2013 LLEBG Compliance Webinar

1. 2013 LLEBG Compliance Webinar January 9, 2013 MO Department of Public Safety

2. DEPARTMENT OF PUBLIC SAFETYCRIMINAL JUSTICE/LAW ENFORCEMENT UNIT Heather Haslag, Program Specialist (A to G) (573) 751-1318 heather.haslag@dps.mo.gov Nancy Capps, Program Representative (H to N) (573) 522-4094 nancy.capps@dps.mo.gov Sarah Verhoff, Program Representative (O to Z) (573) 526-1928 sarah.verhoff@dps.mo.gov • Main Phone: (573) 751-4905 • Fax Number1: (573) 522-1908 • Fax Number2: (573) 751-5399 • CFDA #: 16.738 • MO Department of Public Safety • Attn: CJ/LE • PO Box 749 • 301 W. High Street, Room 870 • Jefferson City, MO 65102

3. OUTLINE FOR TODAY • General Grant Information • Budget Costs • Administrative & Financial Guidelines • Civil Rights Compliance • Reporting Requirement • Monitoring • WebGrants • Questions?

4. GENERAL GRANT INFORMATION

5. BACKGROUND Local Law Enforcement Block Grant (LLEBG) • provided through federal Byrne/JAG program • authorized by 42 U.S.C. 3751(a) • awarded to Missouri by the U.S. Department of Justice (DOJ), Office of Justice Programs (OJP) • provides federal criminal justice funding • streamlined the Byrne and LLEBG programs

6. FUNDING • Calculated by the Bureau of Justice Statistics (BJS) Missouri Base Allocation <$10K Allocations >$10K Allocations JAG (Base $) Department of Public Safety Local Units of Government LLEBG (<$10K $)

7. SOURCE OF INFORMATION • DPS Website: http://www.dps.mo.gov/dir/programs/cjle/llebg.asp • Solicitation • Compliance Webinar Training Powerpoint • WebGrants How-to-Apply Guide • Radio Interoperability Guidelines • LLEBG Fact Sheet • WebGrants: https://dpswebgrants.dps.mo.gov • Opportunity (Funding Opportunity) • Office of Justice Programs (OJP) Financial Guide: http://www.ojp.usdoj.gov/financialguide/index.htm • Office of Management and Budget (OMB) Circulars: http://www.whitehouse.gov/omb/circulars_default • Missouri State Statutes: http://www.moga.mo.gov/statutesearch/

8. BUDGET COSTS

9. ALLOWABLE & UNALLOWABLE COSTS • Eligible costs = equipment and equipment-related costs • Allowable costs = those included within your approved application • limited to no more than the quantity approved • limited to the type of item approved (can purchase a different model or manufacturer) • Unallowable costs = listed in the grant solicitation OJP Financial Guide and OMB Circulars A-87 & A-122 outline allowable and unallowable cost items for DPS

10. EQUIPMENT COSTS • 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 • Equipment must be tagged (where feasible) • Must maintain an inventory control listing

11. ADMINISTRATIVE AND FINANCIAL GUIDELINES

12. FUNDS • Contractors must report actual cash expenditures and any program income/interest that was earned • Expenditures will be reported through a “status report” • Funds must be obligated within the contract period and expended within 60 days following the contract period end date • Contract Period: January 1, 2013 to June 30, 2013 • 60 days following: August 29, 2013 • 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 (e.g. purchase order date) • Funds are expended when payment is made.

13. INTERNAL CONTROLS • Agency must track, account for, and report on all funds separately from all other funds • DPS encourages agencies to open a separate account for the LLEBG grant share and the local match share but does not require it if the unit of government has adequate internal controls • Account may be interest bearing • Any interest earned must be disclosed and reported as program income • Any interest not spent on program-related costs must be returned to DPS • Grant funds may be used in conjunction with other funding as necessary to complete projects but tracking and reporting must be separate • Agency should ensure appropriate internal controls exist for the programmatic and financial aspects of the project

14. PROCUREMENT • 28 CFR, Part 66: Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments • OMB Circular A-110: • 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 amounts of $3,000 and over require prior approval from DPS. • Items costing less than $3,000 may be purchased with prudence on the open market • Items costing between $3,000 but less than $25,000 must be competitively bid, but need not be solicited by mail or advertisement. • Items costing $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.

15. GRANT RECORDS • Establish and maintain accurate financial records and an adequate accounting system • Records must be retained for a period of 3 years starting from the date of submission of the final Claim Report or from the date of submission of the audit for the contract period covered, whichever comes later. • Records must be retained beyond a 3 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. • Financial records must be kept in an orderly manner and be available for audit purposes • Responsible for protecting records against fire, theft, or other possible damages

16. PROPERTY RECORDS & DISPOSITION • Required to maintain property management records • Records shall contain copies of the purchase order and invoice • 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 • Adequate maintenance procedures shall be established to keep the property in good condition • May dispose of the personal non-expendable property when original or replacement equipment acquired under an award is no longer needed for the original project • 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 in excess of $5,000 may be retained or sold but the 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 • Records for non-expendable property acquired with grant funds shall be retained for 3 years after final disposition of property

17. AUDIT REQUIREMENTS • Comply with OMB Circular A-133 “Audits of States, Local Governments, and Non-Profit Institutions” - - http://www.whitehouse.gov/omb/circulars_default • Audit is required if the agency expends $500,000 or more in federal funds within the organization’s fiscal year from any federal source • 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

18. PRINTING AND PUBLICITY • BJA and DPS encourage recipients of federal funding to share success stories of their project • Award of funding • Major cases/investigations • Improvements in services provided as a result of equipment purchases • Agencies are required to disclose of the source of their funding with language such: Funding for this project made available by the Edward Byrne Memorial Justice Assistance Grant, which is administered by the U.S. Department of Justice, Bureau of Justice Assistance and the State of Missouri, Department of Public Safety

19. CIVIL RIGHTS COMPLIANCE

20. CIVIL RIGHTS LAWS • Civil Rights Act of 1964 (42 U.S.C. § 2000d) • Rehabilitation Act of 1973 (29 U.S.C. § 794) • Title IX of the Education Amendments of 1972 (20 U.S.C. § § 1681, 1683, and 1685-86) • Age Discrimination Act of 1975 (42 U.S.C. § § 6101-07) • Americans with Disabilities Act of 1990 (42 U.S.C. § § 12131-34) • U.S. Department of Justice Regulations – Non-Discrimination; Equal Employment Opportunity; Policies and Procedures (28 C.F.R. pt 42) • U.S. Department of Justice Regulations – Equal Treatment for Faith Based Organizations (28 C.F.R. pt 38) • Executive Order 13279 (equal protection of the laws for faith-based and community organizations) • Section 213.055 RSMo– Unlawful Employment Practices • Section 213.065 RSMo– Discrimination in Public Accommodations

21. EQUAL EMPLOYMENT OPPORTUNITY PLAN (EEOP) • A workforce report completed to ensure recipients of federal funding are providing equal employment opportunities to men and women regardless of sex, race, or national origin. • Includes data relating to recruitment, applicant screening, hiring, promotion, termination, transfer, and discipline • Effective for a 2-year period, commencing with the date of the approval letter from the Office of Civil Rights (OCR) • Should be prepared by the recipient of the federal funding (applicant agency: county, city, university) • http://www.ojp.usdoj.gov/ocr Not the same as an EEO4, which is required by the U.S. Equal Employment Opportunity Commission and includes salary data!

22. EEOP cont’d SAMPLE COVER SHEET Date-stamped when prepared

23. EEOP cont’d Is the agency a state or local government agency, employ 50 or more individuals, AND a recipient of a single award of $25,000 or more? NO YES Must prepare EEOP Short Form Must complete Section A of the Certification Form and send to OCR for exemption of preparing an EEOP Did the agency receive a single award of $500,000 or more? NO YES Must complete Section B of the Certification Form and send to OCR for exemption of submission Must send EEOP Short Form to OCR

24. NON-DISCRIMINATION • Contractor may not discriminate on the basis of race, color, national origin, religion, sex, or disability in its employment practices or in the delivery of services • If the Contractor has 50 or more employees and receives DOJ funding of $25,000 or more: • the Contractor must have written policies or procedures in place to notify program participants and employees on how to file complaints alleging discrimination • the Contractor must designate a person(s) to coordinate complaints alleging discrimination

25. FINDINGS OF DISCRIMINATION • Contractor must notify DPS of any findings of discrimination within 30 days of the court judgment • Submit the Court Judgment with a cover letter, which identifies your DPS-assigned contract number, as indicated on the Award of Contract • DPS must forward to the Office of Civil Rights (OCR) Missouri Department of Public Safety Attn: Director of Public Safety PO Box 749 301 W. High Street, Room 870 Jefferson City, MO 65102

26. LIMITED ENGLISH PROFICIENCY (LEP) • Contractor must take steps to provide meaningful access to its programs and activities to persons with LEP • Oral Interpretation • Written Interpretation • Recommended (but not yet required by law) that the Contractor develop a written policy on providing language access services to LEP persons • For more information on LEP, planning tools, or sample law enforcement policies, go to http://www.ojp.usdoj.gov/about/ocr/lep.htm

27. REPORTING REQUIREMENT

28. REPORTING REQUIREMENT – STATUS REPORT • Must submit a status report to report actual expenditures and to provide receipts to support the purchase(s) • Should submit shortly after all equipment has been purchased and funds have been fully expended • Must purchase between January 1, 2013 and June 30, 2013 • Must pay for purchases no later than August 29, 2013 • Status Report due by September 10, 2013 • Submit only 1 status report! • Status Report consists of 5 components: • General Information • Expenses • Detail of Expenditure • Program Income • Attachments

29. MONITORING

30. MONITORING • Each grant will be assigned for oversight to a staff member of the Criminal Justice/Law Enforcement (CJ/LE) Unit • A to G: Heather Haslag • H-N: Nancy Capps • O to Z: Sarah Verhoff • CJ/LE will conduct monitoring of the project to ensure compliance with state and federal laws, regulations, and guidelines • Desk Monitoring – tracking telephone and email communication, as well as reviewing all grant documents and correspondence; could also consist of a request to have documentation submitted • Site Monitoring – a visit the agency’s office(s) to review policies, receipts, and other records • CJ/LE will take appropriate action if determined the Contractor is acting inappropriately, misusing money, and/or not meeting reporting requirements • Such action may result in the cancellation of the contract and legal action to recoup any funds disbursed to the agency

31. MONITORING CHECKLIST • FISCAL • Purchase Order/Requisition (submitted with Status Report) • Invoices/receipts from vendor(submitted with Status Report) • Bid records and/or sole source letters, where applicable • PROGRAMMATIC • Local procurement policy • Inventory control listing for equipment • Tags/labels on equipment • Internal controls

32. MONITORING CHECKLIST – STATE CIVIL RIGHTS • Section 213.055 RSMo– Unlawful Employment Practices • Does your organization’s job announcements/applications include the “Equal Opportunity Employer” statement? • Does your organization display the required labor law posters? • Does your organization maintain a written policy on non-discrimination (and non-harassment) in the workplace? • Does your organization maintain a written policy to notify employees on how to file complaints alleging discrimination? • Section 213.065 RSMo– Discrimination in Public Accommodations • Does your organization display the required labor law posters? • Does your organization 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 organization ensure its facilities are ADA accessible? • Does your organization maintain a written policy on ADA non-discrimination? • Does your organization maintain a written policy to notify employees and/or citizens on how to file complaints alleging ADA discrimination?

33. MONITORING CHECKLIST – FEDERAL CIVIL RIGHTS • EEOP • Is your agency required to prepare an EEOP? • If your agency is not required to prepare an EEOP, has your agency submitted Section A of the Certification Form? • If your agency is required to prepare an EEOP, has your agency prepared an EEOP Short Form? • If your agency is required to prepare an EEOP and is required to submit a copy to OCR, has your agency submitted the EEOP Short Form to OCR? • If your agency is required to prepare an EEOP but is not required to submit the EEOP Short Form to OCR, has your agency submitted Section B of the Certification Form to OCR? • Non-Discrimination Policies and Procedures • How does your agency notify program beneficiaries that it will not discriminate in the delivery of services (e.g. posters, inclusion in brochures, or other program materials)? • How does your agency notify employees that it will not discriminate in employment (e.g. posters, dissemination of relevant orders or policies, inclusion in recruitment materials)? • Does your agency have written policies and procedures informing program beneficiaries and employees how to file a complaint if they feel like they’ve been discriminated against? • Has your agency designated a person(s) to coordinate complaints of discrimination?

34. MONITORING CHECKLIST – FEDERAL CIVIL RIGHTS cont’d • Forwarding of Findings of Discrimination • Does your agency have court findings of discrimination within the contract period? • If so, has your agency complied with the requirement to forward findings of discrimination to DPS, if applicable? • Access to services for LEP individuals • How does your agency make meaningful access to persons with limited English proficiency (e.g. direct foreign language communication by fluent bilingual staff, interpretation conducted in-person or via telephone by qualified interpreters, translation by qualified translators, etc.)? • Does your agency have written policies or procedures on LEP services? • Civil Rights Training • Does your agency provide civil rights training to its employees (e.g. cultural diversity, racial profiling, sexual harassment, etc.)? • How often does your agency provide civil rights training to its employees?

35. WEBGRANTSDPS’ ONLINE GRANTS MANAGEMENT SYSTEMhttp://www.dpsgrants.dps.mo.gov

36. REGISTERED USERS “My Profile” module: • Maintain profile and contact information • Maintain organization’s information • Do not change the Applicant Agency name though! • Add additional registered users • Add only if individual is not already a user • Notify DPS to add if individual is already a user associated with a different grant • Notify DPS via the “Correspondence” component of WebGrants if you add a new individual or else the person will not receive alerts

37. 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/Notifications are sent from dpswebgrants@dps.mo.gov • Add to safe sender list or a contact list to avoid being treated as junk/spam • Do not overlook these alerts as they can contain important and time-sensitive information • While the record is in the “My Applications” module, only the Primary Contact receives system-generated alerts • While the record is in the “My Grants” module, the Primary Contact and Additional Grantee Contacts, as applicable, receive system-generated alerts

38. 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

39. GRANT COMPONENTS • General Information • Contact Information • Correspondence • Budget • Contract Adjustments • Contract Adjustment Notices • Status Reports • Site Visits • Award Documents – Need Signatures • Award Documents – Final • Attachments • Closeout • Opportunity • Application DEMO SCREENSHOT This toolbar will appear on EVERY screen. Options that are not applicable to the screen will be grayed out.

40. COMPONENT #1: GENERAL INFORMATION DEMO SCREENSHOT

41. GENERAL INFORMATION • Contains information relating to your contract • Identifies your Primary Grantee Contact and Additional Contacts • Identifies your DPS Internal Contact (a.k.a. Additional Internal Contacts) DEMO SCREENSHOT If someone is a registered user with your organization but is not listed here, contact DPS via the “Correspondence” component! They are not receiving alerts! Check this form now…and after any change of informations!!

42. COMPONENT #2: CONTACT INFORMATION DEMO SCREENSHOT

43. CONTACT INFORMATION The Contact Information component is a copy of the form completed during the application process. Edits cannot be made to this page by the grantee. If changes need to be made to this form at any time during the contract period, need to submit an email to your grant point of contact via the Correspondence component and include in your message the applicable changes to: • Name • Agency • Address (both mailing and street address) • Email • Phone and Extension • Fax • Also indicate the effective date of the change! DEMO SCREENSHOT DPS will make the changes to this page based on your email.

44. COMPONENT #3: CORRESPONDENCE DEMO SCREENSHOT

45. CORRESPONDENCE The Correspondence component allows you to communicate to your grant point-of-contact and/or for the MO Department of Public Safety to communicate to you. For use in communicating to DPS for: • Changes to the Contact Information form • New registered user has been added to the organization’s profile • Existing registered user should be removed as a contact and registered user • Requesting sole source procurement approval • Submitting the agency’s audit per Circular A-133 To send a Correspondence, click the “Add” button on the right-hand side of the screen DEMO SCREENSHOT A list of correspondence will appear in the table once sent.

46. CORRESPONDENCE cont’d Select your recipient in the To box (the names that appear will be the names listed on the General Information form) Enter additional email addresses in the CC box if you need to carbon copy someone. If entering multiple emails, separate the email addresses with a semi-colon (;) Enter a subject that is meaningful Enter the message Browse for the document to attach, where applicable Click “Send” DEMO SCREENSHOT

47. COMPONENT #4: BUDGET DEMO SCREENSHOT

48. BUDGET The Budget component is a copy of the form completed during the application process. Edits cannot be made to this page by the grantee. Grantees were approved for a specified quantity of a type of equipment. You can NOT purchase more than the quantity identified in the budget with grant funds. You CAN purchase a different model than specified and/or from a different vendor source than specified but you must still purchase the type of item requested (e.g. lightbar, siren, in-car camera, portable radio, handcuff, etc). If changes need to be made to this form, you need to submit a budget revision request via the Contract Adjustment component at least 30 days prior to the end of the contract period. DEMO SCREENSHOT

49. COMPONENT #5: CONTRACT ADJUSTMENT DEMO SCREENSHOT

50. CONTRACT ADJUSTMENTS - TYPES • Program Revisions (unlikely to occur) • Change in legal name of your applicant agency • Change in project site or service area • Other changes that may affect the approved program • Budget Revisions • Need to add a line item that doesn’t exist in your current budget • Want to purchase a larger quantity of an item than what is approved in your current budget • Removal of a line to reallocate funds to other lines