2. Step 2. Understand Grants Monitoring Step 1. Know the Basics Step 4. Follow the Rules and Regulations Step 3. Properly Close Out the Grant Step 5. Use Sample Forms

3. Step 1. Know the Basics

4.  Email is Preferred (firstname.lastname@governor.state.tx.us)firstname.lastname@governor.state.tx.us  Include Grant Number in all Correspondence  CJD Main Number (512) 463-1919  Notify CJD Immediately If You Get a Public Information Request

5. Appointed or authorized by the governing body.

6. Must be the chief financial officer for the grantee agency.

7. Responsible for the day-to-day operations of the project including programmatic reporting.

8. Failure to accept your award within 45 days could result in forfeiture of grant funding.

9. Project Not Operational Within 60 Day Grantee must report to CJD the steps taken to initiate the project, the reasons for delay, and the expected revised start date. Project Not Operational Within 90 Day Grantee must submit a statement to CJD explaining the delay. CJD may cancel the project or extend the implementation date past the 90-day period.

10. All funds must be paid through direct deposit.

11.  Texas Application for Payee Identification Number – http://www.window.state.tx.us/taxinfo/taxforms/ ap-152.pdf  Vendor Direct Deposit Authorization Form – http://www.window.state.us/taxinfo/taxforms/74 -176.pdf  Internal Revenue Service Form W-9 - http://www.irs.gov/pub/irs- pdf/fw9.pdf?portlet=3

12. Quarterly or Monthly SubmissionsMust Report Cumulative ExpensesReimbursement Basis

13. Calendar QuarterDue Date January 1 – March 31April 22 April 1 – June 30July 22 July 1 – September 30October 22 October 1 – December 31January 22

14. IMPORTANT CHANGE

15.  All Financial Status Reports must be submitted through eGrants.  For a step by step guide to creating and submitting FSRs see the eGrants Financial Management Guide. Financial Management Guide

16. Final date to report expenditures Default liquidation date is - 90 calendar days after the grant ends Expenditures not reported to CJD by the liquidation date will result in a loss of funds for the project

17. instructions for accessing the PPRI website http://cjd3.tamu.edu/ http://cjd3.tamu.edu/ user name/log-in and password number and types of reports required for the applicable fund source  Required by CJD  Collected by Texas A&M Public Policy Research Institute (PPRI)  Reporting packets include:

18. All payments to an agency for all grant funded projects will be held. Reasons for vendor hold include: Delinquent programmatic progress reports Delinquent financial status reports Delinquent single audit reports Unresolved monitoring findings Non-Compliance with State or Federal rules and regulations

19. Must be submitted through eGrants and Certified by the Authorized Official Grant Officials or Address Changes Programmatic Changes Budget Changes Grant Period Extensions Grant Adjustment Types 10% of Cumulative Expenditures can be moved without CJD’s Prior Approval (except within Equipment and Indirect Costs)

20. Notify CJD within 20 Days of Changes to Grant Officials or Address Changes Changes to existing grant officials Add new grant officials Agency or project address changes

21. Types of Programmatic Adjustments Changes to the Project Narrative New or different Project Activities Changes to the Performance Measures New or different Population or Geographic Area Changes to the Agency Name or Project Title New or different Vendor/Payment Information

24. Personnel Contractual / Professional Services TravelIndirect CostsConstruction Supplies and DOEs Equipment

25.  Time/Activity Reports  Case Numbers for Grant-Funded Law Enforcement and Prosecution Personnel  Volunteer Activities  Signed Timesheet  Salaries Consistent with Local Policy  Backfill of Existing Positions  Overtime

26. Contractual and Professional  Contracts in Writing  Consistent with Texas Contract Law  Contract Monitoring Documentation  Compliance with Agency Procurement Guidelines  Invoices for Contract Deliverables  CJD-Prescribed Procurement Questionnaire

27. Travel  Employee Travel and Training Only  Comply with Agency Travel Policies or State Travel Policies  Maintain Travel Log and Travel Receipts  Pre-Approval of Out-of-State Travel NOTE: Expenses for Outside Trainers go under the Contractual Budget Category.

28. Equipment  All purchases MUST be pre-approved by CJD  Must maintain Inventory  Procurement Questionnaire for purchases in Excess of $100,000  Must have invoices to support purchases  Must be used for the purpose for which it is purchased  All changes to Equipment Line Items (including the number of items) MUST be approved by CJD

29. Construction This budget category is currently unavailable for CJD funded projects.

30. Supplies & Direct Operating Expenses  Related to the daily operation of the CJD grant  All costs MUST be Pro-Rated  Rent or Lease MUST include cost/sq. ft. and the number of square feet  Documentation (ex. receipts, invoices) MUST be maintained  Includes small equipment

31. Indirect Costs  When allowed, the standard rate is 2% of CJD- funded direct costs (NOTE: this is NOT the CJD Award Amount)  Cognizant agency approval letter required for requests in excess of 2%  ALL rates are negotiable

32. Matching Funds  Cash or In-Kind  Held to Percentage in Approved Budget  Federal Funds CANNOT be used to meet match requirements

33. Step 2: Understand Grants Monitoring Rebecca Martinez, CFE, CGAP, CIA Director of CJD’s Grants Monitoring

34. Grants Monitoring Overview Reviewing & Testing Recurring Findings Technical Assistance Questions & Answers

35. What is grants monitoring? “The process of reviewing grant documentation to ensure that grant funds are used for authorized purposes.”

36.  Desk reviews  Site reviews  Grantee contact visits (informal)  1 st year COG Checklist Analyses (site reviews and phone contact)

37.  Perform a risk assessment of grantees.  Develop a monitoring schedule for the year.  Carry-out monitoring schedule (Plan our work & work our plan.)  Monitoring schedules are subject to change.  In most instances, we provide a 2 week advance notice of the reviews to grantees and COG planners.

38.  Funding: The more money awarded, the higher the risk of misspent funds ($10,000 vs. $1,000,000).  No. of grants: The greater the number of grants awarded, the higher the exposure to non-compliance of requirements. (1 grant vs. 7 grants)  Based on risk factors, grantees are assigned a risk rank: high risk, medium risk, or low risk.

39.  A Monitoring Plan is developed from the risk assessment report.  Grantees in each level (high risk, medium risk, low risk) are reviewed.  Grantees are scheduled for review on a rotation basis.

40.  Notify grantee of upcoming desk review.  Gather and analyze grant documents from the grantee.  Call grantee and conduct a phone interview regarding issues noted.  Complete examination and issue a report.  Follow-up with grantee on issues.

41.  Site reviews are scheduled with the grantees. Dates, times, and locations are set.  A notification letter is sent to the grantee. It includes a list of documents to be examined.  Reviews are conducted at the grantee’s office. Reviews may last from 2 to 5 days, depending on the size and complexity of the grant.  Monitors continue the analysis of support documentation and calculating of expenses, back at CJD.  Written reports of the review are prepared and submitted to grantees for response.

42.  Entrance conference.  Examine documents, select samples, test transactions, discuss issues with grantees. Make copies for analysis later. (Monitors time is very limited while on-site.)  Exit conference.

43.  General Grant Administration: FSR, program income, Single Audit  Personnel: payroll, personnel activity reports, timesheets  Contractual Services: contracts, contract monitoring, procurement questionnaire  Travel: invoices, receipts, training certificates  Equipment Inventory: inventory list, physical observation, procurement questionnaire  Construction: pre-approval, change orders  Supplies: invoices, receipts  Indirect Costs: 2% limit, cost allocation plan  In-Kind or Cash Match: what is used as match, how much has been provided, volunteer timesheets  Program Issues: specific to the unique program, program records

44.  Monitors continue to examine and analyze documents back at the CJD office.  The further analysis of the grantee’s documents may result in additional findings. If this occurs, the grantee will be contacted to discuss the finding and may be able to clear the issue with supplemental documentation or information.  All findings will be presented in the report and the grantee will have an opportunity to respond.

45.  Issue Draft report (includes requirements, findings, and recommendations). Grantee has 15 days to respond with corrective action.  Receive grantee responses & corrective action.  Analyze responses. Issue Second draft report, if necessary. Reports will include the grantee’s responses.  Receive grantee responses & corrective action  Analyze responses. Issue Final report.  (If necessary) Receive grantee responses and corrective action.  Issue Closeout letter. Review is complete.

47.  Single Audit issues  FSR/PPRI reports submitted late  Program Income not reported (from seizures, forfeitures, other)

48.  Time sheets lack employee’s or supervisor’s (or both) signatures.  Actual activity not documented.  Volunteers’ time not documented same as grant-funded employees.  Overtime paid, without prior CJD approval, or not following approved Overtime Policy.

49.  Procurement Questionnaire for contract exceeding $100,000 not completed and submitted to CJD.  No written contract(s) for Contractual expenses.  Grantee did not monitor (or have evidence of monitoring) the contract. No contract monitoring tool was used to document the grantee’s oversight of the contract.  Documentation of procurement not maintained.

50.  Requisition or voucher documents not completed.  Support documents (receipts, invoices, etc.) not available.  Purchase of unallowable items (gifts, alcoholic beverages).

51.  Procurement Questionnaire for purchases exceeding $100,000 not completed and submitted to CJD.  Incomplete/non-existent inventory list.  Grant–purchased items not identified on the inventory list.  Equipment items not properly tagged.  No procurement policy; competitive procurement documents not maintained.

52.  Not pre-approved. Using grant funds for construction must be pre- approved by CJD.

53.  Non-essential operating expenses (snacks/ coffee/creamer/paper towels/etc.) were purchased with grant funds.  Prohibited items (i.e. advertisements, gifts, fundraising expenses, admissions to sporting events /amusement parks/recreation) were purchased with grant funds.

54.  Commingling of funds: Grant funds have been commingled with other funds. (Requirement: Each grant award must be accounted for separately.)  Irreconcilable accounts: CJD Financial Status Report does not reconcile to general ledger expenditures. (Requirement: Grant expenditures need to reconcile to GL expenditures.)  Inability to trace expenditures: The source and application of funds can not be traced to the general ledgers. (Requirement: Expenditures need to be traceable to the GL.)

55.  Monitors provide technical assistance to the grantees while on site (or over the phone, if it is a desk review).  This includes explaining governing directives and discussing possible recommended actions for compliance.  Monitors may also provide samples of documents to assist the grantee with compliance, such as sample personnel activity reports.

56.  Informal stop-in visits with grantees in the same geographic area where we are doing site reviews  Carried out if the monitor has time to stop-in; if the schedule is too tight, the monitor will forgo the visit  Monitor asks for the project director, talks to him/her about the grant, and asks if there are any questions about the grant  If time allows, grantee may offer a brief tour of the facility  Visit usually lasts about 30 minutes or less  No documentation is requested; although grantees may provide a brochure or a business card  Allows for CJD to more efficiently use state travel funds and for CJD to make contact with more grantees out in the field.

57.  Completed by COG planner during site visit (or if a JAG Recovery grant, then possibly phone contact form instead)  Also, referred to in our Notification Letters to grantees before reviews, for their use  Purpose: Identifies grantee’s compliance issues  Completed checklists are forwarded by planners through eGrants to CJD  Issues analyzed by CJD Grants Monitoring  CJD may follow-up with a monitoring review  (In-depth training sessions on the checklists & phone contact form, tomorrow)

58.  Technical Assistance Checklist available at: https://cjdonline.governor.state.tx.us Then go to Updates, then Grants Monitoring Tools, then Checklist (and Coversheet and Phone Contact Form for the COG planners.)  Examples of governing directives can be found on the link to Grants Resources on eGrants, including: – Guide to Grants – Texas Administrative Code (TAC) – Uniform Grant Management Standards (UGMS) – Office of Justice Programs Financial Guide – Financial Management Guide

60. Step 3. Properly Close Out the Grant

61. Final FSR Final Progress Report Expend all GPI Request Disposition of Equipment

62. Step 4. Follow the Rules and Regulations

63. Office of Justice Programs (OJP) Financial Guide http://www.ojp.usdoj.gov/financialguide/ Education Department General Administrative Regulations (EDGAR) http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html Office of Management Budget (OMB) Circulars http://www.whitehouse.gov/omb/circulars_default/ – A-21: Cost Principles for Educational Institutions – A-87: Cost Principles for State, Local and Indian Tribal Governments – A-102: Grants and Cooperative Agreements With State and Local Governments – A-122: Cost Principles for Non-Profit Organizations – A-133: Audits of States, Local Governments, and Non-Profit Organizations Fund Specific Guidelines

64. Uniform Grants Management Standards (UGMS) http://governor.state.tx.us/grants/what/ http://governor.state.tx.us/grants/what/ Texas Administrative Code (TAC) https://cjdonline.governor.state.tx.us/updates.aspx https://cjdonline.governor.state.tx.us/updates.aspx CJD’s Guide to Grants https://cjdonline.governor.state.tx.us/updates.aspx https://cjdonline.governor.state.tx.us/updates.aspx

65. NOTE: CJD awards grants with both State and Federal funds. Use this Matrix to figure out if your grant is awarded with State or Federal funds. Sources highlighted in Yellow are prioritized by the COGs. Fund SourceFederalState CD-Coverdell Nat'l Forensic Sciences Improve ActX DJ-Edward Byrne Memorial Justice Assistance Grant ProgramX ED-Safe and Drug-Free Schools and Communities State GrantsX JA-Juvenile Justice and Delinquency Prevention ActX JB-Juvenile Accountability Incentive Block GrantsX JT-Title V Delinquency Prevention ProgramX RT-Residential Substance Abuse Treatment for State PrisonersX VA-Victims of Crime Act, Victim Assistance ProgramX WF-STOP Violence Against Women Formula GrantsX BVP-Bulletproof Vest PartnershipX SCAAP-State Criminal Alien Assistance ProgramX DNA-Post-conviction DNA Testing Assistance ProgramX CE-County Essentials Program X CG-Operator and Chauffeurs Funding-Gangs X CH-Operator and Chauffeurs Funding-Prosecution X CR-Crime Stoppers Assistance Fund X DC-Drug Court Program X SF-State Criminal Justice Planning (421) Fund X

66. STEP 5 Use Sample Forms Time Sheets/Personnel Activity Logs – Blank Time Sheets/Personnel Activity Logs – Requirements Post-Award Procurement Questionnaire Resolution Technical Assistance Checklist