Yes. A grantee should maintain written policies and procedures for its subrecipient award process to ensure it meets the requirements as laid out in 2 C.F.R. §§200.331 and 200.332. These policies and procedures should address both pre- and post-award responsibilities. For additional information, please consult the—
- Delivering Impact through Effective Grants Compliance and Oversight recorded webinar,
- DOJ Grants Financial Guide section on Subrecipient Management and Monitoring, and
- OVC Mini Toolkit for Subrecipient Monitoring.
Grantees (and any "subgrantee" at any tier) must have written policies and procedures in place that address how it will maintain the confidentiality of victims' names, addresses, telephone numbers, or any other identifying information, including how this information will be protected when there is information sharing between partners.
In addition, grantees must submit a signed, written certification that data privacy and sharing protocols comport with the confidentiality and privacy rights and obligations of federal law or the grantee jurisdiction's laws, court rules, or rules of professional conduct applicable to the work performed by the grantee.
The below standard award conditions require additional documentation post-award. Please consult your award conditions, as not all awards will have the following conditions:
- The recipient will coordinate its efforts with other similar OVC-funded programs within the relevant jurisdiction in order to enhance the project and avoid duplication of efforts.
- Submit a signed memo on letterhead about how your OVC-funded program is coordinating or will coordinate with other OVC-funded programs in your community to satisfy this condition. Please consult the grantee map to identify any other OVC human trafficking grantees in your jurisdiction.
- Submit a signed memo on letterhead about how your OVC-funded program is coordinating or will coordinate with other OVC-funded programs in your community to satisfy this condition. Please consult the grantee map to identify any other OVC human trafficking grantees in your jurisdiction.
- Within 90 days of an OVC written request, the recipient must submit for OVC review and approval, the policies, procedures, and rules governing the provision of program services supported with award funding or provided as a match. These documents should include, but are not limited to, those used for program eligibility, intake, working with participants, and program protocols. The recipient further agrees to work with OVC-sponsored technical assistance providers to develop or enhance rules, policies, and procedures that OVC determines are needed to ensure they reflect best practices for serving survivors of human trafficking.
- Submit a copy of your organization’s policies and procedures to your OVC grant manager and appointed technical assistance provider to satisfy this condition. Please discuss this with your OVC grant manager, as award condition language varies across fiscal years.
- Submit a copy of your organization’s policies and procedures to your OVC grant manager and appointed technical assistance provider to satisfy this condition. Please discuss this with your OVC grant manager, as award condition language varies across fiscal years.
- The recipient (and any "subrecipient" at any tier) must have written policies and procedures in place that address how it will maintain the confidentiality of victims' names, addresses, telephone numbers, or any other identifying information, including how this information will be protected when there is information sharing between partners. In addition, the recipient must submit a signed, written certification that data privacy and sharing protocols comport with the confidentiality and privacy rights and obligations of federal law or the grantee jurisdiction's laws, court rules, or rules of professional conduct applicable to the work performed by the recipient. The recipient agrees to provide to OJP all documentation as required for grant monitoring purposes.
- Submit a copy of your organization’s policies and procedures regarding client privacy and confidentiality practices, as well as a signed memo on letterhead certifying that the organization’s data privacy and sharing protocols comport with the confidentiality and privacy rights and obligations of federal law or the grantee jurisdiction’s laws, court rules, or rules of professional conduct to satisfy this award condition.
Information about grantee performance measures and semiannual report narrative reporting requirements can be located on the OVC Human Trafficking Performance Measures website. Additionally, the OVC Performance Measure Dictionary and Terminology Resource provides standardized definitions and examples to assist with OVC’s performance data collection efforts.
If you have questions about the performance measures and reporting requirements, please contact the OVC PMT Helpdesk via email at [email protected] or call 844-884-2503. If you have questions about JustGrants, please consult the JustGrants Resource website or contact the JustGrants Helpdesk via email to [email protected] or call 833-872-5175.
Performance reports are submitted semiannually in JustGrants and due within 30 days after the end of the reporting periods, which are June 30 and December 31, for the life of the award. While grantees are strongly encouraged to gather performance data quarterly, it is only uploaded to JustGrants on a semiannual basis. Performance reports submitted in JustGrants must include both program narrative question responses and performance measures/data. The performance reports submission schedule is:
Reporting Period | Data Required | Upload to JustGrants | Due no Later Than |
October 1 – December 31 | Quarter 1 Performance Measures and Narrative Question Responses | Yes | January 30 |
January 1 – March 31 | Quarter 2 Performance Measures | No | N/A |
April 1 – June 30 | Quarter 3 Performance Measures and Narrative Question Responses | Yes | July 30 |
July 1 – September 30 | Quarter 4 Performance Measures | No | N/A |
Last Reporting Period of Award | Performance Measures, Narrative Question Responses, and Closeout Question Responses | Yes | 120 days after end of reporting period |
The final report should document the project activities that occurred in the final performance reporting period of the award, AND a cumulative narrative that documents all project activities during the entire period of award funding.
The report should include detailed information about the project(s) funded, including, but not limited to—
- information about how the funds were used for each purpose area,
- data to support statements of progress, and
- data about individual results and outcomes of funded projects reflecting project successes and impacts.
The final report must include both the performance report narrative and Performance Measurement Tool (PMT) data report.
The final report is due in JustGrants no later than 120 days following the close of the award project period or the expiration of any extension periods.
If a training was not developed using award funds, but is being provided as part of an OVC-funded award, please provide the following language to any slides or materials: “The opinions, findings, and conclusions or recommendations expressed in this presentation are those of the contributors and do not necessarily represent the official position or policies of the U.S. Department of Justice.”
If you are aware of any fraud, waste, abuse, misconduct, or whistleblower reprisal relating to a Department of Justice employee, program, contract, or grant, you may report it to the OIG Hotline.
Prior approval is not required for grant award recipients; however, cooperative agreement recipients or contractors may be required to submit a formal conference cost approval.
View more information on OJP’s conference cost policy guidance and supporting materials, resources, and job aids.
Please review the Delivering Impact through Effective Grants Compliance and Oversight recorded webinar presented by the Office of Justice Programs’ (OJP) Office of Audit, Assessment, and Management. The webinar equips OVC anti-trafficking grantees with information about effective grants compliance and oversight to meet grant requirements, including subrecipient monitoring, agency internal controls, and common audit findings. Additional resources include:
- The OJP Financial Policies and Procedures Guide Sheets collection, developed by the OVC Tribal Financial Management Center, offers resources on internal controls, and other compliance and oversight topics.
- The Subawards and Procurement Contracts under OJP Awards resources help clarify the differences between subawards and procurement contracts under an OJP award and outlines the compliance and reporting requirements for each.
- The OJP Subaward and Procurement Toolkit provides guidance designed to help recipients of OJP grants and cooperative agreements understand subawards and procurement contracts and their administrative requirements.