified attorneys to choose careers as prosecutors and public defenders and to continue in that service • Provides loan repayment assistance
FUNDING • Bureau of Justice Statistics (BJS) calculates a minimum base allocation for each state • Base allocation is enhanced by an amount proportional to each state’s share of the national population • Must be allocated equally between prosecutors and public defenders.
CONTRACT PERIOD • October 1, 2012 to September 30, 2013 (12-months) • Funding for subsequent contract periods will be subject to 1) federal re-appropriations of such monies, 2) eligibility, and 3) availability of funds • Nothing shall obligate DPS to renew a benefit or to renew such benefit in the same (or greater) amount previously received • Must re-apply for funding each contract period
SERVICE AGREEMENT**Required by federal awarding agency** • Remain employed as a prosecutor or public defender for a period of not less than 3 years (36 months) unless involuntarily separated from employment • Service period begins with the date of award (October 1) • Recipients of renewed funding must sign a new Service Agreement to receive benefits under each new fiscal year in order to recertify their continued agreement to the original terms but the newly signed Service Agreement does not commit the individual to a new 3-year term of service. • The new Service Agreement only binds the continuing recipient to the 3-year term of service from the date of the first signed Service Agreement
TERMS & CONDITIONS OF SERVICE AGREEMENT Eligibility/Commitment: • Remain employed as an eligible beneficiary for a period of not less than 3 years (36 months) unless involuntarily separated from employment • Allowed a reasonable break in service when changing employers, not to exceed 30 days • Periods of leave without pay do not count toward the completion of the 3-year service agreement • Periods of leave with pay is considered creditable toward the completion of the 3-year service agreement (e.g. military, authorized maternity/paternity, FMLA, compensable injury, etc.)
TERMS & CONDITIONS OF SERVICE AGREEMENT cont’d Loan Status: • Grant funds are a supplement to, not a substitute for, personal student loan obligations • Remain responsible for making regular student loan payments • Must not default on any loan obligation with respect to the qualifying student loan Income Tax: • Responsible for any income tax obligations resulting from the student loan repayments
TERMS & CONDITIONS OF SERVICE AGREEMENT cont’d Changes Requiring Written Notification to DPS: • Transfer to a new position or employing agency • Must be determined by DPS to be an eligible position for continued benefits (and within a 30 day break) • Affects the “Employment Information” component • Affects the Supervisor Name signing your monthly Status Report • Involuntary separation • May affect the quarterly payments and/or disbursement of future payments • Voluntary separation, resignation, or retirement • Must be reviewed by DPS for continued eligible benefits • May affect the quarterly payments and/or return of prior payments • Paid leave status • Must be reviewed by DPS for continued benefits • Affects the timeliness, submission, and signature of the monthly Status Report(s) • Non-paid leave status • Must be reviewed by DPS for continued benefits • Must be tracked for extension of commitment • Default on loan obligation • Affects the continued quarterly payments on the qualifying student loan
TAX LIABILITY • A condition of the JRJ Program states “I am responsible for any income tax obligations resulting from the student loan repayments made on my behalf.” • The State of Missouri, Office of Administration will issue an IRS 1099-MISC form following each calendar year. • The 1099-MISC form is used to report miscellaneous income that does not fall in the category of salary, wages, or tips. • The JRJ benefits must be reported in Box 3 titled “Other Income” per the IRS. • NOTE: Prior to Tax Year 2012, OA Accounting has been reporting the benefits in Box 7 titled “Non-Employee Compensation”, which is traditionally used for self-employment income. Tax Preparers argued this practice because the amount triggers the need to pay self-employment taxes, which they would just notate as irrelevant and exclude the individual from such responsibility. • If an individual leaves employment and has to repay the grant in the same year (or prior to sending the 1099s), OA can make the change. DPS will notify OA Accounting. • If an individual leaves employment and has to repay the grant after the 1099 has been issued, it falls on the employee to make the necessary changes to their Tax Form 1040. (The 1099 was filed correctly at the time of filing.) • OA Accounting has indicated they will make the correction if the monies are returned within 5 months of the issued 1099. DPS will notify OA Accounting in this situation. DPS is not a financial advisor. If you require financial or tax advice, it is recommended you seek a professional opinion. The information provided above is per OA Accounting and is the extent of information that they can provide as well.
PAYMENT ADDRESSEE • Funds may only be paid to the institution holding the qualifying loan • May not be paid to the recipient • Recipient may hold more than one qualifying student loan but funds will only be issued to one institution, as identified in the application
INTENT OF PAYMENT • Funds are to be a supplement to, not a substitute for, personal student loan obligations • Recipients remain responsible for making regular student loan payments toward their qualifying loan • When check is mailed to the lending institution, the accompanying letter indicates that the payment should be applied to principal no-date DPS is aware that lending institutions are applying the quarterly payments to more than just principal. This has been reported to BJA each quarter, but unfortunately, neither DPS nor BJA has authority over the lending institutions to mandate them to follow different practices. The lending institutions must follow their own internal procedures, which causes the program to not meet its intended purpose.
PAYMENT SCHEDULE • Funds will be dispersed on a quarterly basis in four “equal” installments • Can access payment history through • Vendor Services Portal: https://vendorservices.mo.gov • Click “Vendor Payment” • Search by your Social Security Number • WebGrants: https://dpsgrants.dps.mo.gov • Click “My Grants” • Select appropriate grant number • Select “Quarter Payments”
WEBGRANTSDPS’ ONLINE GRANTS MANAGEMENT SYSTEMhttp://www.dpsgrants.dps.mo.gov
MAIN MENU • Grantee Instructions: general instructions and navigational aids • My Profile: maintain contact information and reset password • Funding Opportunities: displays posted program funding opportunities • My Applications: displays previously created applications • My Grants: displays awarded grants
STATUS OVERVIEW My Applications: • Submitted – application has been submitted by the grantee • Under Review – application has been assigned for review • Correcting – application is being edited by the grantee • Approved – application has been approved, following any necessary revisions by the grantee • Awarded – award of contract documents being signed by grantee and grantor My Applications – Archived Applications: • Editing – application was initiated but never submitted prior to the close of the funding opportunity • Withdrawn – application has been withdrawn from consideration by the grantor per request by the grantee My Grants: • Underway – application officially becomes a grant • Suspended – grant has been “frozen” due to delinquent reporting and/or inappropriate activities My Grants – Closed Grants: • Closed – grant has been closed by grantor
ALERTS/NOTIFICATIONS • Types of notifications: • Automated alerts triggered on grant phases (e.g. status change, submission, negotiation, approval, not approved) • Mass distribution list emails from DPS staff (e.g. reminders, updates, training notices) • Alerts sent from dpswebgrants@dps.mo.gov • Add to safe sender list • Do not overlook these alerts as they can contain important and time-sensitive information
GRANT COMPONENTS • General Information • Internal Budget • Applicant Information • Employment Information • Loan Information • Correspondence • Contract Adjustment Notices • Quarter Payments • Status Reports • Award Documents – Need Signatures • Award Documents-Final • Closeout • Opportunity • Application
GENERAL INFORMATION • Contains information relating to your contract • Identifies yourself as the Grantee Contact • Identifies your DPS Internal Contact • Identifies your DPS Contract Number
INTERNAL BUDGET • This is a read-only form for recipients • Contains the awarded amount as entered by DPS • This amount creates the basis for paying your quarterly disbursements; without a budget, the claims could not be paid
APPLICANT INFORMATION • Copy of the “Applicant Information” form completed during the application process • This component should never need updating!
EMPLOYMENT INFORMATION • Copy of the “Employment Information” form completed during the application process • This form is used to verify employment on the monthly Status Report • Change in any of the following requires a “Correspondence” be sent to DPS: • Employer • Employer Address • Work Type • Position Title • Position Status • Supervisor Name • Supervisor Job Title • Supervisor Phone Number • Supervisor Fax Number • Supervisor Email Changes in employers will be subject to review to determine continued eligibility.
LOAN INFORMATION • Copy of the “Loan Information” form completed during the application process • This form is used to verify loan status and the loan information on the monthly Status Report • Change in any of the following requires a “Correspondence” be sent to DPS: • Institution Name • Loan Account Number • Payment Remittance Address • Change in the following requires a revised Vendor Input Form be completed and submitted with the “Correspondence” to DPS: • Institution Name • Payment Remittance Address Reminder: Loans must remain in “repayment” or “forbearance” status for the duration of the contract period to continue receiving assistance.
CORRESPONDENCE • For use in communicating to DPS changes in: • Legal name • Home address • Employer (and/or employer contact info) • Separation from employer • Break in service • Paid leave status (e.g. military, maternity/paternity, FMLA) • Non-paid leave status (e.g. military, administrative, inadequate leave time) • Supervisor (and/or supervisor contact info) • Lending Institution • Loan Account Number • Payment Remittance Address • Also for use in communicating to DPS: • Desire to cancel contract prior to receiving benefits • Intent to pay off balance of loan and discontinue future benefits
CORRESPONDENCE SCREENCreating and Viewing a Correspondence… To create a new email, click “Add” Created emails will be listed below
CORRESPONDENCE cont’dSending a Correspondence… • To – select the individual you wish to send the email to (if you do not select a name, the email will send to yourself and DPS will be unaware) • CC – enter additional contacts, as applicable; must enter as an email address • Subject – enter a meaningful subject for the email • Message – provide the necessary information • Attachments – browse for the attachment, as applicable, to upload to the message • Click “Send” when complete
CONTRACT ADJUSTMENT NOTICES • This component is used by DPS to relay official documentation pertaining to budget revisions (i.e. increase in award) or program revisions (i.e. change in legal name) • Documents will only appear on this screen if there have been revisions to the contract • Select the appropriate blue hyperlink in the File Name column to open the document.
QUARTER PAYMENTS • This component will display a read-only copy of the letter and check mailed to your lending institution each quarter. • Select the appropriate blue hyperlink in the File Name column to open the document.
STATUS REPORT #1: Proof of Employment/Verification - Monthly • Recipients will be required to verify continued employment and qualifying loan status • Must submit by the 5th of each month via WebGrants: • Proof of Employment Form • Statement Due • Name on the account • Account number • Loan status • Last payment/recent activity • Account balance • Payment Remittance Address The 5th is subject to change if it falls on a weekend or holiday; deadline would change to the next business day if this occurs.
MONTHLY STATUS REPORT SCHEDULE • Monthly Status Report to verify employment and loan status are due: Create only 1 status report each month. Each time you add a status report, it is assigned a sequential number. If you create too many, use the correct template and save the others for future months.
Purpose of MonthlyProof of Employment/Verification • DPS is responsible for ensuring all recipients adhere to the following: • Employed as an eligible beneficiary • Continue to have a qualifying student loan • The qualifying loan is not in default • The qualifying loan balance exceeds the regular obligations and award amount • Regular payments are being made in addition to the benefit payments Past experience with the JRJ program has shown that recipients that fail to adhere to the guidelines and/or service agreement do not contact DPS as instructed. Therefore, DPS has to proactively collect documentation that would prove eligibility. Monitoring and audits performed by BJA support our actions and similar recommendations have been made to other states to improve internal controls.
STATUS REPORT #2:Personal Feedback - Annually • Recipients will be asked to evaluate the overall program and provide feedback to DPS • The report consists of the following questions: • How did you hear about the JRJ Program? • Was the JRJ Program a benefit to you? • Will you apply for the JRJ Program again in the future? • How would you rate the JRJ Program? • How would you rate the application process? • Other Comments/Feedback
Purpose of Annual Personal Feedback • DPS must evaluate the overall program and submit a report to BJA • DPS is only able to evaluate based on feedback and data collected from recipients Your feedback and suggestions enable DPS to adjust the program, as applicable. Some feedback relates to issues out of our control while some feedback allows us to adjust our methods and/or internal training. DPS values the time that you take to complete the evaluation form!
STATUS REPORTS SCREENCreating, Viewing, and Correcting Reports… • To create a new Status Report, click “Add” in the WebGrants toolbar • To view previously created Status Reports, select the appropriate blue hyperlink in the “ID” column of the Status Report table • To make revisions to a Status Report in “correcting” status, select the appropriate blue hyperlink in the “ID” column of the Status Report table
STATUS REPORTS cont’dStep #1: Complete & Save the General Information form • Enter the appropriate Report Period dates • Select the appropriate Status Report Type • Click “Save” when complete • Review for accuracy; click “Edit” if revisions are necessary • Click “Return to Components” if accurate and complete
STATUS REPORTS cont’dFor “Monthly” reports…Step #2: Complete the Employment/Loan Verification Form • Click the blue hyperlink component name titled “Employment/Loan Verification Form”
STATUS REPORTS cont’dFor “Monthly” reports…Step #3: Attach the Proof of Employment form & Loan Statement document • Proof of Employment Form: • Must contain original signatures (stamped signatures will not be accepted) • Loan Statement: • Must identify the following: • Your Name • Loan Status • Last Payment/Recent Activity • Account Balance • Loan Account Number • Payment Remittance Address • If you have not yet downloaded and completed the “Proof of Employment Form”, you can obtain the form from the instructions. • Once the “Proof of Employment Form” is completed and signed, scan it with your “Loan Statement” form. • Click the blue hyperlink attachment titled “Employment/Loan Verification Form”