OVC Tribal Victim Services Set-Aside Program: FY 2022 Grantee Orientation Compliance and Allowables Webinar
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The goal of this recorded webinar is to provide OVC FY 2022 OVC Tribal Victim Services Set-Aside Formula Grant Program (TVSSA) grantees with knowledge and resources on the variety of award conditions that must be met in order to successfully manage their award. View the webinar presentation.
JANA PFEIFFER: Let me start by introducing myself. My name is Jana Pfeiffer. I'm an enrolled member of the Navajo Nation and a technical assistance specialist with the T-VSTTA team. You've been invited here today because you have been awarded a fiscal year of 2022 Tribal Victim Services Set-Aside grant. We'd like to welcome you to the grantee community, so let's get started. First, we just have a few housekeeping rules and items.
This session is being recorded and will be available to the public on the OVC TVSSA website in about 10 days. We dropped the link, that site in the chat box. Throughout our session today, please enter your questions through the Q and A feature at the bottom of your screen instead of the chat box. This will help us identify and address your questions quickly. Please use the chat feature today for general communication with the host and fellow participants and to find the resources our presenters will share. To help with audio quality, all lines are in listening mode. If you're listening through a computer, please select the speakers and headphones you wish to use. If you are experiencing any technical issues with this session, please let us know right away in the chat box, or you could email the technical support using the address [email protected].
Oh, and if you haven't already done so, please use the chat now to tell us where you are from, and say hello to everybody inside the group, the webinar. And finally, for closed captioning, please click on the CC button at the lower left of your computer screen. Okay, so before we begin, let's start off with a polling question to get an idea of who is in the room. Please take a moment to share your role as it relates to the FY 2022 TVSSA award. If your option isn't on the screen, feel free to enter it in the chat box. Okay, so it looks like we're getting in our numbers. It looks like we have about 40% of accountants that are attending this webinar.
And then second, we have grant officers or the grant writer on behalf of the Tribe that they are from. So looks like we have a lot of great individuals participating in today's webinar. Well, no matter what your role is, the information presented in this session will definitely benefit you and help you successfully manage your new OVC award. Now to Lori Gardner from the Office for Victims of Crime.
LORI GARDNER: Thanks so much, Jana. I'm Lori Gardner, and I'm a grant manager with the Tribal Division. And on behalf of the Tribal Division, I would like to welcome you all today to the third webinar in our New Grantee Orientation series. Being the grant recipient of funding can be a great opportunity, obviously, but it can also be really confusing due to all of the requirements, the award conditions, and the reporting that must be met in order to satisfy the conditions of accepting the award.
Our goal today is to provide you with the knowledge and resources on a variety of award conditions that must be met in order for you to successfully manage your Tribal Set-Aside award. Next slide, please. So before we get started, there are a few things you do need to know. The award conditions and language mentioned during the webinar are specific to the FY 2022 grants only. If you have other TVSSA awards from previous years, those conditions are likely very similar, but there are some differences, so today we'll be covering 2022 only. If you have grant-specific questions regarding the award conditions on this or other awards, please always reach out to your grant manager. Next slide, please. So we'll start off really simple. What is an award condition? Award conditions are the terms and conditions that are outlined in your grant award package. Next slide, please.
So where can you find the award conditions? They can be found in the Award Package tab that's located in your award in JustGrants, and that was demonstrated on the previous slide if you ever need to know where exactly they are. So who should read the award conditions? I can't stress this one enough. Everyone that is working on the award should be familiar with the award conditions. Certainly, your authorized representative, the grant award administrator, and the financial managers. But again, really anyone who is working on the award should read and be familiar with the award condition, and we recommend this because there are a whole host of award conditions that can really relate to anyone that's carrying out the daily activities under the award. Next slide, please.
And one last point before we talk about the award conditions. When you look at the award conditions in JustGrants, you'll notice some of them are removable, and some of them are not. So removable award conditions can be removed during the life of the grant, and these are going to be your withholding conditions that require some sort of action. So like, withholding conditions could be like a conditional clearance on your budget, or you need to provide a revised budget, a withholding for an expired indirect cost agreement, so you need to provide a new agreement in order to get that withholding removed, or you need to provide the required certification, but the program maintains confidentiality programs, policies, and procedures. Most award conditions, however, cannot be removed. Many are active and will remain active throughout the lifecycle of the award. So please note, at the grant closeout, you must certify that all conditions have been met with the removable award conditions. Next slide, please.
Because there are so many award conditions, and some of them can even vary from one award to the other, we will be highlighting today the award conditions that we, as grant managers, are most frequently asked about. And we've grouped these into the eight topics you see here on the slide. Next slide, please. Since we'll only be covering the highlights today, we wanted to share resources for those who would like to take a deeper dive into the award conditions. You can visit the OJP Funding Resource Center and select the appropriate legal overview section where you can read more about what these award conditions mean. And I want to emphasize this link on the slide because it's a very helpful resource for you in helping you understand and successfully manage your award conditions. Next slide, please.
And before we dive too far into the conditions, we would like to find out how familiar you are with them, so please take a moment and tell us about your experience. And if your option is not listed on this multiple choices, please feel free to write your answer in the chat. So the question is, have you reviewed your award conditions? And the answers are yes, I have, no, not yet, no, I was not sure where to locate them, and I'm not sure. Wow, and we have 79% of folks who have read their award conditions, so that is great to hear. And for those of you that haven't, you've come to the right place where you can learn more about them today. Next slide, please.
So what you see on this slide are three of the topic areas that we'll discuss. We have general award conditions, programmatic award conditions, and withholdings. And then our first topic here is the general award conditions. Next slide, please. I'm going to speak to six of the general conditions. Each of these conditions essentially has the purpose of helping mitigate the risk of the misuse of grant funds, and the conditions do this in a couple of different ways. One, they provide notice to you of the things that you cannot do. The other are things that you agree that OJP can do to either address non-compliance or some risk that has been identified in your application that needs to be addressed. Some of these conditions have affirmative requirements that you need to take in terms of doing something, so I'm going to highlight those as well. Next slide, please.
The DOJ Financial Guide. This guide serves as the primary reference manual to assist OJP, OVW, and the COPS Office award recipients in fulfilling their financial responsibility. It compiles a variety of laws, rules, and regulations that will affect the financial and administrative management of your award. There may be times where, actually, the requirements may differ among these three grantmaking components, but those differences are generally spelled out throughout the guide. This guide should be the starting point for all recipients of DOJ awards to ensure that the effective day-to-day management of the awards. This guide was updated fairly recently, so if you have an old copy saved, you should definitely check out the new version, and it continues to be updated generally yearly.
Remember, this resource should be your first stop whenever you have any type of grant, financial, or administrative question. It is a whopping 150-plus pages, so I'm going to give you all a little tip about what I do. I download the PDF version of the document on my computer, and that way, anytime I need to know something, I type it into the search function, and it shows me exactly where in the document the topic is addressed. So even though it is a large document, please don't be too overwhelmed. While it is lengthy, it's manageable. And, of course, you always have your OVC grant managers to help, so please always reach out to them if you ever have a question about anything that's in the guide. Next slide, please.
This next award condition focuses on not duplicating efforts or double-dipping. And what this means is maybe you applied for two grants at the same time to do the same thing, and then you get both of them. So, first of all, congratulations, that's wonderful. But also, you need to reach out and let your grant managers know as soon as possible because you'll need to work with those funding agencies to determine how you will ensure there's no duplication of effort. So if you feel like there might be any duplication of costs between any awards, please do reach out to your grant manager, and they can provide you with next steps. Next slide, please.
This award condition says that if you are listed in JustGrants, either as the grant award administrator or the financial manager, you are required to take the DOJ's Grant Financial Management Training. The good news is, is that you can do this online, and the link to the information about the training is, I think, going to be provided in the chat. The grant award administrator and the financial manager must complete this training within 120 days after the date you've accepted the grant. If you assign a new grant award administrator or financial manager at any point after that, they also have 120 days to complete that training. And your certification is good for three years after you've taken it. After taking the training, please do send your certificate to your grant manager so that they can add it to your award file and release any related withholdings. Next slide, please.
And so we're going to pause for a moment and ask another quick question. And we want to know who has taken the DOJ Financial Management Training in the last three years? And the answers here are yes, no, I've taken the training, however, I'm not sure if my certification is current, I'm unsure if I've taken it, or I'm not required to take this course. Right, again, we have the majority of folks who have taken the Financial Management Training, so that's great, but we still have quite a few that haven't, so this segues into, I wanted to take a moment for TFMC to be able to highlight the Grants Financial Management Training that they now offer.
TARA BALLESTEROS: Good afternoon.
LORI GARDNER: I'll turn it to you, Tara.
TARA BALLESTEROS: Oh, thank you, Lori. Good afternoon, my name is Tara Ballesteros, and I'm with TFMC. TFMC is partnered with the Office of the Chief Financial Officer to provide an alternative hybrid training model, which includes a combination of live discussion webinars, interactive activities, and a study guide to reinforce existing material. Dedicated TFMC team members accompany learners on their journey and are responsive to the needs and the feedback of participants. The TFMC training is designed specifically with you, the grantee, in mind, with updated scenarios and activities relevant to those working in victim services to enhance the retention of material.
TFMC will be offering the training later this summer. We are currently confirming the date, but it will be five weekly one-hour sessions with self-guided interactive activities in the TFMC learning panel. This hybrid training helps to address some of the barriers to successful completion. While internet access is necessary to complete knowledge checks and activities in the learning portal, we provide call-in options to the live sessions and a PDF of the study guide so you can review material offline. If uninterrupted bandwidth is a challenge, this is the training for you.
If you are interested in participating in the next cohort, please email us at [email protected] to be notified of the confirmed date and to register for the upcoming session. Again, the next session will be later this summer, probably the last week in July into August, five consecutive weekly sessions. The sessions will run from about an hour to an hour and a half, and then you'll have additional material to work on in the learning portal. And successful completion of this training does meet the requirements. So back to you, Lori.
LORI GARDNER: Thank you so much, Tara. This is an amazing resource, and we appreciate you jumping on to be able to share about this today. So, this next condition says that if you are working on a project funded through a federal grant in any capacity, and that could be as an employee, a sub-recipient, or even as a volunteer, you are strictly prohibited from engaging in any activities that would be considered human trafficking. If you go to the link listed on the slide, there's a lot of information about how human trafficking is defined, and that says that if you receive a federal grant and it's discovered that you have participated in human trafficking, that your grant award will be terminated. Next slide, please.
This next award condition states that failure to comply with any one or more of the award requirements that we've talked about today may result in OJP taking action with respect to the recipient and the award. Among other things, OJP may withhold award funds, disallow costs, suspend, or even, in some cases, terminate the award. The DOJ, including OJP, may also take other legal action as appropriate. The key here to avoid all of that is to know and follow all of the award conditions outlined in the award package and to always, always, always reach out to your grant manager if you're ever unsure about any of the award conditions. Next slide, please.
This condition relates to the variety of audits that your programs may be subjected to. The most relevant one for OVC purposes is the Office of Inspector General or OIG. The OIG is tasked with making sure that there is no evidence of fraud, waste, or abuse in the government programs and making recommendations to mitigate those risks. The OIG can audit any program they choose to, and they do audit a number of OVC programs. If there are recommendations or issues that are discovered in audits of your program, and if you haven't addressed those, then OJP can take a number of actions to make sure you address those audit findings. And the purpose behind this is to make sure that any risk identified in the audit is addressed before you move forward with the project. There are a number of remedies that we can take, however, the typical remedy is withholding funds. Next slide, please.
Uniform Guidance, sometimes we refer to this as Supercircular or Omnicircular. Sure, not very easy to say. And they provide a streamlined government-wide framework for grant administration and management that consolidates all of the requirements. The current regulation that guides the requirements associated with your grant award are these uniform administrative requirements, and these apply to everyone that has received a grant award from fiscal 2014 forward. The Uniform Guidance provides provisions for things like eliminating duplicative and confusing guidance, increasing accountability of non-federal entities, and promoting the efficient use of technology. The Uniform Guidance is really the foundation of everything that we are talking about today. And for more information, you can visit the link listed on the slide. Next slide, please.
So we covered grant reporting requirements in the webinar last week, so we won't go into that in too much detail here. But just as a reminder, there are three different types of reporting responsibilities that grantees have. The first is the progress report, which is due semi-annually in JustGrants on January 30th and July 30th of each year. You also do need to input data into the system known as the PMT on a quarterly basis, but those semi-annual reports are the reports that will be submitted into JustGrants. Final reports are due also at the end of the award, and this report summarizes absolutely everything you have done with all of your funds throughout the entire project, and those are due within 120 days of the award closing.
And then, finally, there are the financial status reports, and you'll hear us call them FSRs. These are done quarterly, and you'll go into JustGrants, and your financial manager will be able to log in and complete your financial reporting there. And those are due within 30 days of the close of each quarter. Something to be aware of is that with any of these reports, if you don't submit them by the deadline, our system will automatically freeze your funding. This is unfortunately not anything that your grant manager has control over. It is automatically done by the system. However, I think it might be helpful to know, as soon as you do submit your reports, funds are generally available again pretty quickly.
If you have any specific questions about how you report, or you need a little bit of help figuring out what goes where, I know it can be confusing sometimes, especially when you're just starting out, so, again, please always reach out to your grant manager, and they can help walk you through it and help provide additional resources that are needed. Next slide, please.
The next condition is the requirement that you register for the System Award Management, or SAM, as we call it. SAM is the federal clearinghouse for information about entities that receive federal money. For example, OJP checks SAM to see if an agency has been suspended or debarred before making an award because if an organization has been suspended or debarred, it's prohibited from receiving federal funds. So this one's a fairly straightforward condition. You need to register with SAM. You need to make sure any sub-recipients are registered. And then you'll need to update SAM whenever you do have changes. Next slide, please.
This next condition is about civil rights and non-discrimination. The recipient and any sub-recipients must comply with the applicable requirements of 28 CFR Part 38. Among other things, Part 38 includes rules that prohibit specific forms of discrimination on the basis of religion, a religious belief, a refusal to hold a religious belief, or refusal to attend or participate in a religious practice. Next slide, please.
This next award condition applies to programs who interact with any participating minors. All individuals, and this can be personnel, consultants, contractors, and even volunteers who are expected or even likely to interact with participating minors, they must have a criminal background check and a check of the public sex offender and child abuse websites and registries. And these checks actually must be completed at least every five years or upon learning of information that may reasonably suggest unsuitability. And the requirements and definitions of covered individuals can be found at the link listed on the slide. Next slide, please.
The next condition also addresses risk, and this is what happens when an organization is designated as a high-risk grantee. OJP has a process where if certain deficiencies in your financial management, like past performance or audit issues, come up, DOJ can designate your organization or Tribe as high risk. And what that means as a practical matter is DOJ may impose additional requirements. Typically, these requirements are geared just to make sure you come into compliance. So, for example, if you have any deficiencies in your financial management, we may require that you take some type of financial management training. There also can be withholding conditions if there's a misuse of funds or a risk of misuse of funds. If you are on the high-risk list before you received the 2022 award, you will likely have high-risk conditions already on your award. And if you don't have high-risk conditions, you don't necessarily have to worry about this condition at this point. However, just know that you can become high risk at a later time if, for example, there's an audit finding that identifies some issue. Next slide, please.
This next condition is again about mitigating the risk of misuse of federal funds. There's a requirement that fraud, waste, and abuse should be reported to the department's OIG or Office of Inspector General. So if you detect fraud, waste, or abuse in your program, you should report that to the Department of Justice OIG, and the link for more information is on the slide. This condition also prohibits your organization from having any internal confidentiality agreement that prohibits your employees or contractors from reporting fraud, waste, and abuse to federal investigators or law enforcement. So when you accept this award, your Tribe or organization has agreed that it does not have or require these internal confidentiality agreements that will restrict the reporting of fraud, waste, and abuse. And so with that, I am going to turn things over to my colleague, Ramesa Pitts, who will cover the programmatic award conditions from here.
RAMESA PITTS: Thank you for that, Lori. As Lori mentioned, I am her colleague, Ramesa Pitts, in Tribal Division here within OVC, and I will move straight through the presentation and start with the programmatic award conditions. Next slide, please.
So here, we are looking at the programmatic award conditions, which are those award-specific conditions that are active throughout the life of the award, depending on the specific grant that you have. Next slide, please.
So one of the conditions we're discussing today is the programmatic access rights. So initially, when you accepted the award, you agreed to all of those conditions, and one of them says that you authorized OJP the access to and the right to examine all records, books, papers, and other documents that are related to this grant. And this also is passed through to any of your sub-recipients. So if you make sub-awards, then those recipients are also bound by the same condition. So if OVC or any of the other entities at OJP, like the Office for Civil Rights or the Office of the Chief Financial Officer, also known as OCFO, or the OIG is doing any sort of review or audit or monitoring visit, we may ask to see certain items that you initially agreed to provide us when you accepted your award.
So as you can see, on this slide, it says access rights, so when you see that, it typically refers to required, and you see specific language as it reads, and the special condition says that the recipient authorizes the Office for Victims of Crime, OVC, and/or the Office of the Chief Financial Officer, OCFO, and its representative access to and the right to examine all records, books, papers, or documents related to this grant. Next slide, please.
So because you're being funded with federal dollars, you are obligated to follow all relevant federal law with respect to confidentiality and privacy. You must protect the privacy of those you serve, as well as identify your procedures for protecting personally identifiable information, also referred to as PII. Within 90 days of the date of the award, the grantee will submit to the Office for Victims of Crime for review and approval its policies and procedures that it has established to maintain the confidentiality of victims' names, addresses, telephone numbers, or any other identifying information and its policies and procedures relating to information sharing between partners. In addition, the grantee 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. Next slide, please.
So, this next slide is about failing to initiate activity, and it essentially says OVC reserves the right to take action when a grantee fails to initiate activity or misses time task lines. Funds are provided to an organization, and they are pretty much agreed to, where the grantee has pretty much agreed to do certain activities. If they get the money and then they do nothing, then OVC has the right, in many cases, to terminate or suspend your award if it gets to that particular point. So as a grantee, as a recipient, you have an obligation to abide by those terms and conditions in the grant, and if you fail to initiate activity or if you miss multiple time task lines, OVC does have the right, again, to terminate or suspend your particular award. I will say that termination or suspension of an award is a rarity, and therefore, we want the project to be successful, so just work directly with OVC and making sure that you are in compliance with these particular conditions as it relates to your award. Next slide, please.
So next, we will touch on the confidentiality policies and procedures. Victim assistance providers should be aware of relevant policies and laws on privacy, and that could include limitations on confidentiality within justice agencies, professional organizational, or ethical standards, state laws on privileged communication, and mandated reporting, federal laws and regulations. And to the providers, you must, and you are required to adhere to the highest standard of privacy. And so when looking at this, to ensure that your program has these written policies and procedures included in the documentation, you want to address how you will maintain the confidentiality of victims' names, addresses, telephone numbers, and identifying information, and also have procedures for information sharing amongst partners. So to satisfy this condition, you must submit a signed, written certification that data privacy and sharing protocols comport with confidentiality and privacy rights. Again, this is just a reiteration of the previous slide in which we touched on the confidentiality piece.
So if you need help in developing policies and procedures, I encourage and welcome you to contact your assigned OVC grant manager. We do have T-VSTTA, our programmatic TA providers, who can support and help in developing your policies and procedures. So if you are uncertain, if you have never been in contact with that T-VSTTA assigned individual, then I encourage you to contact your OVC grant manager. Next slide, please.
So as it relates to Tribal awards, we now have a special condition for construction. The first thing I would like to emphasize is that all grant-funded construction and renovation projects are required to comply with the National Environmental Policy Act, also known as NEPA. Prior to funding, authorizing, or implementing an action including awarding grants, federal agencies, including OVC, are required to consider the effects that the proposed action may have on the environment and any related social and economic effects. OVC has hired a contractor that will guide you through this process and work with you to ensure your project complies with NEPA and any related environmental laws. If you haven't already done so, please speak with your OVC grant manager about this special condition who can provide you with further guidance. Next slide, please.
So, it brings us to consultant rates. Many of you have been around for a while, and you're pretty familiar with the TVSSA award as well as the special condition for consultant rate. The consultant rate is also discussed in your DOJ Grants Financial Guide. OJP has a limit that we do not permit grantees to pay consultant rates higher than $650 per day or $81.25 per hour. So what that really means is that that it doesn't mean that every consultant on your particular award should be paid $650 a day or $81.25 per hour, but it just means that that is OJP's cap. The cap is $650 per day or $81.25 per hour, and you should definitely, definitely pay individuals for the adequate services rendered. And when we do talk about a day or a rate, that does include preparation, evaluation, travel time, as well as the actual performance of whatever consulting sort of activities they are engaged in.
If you do need to exceed that rate, you would want to work closely with your grant manager to submit a GAM, which is a Grant Award Modification, to basically request that that limit be waived for whatever reason. And again, so I encourage you to speak directly with your grant manager and discuss what your needs are, why the need exists, et cetera, and try to figure out what would be the best course of action for you. But we'll move on to the next page. But basically, I just wanted to reiterate that $650 per day is the cap for OVC. And again, that doesn't mean everyone should be paid at that $650 per day or $81.25 per hour, but it does mean that you would need to communicate with your grant manager should anything change with that consultant rate. Next slide, please.
Sole source, so this slide pretty much talks about the sole source procurement. Sole source procurement should be used only when the use of competitive solicitation procedures like sealed bids or competitive proposals are not applicable to the requirement or is pretty much impractical. All sole source procurements in excess of the simplified acquisition threshold set in accordance with 41 USC 1908 must receive prior approval from the grantmaking component before entering into the contract and should only be used as a last resort. And that the threshold for the sole source is $250,000, so just wanted to reiterate that as well. Next slide, please. So now this brings us to the point where we can segue into the withholding of the award conditions, next slide.
So, the withholding conditions are conditions that restrict grantees from drawing down funds if they are not in compliance with the award conditions. The withholding conditions should be addressed immediately, and the withholding conditions may be added when information is missing from the application. But please remember, not all award withholding conditions are specific to all grantees. There are only specific award conditions that may be specific to your particular award. And next, I will go over a few additional conditions shortly. Next slide, please.
So, in case you were wondering where can you find the withholding, this slide gives you an easy view of how to locate this information. You can go to the Funding Balance and Availability tab in JustGrants and scroll down to the bottom. If you have a hold, you will see it on the screen once you log into JustGrants. And as you can tell from this particular screenshot, this grantee's funds are suspended and frozen. This means they cannot access program funds until all these special conditions have been addressed. So make sure that you look at, if you have a question of maybe a drawdown question, you may want to take a look at this particular tab in JustGrants, which may provide you some insight on any special condition holds. Next slide, please.
So, the most common withholding award condition that applies to almost everyone is the financial hold for conditional budget clearances. So you'll see the award condition language on the award, and it specifically states that the recipient's budget is pending review and clearance by OJP. Prior to budget clearance, unless prohibited by another condition of this award, the recipient may obligate, expend, and draw funds for budgeted recipient personnel, fringe benefit, and related operational costs and OVC-mandated travel costs only up to 10% of the award amount to participate in OJP-required trainings, advertise for new positions, maintain current staffing, plan activities with project staff, and provide victim services. This means you can only draw down up to 10% of the award amount until your budget is approved. So it is very, very important that you work with your OVC grant manager who's going to serve as your liaison and point of contact between you as the grantee and OVC to address any issues with the budget detail worksheet or budget narrative.
I will stress that it's also important for you to be responsive to those particular requests that may come from your grantee so that we can get the final budget approval from OVC on your behalf so that that final budget GAM can be issued to release any special conditions on your award. Next slide, please.
So in this process, those grantees that are charging indirect costs to their grant will also have an additional withholding award condition that will hold funds for their indirect costs. So during that budget review period, it's a good idea for you to send copies of your new indirect cost rate agreement because there may be some lag time between the time of the application and the time that these conversations are happening with your grant managers. But it is a great idea, again, to go ahead and email your most recent indirect cost rate agreement to your assigned grant manager so that the grant manager can then release the additional hold for indirect cost on your grant.
Note that this is, again, a separate withholding award condition, so there are two. One for the budget and one for the indirect cost. And again, it is important that we receive the most recent IDC rate agreement so that the funds can be released. It's also important to note that any changes in your rate, that means that the rate has gone up or the rate has either gone down, may require you to submit a budget GAM, a budget modification GAM. But that's a conversation that you can specifically have with your grant manager to determine if a budget modification should be submitted in JustGrants. Next slide, please.
So, another potential area where you might see a withholding award condition is for the single audit, and this is the award condition or withholding award condition that are for those grantees that expend more than $750,000 in grant funds in a year. Those grantees would see this special condition on their or in their particular award. So this would be most likely applied to our larger grantees that receive more or multiple larger grants. But those grantees that expend more than $750,000, again, in grant funds in one year are required to submit their audit reports to the Federal Audit Clearinghouse. And the link to the Audit Clearinghouse is reflected on this screen on that screenshot. So next slide, please.
So, I've gone over a few different areas or situations where you might see withholding award conditions added to your award. So here's an opportunity for me to talk about a few additional conditions as I mentioned earlier. So I did already mention that we at OJP use withholding award conditions in a number of situations where grantees may have left out information during the application process. So, for example, if a grantee does not disclose pending applications or if we are missing information from the application, such as a missing lobbying form, that might be a situation where a withholding award condition is added directly to the award that requires the grantee to submit one or both of the forms or any other additional information.
Some other situations where there might be withholding award conditions added to the award include situations where grantees might have issues with either an invalid UEI or expired SAM profile for their grantee organization. And then the last situation I'll cover today is for the programmatic strategy and budget, and this happens sometimes during the award process where OVC might add a withholding award condition to require grantees to make specific changes to their program strategy or program narrative as well as their budget. So you'll see this is where perhaps some of the requirements to submit this may be a little different, but you would have to, again, work directly with your grant manager to figure out what requirements are there and then work through those in order for those special conditions to be released. And again, once we are able to verify that everything has been adequately addressed, we would then clear that award condition via GAM in JustGrants. Next slide, please.
So just to recap on this slide here for how to satisfy a withholding award condition, the first thing we need to do is take action. So either the grantee needs to go ahead and email those documents to the grant manager. That may be like some of the things that we talked about previously. It may include the most recent updated indirect cost rate agreement or any other necessary documentation that may be required by your grant manager, by OVC to revise the budget or any other information that may be needed to lift this or the multitude of special condition holds that may be on the grant.
And we talked about submitting, where a budget GAM, again, will be submitted in order to lift that special condition. Once the GAM receives final approval, both POCs in JustGrants will receive an automatic email to confirm that the award condition has been removed. That process normally takes as short as three days. Sometimes it may take a couple of weeks, just depending on, you know, just the volume of requests that are being filtered through the system.
Primarily, it depends on which award condition also that we're looking at to release. That may take a little time to release that special condition. It can also depend on the time of year during our grant cycle as we get busier both within OVC and OCFO. So just keep in mind that it's typically a short process, but it's one that can take a little time in order to clear that special condition. Next slide, please.
So here we are. We are now looking at some helpful hints. So just a little few hints here, and you can read the ones that are on the slide. It says successful grant management. Basically, it encompasses a team, so it's a group of us who are working together to kind of work through the special conditions, to clear those special conditions, so that you can move forward and receive a budget clearance, and you can move forward with implementing your project. And there are others here that you can read on the screen, but I won't take too much time with these here. Next slide, please.
And now this slide brings us to some key takeaways. So one is you want to, again, you want to review your award conditions. Be familiar with those award conditions, and communicate with your OVC grant manager if any of the award conditions are ambiguous. It's important that you are clear, that you read through those. There are a lot of conditions there, but in certain cases, most certainly now because we do have, and it will, you know, the new condition as it pertains to construction or required documents, some of those conditions may have changed a bit, so you want to make sure that you read all of those conditions. You want to make contact with your grant manager if anything is unclear to you. The second one is take action if you have a withholding award condition.
Again, work directly with your OVC grant manager to satisfy those conditions so that they can be removed from the award. Your grant manager, and Lori and I have both stressed, your grant manager is here to help, so contact your grant manager on a as-needed basis for guidance. You know, anytime it's needed, just please contact us. We're not here to determine how many contacts you make, but we're here to support you as you go through your particular project.
Number four, take the Grants Financial Management Training. Lori touched on this as well. This is an award requirement that must be satisfied within 120 days of award acceptance. The primary POC and all financial POCs must complete this training. So, again, remember to at least satisfy this condition within 120 days of the acceptance of the award.
The fifth one on the screen says know the reporting requirements. PMT quarterly requirements and JustGrants' semi-annual reporting requirements. So you want to make sure that if you're completing those quarterly reports in the PMT, once you get to the section where it asks for the completion of a semi-annual report, that that semi-annual report is completed in its entirety, and that that report is converted into a PDF and then uploaded as the semi-annual report in JustGrants.
And lastly, know that training and technical assistance is available to you at no cost, both financial TTA from our financial provider, TFMC, and our programmatic TTA provider, T-VSTTA. So if those individuals are unknown to you, if you have not already been in contact with a programmatic TA provider or a financial TA provider, I encourage you, if you need support, to reach out to your OVC grant manager, who can then identify your assigned financial or programmatic TTA provider and put you in contact with them, so that they can assist you with any support that's needed on the financial or programmatic side. Next slide, please.
So this slide contains websites and resources to include the OVC Tribal Division webpage, the DOJ Grants Financial Guide, the System for Award Management known as SAM, JustGrants, and the DOJ Grants Financial Management Online Training.
So, I believe the slide deck will be available, I believe, it's five to seven days. I may be corrected, but maybe shortly thereafter this webinar, so that if you don't already have these references, you'll have them for future reference that you can refer back to should you need to contact any one of, or should you need to actually tap into any of these resources. Next slide, please.
And so this brings me to my very last slide in this presentation, which gives some useful contact information to include the OVC mainline phone number and email address, the JustGrants Help Desk number and email address, the OVC PMT Help Desk phone number and email address, and the OCFO Customer Service Center phone number and email address, so you have this information. Also, if you don't, you will have it shortly thereafter the webinar for your reference as well. So I highly encourage you to and recommend that you keep any of these, the resources, and to include the contact information for future reference.
I'm sure it will come in handy in case you're fishing around or trying to figure out the information for JustGrants or the PMT Help Desk. And even without these resources handy, again, you can contact your grant manager here within OVC who can put you in contact with any component where you need additional support as it relates to maybe the PMT, or if you have JustGrants issues, et cetera. And with that said, this concludes my portion of today's presentation. And again, I would like to thank each of you for taking the time to learn more about your TVSSA award conditions. That said, I will now turn it back over to Jana from T-VSTTA.
JANA PFEIFFER: Great, thank you for sharing all of those links, Ramesa. Just to remind you all, you can definitely find these links from today that were mentioned are also in the chat as well. So thank you so much for your time and your attention today. Just a little bit more few housekeeping items to send us off in a good way.
First, I'd like to kind of take a pause and just a moment of reflection to share any final thoughts in the chat. You can put them in the chat box right now. Any other thoughts that you may have during the webinar, you can share them in the chat box. Well, thank you so much for sharing. As you can see on the screen, there is one upcoming webinar in this series where we will explore effective financial management. This will take place on Tuesday, June 27th, 2:00 p.m. to 4:00 p.m. eastern time. You can find the registration link in the chat box as well. If you haven't already done so, please register as soon as possible. Get it on your calendar and get ready for the session.
And we encourage anyone from any of your grants or your organization who works with the finance to attend, and we also dropped the link there, again, in the chat. Thank you so much, everybody, who took their time to join us today. We are looking forward to walking with you as you continue to serve your communities, so we will see you next week.
Disclaimer:
Opinions or points of view expressed in these recordings represent those of the speakers and do not necessarily represent the official position or policies of the U.S. Department of Justice. Any commercial products and manufacturers discussed in these recordings are presented for informational purposes only and do not constitute product approval or endorsement by the U.S. Department of Justice.
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