OVC Human Trafficking Program FAQs: Administrative

The assigned Grant Award Administrator and all Financial Managers for grant awards must have successfully completed the OJP Grants Financial Management and Grant Administration Training by 120 days after the grantee’s acceptance date of the award. Successful completion of such a training within the last three years, will satisfy this condition. In the event that either the Grant Award Administrator or Financial Manager changes during the award project period, the new staff member must have successfully completed an OJP Grants Financial Management and Grant Administration Training by 120 calendar days after the user information has been changed in JustGrants.

Grantees should anticipate that OJP will immediately withhold award funds, if the grantee fails to comply with this condition. Failure to comply also may lead OJP to impose additional appropriate conditions on the grant award.

Grantees should note that this requirement is also included as an award condition.

Yes. Grantees working with minors and vulnerable adults must have policies and procedures in place regarding mandated reporting. Grantees must be aware of state laws that determine who must report concerns of child and vulnerable adult abuse and neglect, definitions of abuse and neglect, and the process for making a report. Grantees should include information about their mandated reporting requirements in the informed consent forms, in language that is appropriate for the client. Grantees should train all staff and volunteers who will interact with minors and vulnerable adults served by the program to ensure compliance with state mandated reporting requirements.

Please refer to the notice of funding opportunity an award was funded under for program-specific requirements.

Federal laws prohibit recipients of Trafficking Victims Protection Act (TVPA) funding administered by the OJP from discriminating in the delivery of services on the basis of age, race, color, national origin, religion, or disability. Applicable federal laws also prohibit TVPA recipients from discriminating on the basis of disability in their employment practices, and from discriminating against employees and beneficiaries on the basis of sex in grant-funded education or training programs. Recipients are also obligated under federal civil rights laws to provide meaningful access to their programs and activities for persons with limited English proficiency. Under certain circumstances, it might be permissible to limit services based upon age. Please note that other federal, state, or local laws prohibiting discrimination may apply. See Civil Rights Requirements Associated with OJP Awards for more information.

All grantees are required to have a process in place for investigating discrimination complaints. The Office for Civil Rights at OJP ensures that recipients of financial assistance from OVC comply with federal laws that prohibit discrimination and is available to provide technical assistance to OVC grantees about civil rights obligations.

Employees, beneficiaries, and applicants for employment or services of an OVC grantee who believe that they have experienced unlawful discrimination may file a civil rights complaint with the Office for Civil Rights at OJP.

If you have questions about civil rights compliance, please contact the Office for Civil Rights via phone at 202-307-0690, TDD/TTY at 202-307-2027, or via email at askOCR@usdoj.gov.

Yes. Compliance with Title VI of the Civil Rights Act of 1964, which prohibits grantees from discriminating on the basis of national origin in the delivery of services or benefits, entails taking reasonable steps to ensure that persons with limited English proficiency (LEP) have meaningful access to their programs and activities. An LEP person is one whose first language is not English and who has a limited ability to read, write, speak, or understand English.

To assist grantees in meeting their obligation to serve LEP persons, DOJ has published a number of resources, including a language access assessment and planning tool. Additional resources are available on the Office of Civil Rights webpage. Grantees should contemplate how their program budget supports the costs for providing interpretation and translation services to eligible LEP persons or be able explain how language access will be provided if grant funds are not needed for this purpose.

Yes. Please refer to your award conditions for specific requirements. All products (e.g., curricula, training materials, publications, reports, videos, fliers, or any other written, web-based, or audiovisual, or other materials) developed and/or published with grant funds must contain the grant disclaimer statement found in your award conditions:

“This ______________ was produced by ______________ under [add grant number], awarded by the Office for Victims of Crime, Office of Justice Programs, U.S. Department of Justice. The opinions, findings, and conclusions or recommendations expressed in this ______________ are those of the contributors and do not necessarily represent the official position or policies of the U.S. Department of Justice.”

Your OVC grant manager will determine whether minor deliverables, such as one-page fliers and discrete web pages, require review or prior approval by OVC.

Yes. Under the Federal Funding Accountability and Transparency Act of 2006 (FFATA), grantees of awards of $30,000 or more are required to report award information on any first-tier subawards totaling $30,000 or more and, in certain circumstances, to report the names and total compensation of the five most highly compensated executives of the grantee and first-tier subgrantees.

Recipient executive compensation data are to be reported in the System for Award Management (SAM). The previous reporting tool for subaward information, FFATA Subaward Reporting System (FSRS), was retired on March 8, 2025, and all subaward reporting data and functionality are now on SAM.gov. Learn more about the subaward reporting transition from FSRS to SAM.gov.

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.

Starting in October 2024, many OVC anti-trafficking grantees (and any “subrecipient” at any tier) that provide services to trafficking survivors must have, or be actively working with OVC to establish, privacy and confidentiality policies and procedures that conform with the requirements of 34 U.S.C. 12291(b)(2). Section 12291(b)(2) is the confidentiality and privacy condition applicable to awards under the Violence Against Women Act of 1994, commonly referred to as the “VAWA Confidentiality Provision.” For purposes of OVC’s anti-trafficking program, the phrase “under this subchapter” in the VAWA Confidentiality Provision shall be understood as referring to “under this OVC program.” With prior approval from OVC, recipients may use award funds to develop policies and procedures that comply with the VAWA Confidentiality Provision. Learn more about the VAWA Confidentiality Provision.

Grantees may refer to the confidentiality award condition placed on their award to determine if they are subject to VAWA confidentiality provision, or they may consult with their OVC grant manager.

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 ovcpmt@usdoj.gov 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 justicegrants.support@usdoj.gov 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:

The final performance 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. Answer questions based on the goals you set out to accomplish at the beginning of your award – reviewing the goals and objectives on your award application may help.

The narrative report should include detailed information about the project funded, including, but not limited to—

• descriptions of all relevant project activities conducted during the award period with federal and match funds and how they align with the OVC program goals and objectives,
• analysis of data to support statements of progress, and 
• examples of individual results and outcomes of funded activities reflecting project successes and impacts. 

In addition to the final performance report narrative, most grantees must also attach a PMT Report with cumulative data from the entire project period. If grant funds were used to conduct a project evaluation or action research, these evaluation documents should be attached as well. 

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.

It is important that each OJP recipient have a full understanding which (if any) of its actions (for purposes of OJP and other federal grants administrative requirements) are “subawards”, and which are “procurement contracts under an award.” The substance of the relationship should be given greater consideration than the form of agreement between the recipient and the outside entity.

If an OJP recipient agrees to provide award funds to an outside entity (or another third party), so that the outside entity will carry out part of the OJP award or program, OJP will consider the agreement between the recipient and the outside entity a “subaward.” If, instead, an OJP recipient agrees to provide funds to an outside entity, and, in exchange, the outside entity will simply provide the recipient with goods or services ancillary to the award, rather than “carry out part of the OJP award,” OJP will consider the agreement a “procurement contract (or procurement transaction) under the OJP award,” not a “subaward.” The critical question, then, is whether the outside entity is “carry[ing] out part of the OJP award or program.” The answer lies in the relationship between– (1) what the outside entity will do under its agreement with the recipient, and (2) what the recipient has committed (to OJP) to do to further the public purpose(s) of the OJP award.

The Office of Justice Programs (OJP) has developed the following guidance documents to help clarify the differences between subawards and procurement contracts under an OJP award and outline the compliance and reporting requirements for each.

• Subawards under OJP Awards and Procurement Contracts under Awards: A Toolkit for OJP Recipients.
• Checklist to Determine Subrecipient or Contractor Classification.
• Sole Source Justification Fact Sheet and Sole Source Review Checklist.
• Guide to Procurement Procedures for Recipients of DOJ Grants and Cooperative Agreements.

Please contact your grant manager if you have any questions regarding subawards and procurement contracts under an OJP award.

Your award package, including award conditions, will indicate whether your award was made as a grant or a cooperative agreement. Grants and cooperative agreement are both legal instruments of financial assistance from the Federal Government to a non-federal entity to carry out a public purpose authorized by U.S. law. Cooperative agreements provide for substantial involvement of the Federal awarding agency in carrying out the activity contemplated by the Federal award, while grants do not.

All cooperative agreements will include the Statement of Federal Involvement award condition: 

Due to the substantial Federal involvement contemplated in completion of this project, the OVC has elected to enter into a cooperative agreement rather than a grant. This decision is based on OJP and OVC’s ongoing responsibility to assist and coordinate projects that relate to the funded activities. OJP and OVC will provide input and re-direction to the project, as needed, in consultation with the recipient, and will actively monitor the project by methods including, but not limited to, ongoing contact with the recipient. In meeting programmatic responsibilities, OJP, OVC, and the recipient will be guided by the following principles: responsibility for the day-to-day operations of this project rests with the recipient in implementation of the recipient’s approved proposal, the recipient’s approved budget, and the terms and conditions specified in this award. Responsibility for general oversight and redirection of the project, if necessary, rests with OVC. In addition to its programmatic reporting requirements, the recipient agrees to provide necessary information as requested by OJP and OVC. Information requests may include, but are not limited to, specific submissions related to: performance, including measurement of project outputs/outcomes; meeting performance specifications; developmental decision points; changes in project scope or personnel; budget modifications; and/or coordination of related projects.

Cooperative agreements have additional requirements including obtaining prior approval for some costs related to conferences/events. Grantees should carefully review the DOJ Financial Guide to understand the requirements associated with cooperative agreements.

Yes. Changes to subrecipients or subrecipient activities generally need to be reviewed and approved through budget modification and scope change GAMs because they are considered in an award’s eligibility and merit review.