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Human Trafficking
OVC Human Trafficking Program FAQs
Grantees are expected to be familiar with—
the program requirements detailed in the fiscal year funding opportunity under which the award was made, and
the terms and conditions contained in their award documents.
Simply stated: when in doubt, refer to the notice of funding opportunity and your award documents.
The notice of funding opportunity may outline specific allowable and unallowable costs and activities, and the award conditions detailed in the award documents will provide further guidance about programmatic requirements.
Grantees should read the notice of funding opportunity and review the award conditions in JustGrants before consulting their OVC grant manager.
Below are some frequently asked questions and responses about the OVC human trafficking awards.
Persons who have been subjected to a “severe form of trafficking in persons,” as defined in 22 U.S.C. § 7102(11).
(A) sex trafficking in which a commercial sex act is induced by force, fraud, or coercion, or in which the person induced to perform such act has not attained 18 years of age; or
(B) the recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.
An individual does not need to currently be in a trafficking situation to be eligible for victim services, or have recently exited their trafficking situation. Grantees should remove barriers that prevent individuals currently experiencing trafficking from accessing services, such as policies related to sobriety, engagement in commercial sex, etc.
OVC acknowledges that the amount of time and the process for determining if a person meets the definition of a victim of human trafficking may differ for every client and situation. OVC considers an individual to be a “potential” when the grantee has reason to believe that the person is or might be a trafficking victim and is providing support or services tailored to that individual. This may occur at an initial intake or screening interview, or upon completion of victim needs assessment.
When the information needed to determine eligibility is not immediately available, and the person is not clearly ineligible, a grantee may use OVC funds for a reasonable period of time to provide services until sufficient information to make a determination has been gathered and a determination has been made. If the client is not eligible, they should be referred to other appropriate services and providers.
Your notice of funding opportunity will outline client eligibility and any specific age range limitations, if any exist.
Yes. OVC encourages grantees to coordinate their efforts with other similar OVC-direct funded human trafficking programs within the relevant jurisdiction to enhance the projects and avoid duplication of efforts. Grantees are expected to work together to determine whether OVC discretionary award funds have been, are being, or are to be used (in whole or in part) for one or more of the identical services for the same person or family member (cost items) included in the each of their grant award budgets.
If duplicative costs and services are identified, each grantee must notify their OVC grant manager(s) in writing of the potential duplication and, if requested by OVC, submit a Financial or Programmatic GAM to eliminate any inappropriate duplication of funding.
Yes. As long as there is no duplication in costs or activities, OVC funds may be used to provide services to a client who is already receiving services through another federal funding stream. For example, an OVC grantee could provide legal services to an individual client receiving housing services funded through a different federal award. However, please consult requirements for other funding sources, as they may differ.
Please refer to the notice of funding opportunity your award was funded under for program-specific requirements.
Human trafficking is a crime that impacts not only the victim, but also the victim’s family. Providers must work with each client to understand his or her individual situation and develop appropriate goals regarding family members. Grant funds for services are intended primarily to support the cost of direct services for victims of human trafficking. Where the services for family members are directly related to promoting justice and healing for trafficking survivors, they are potentially allowable.
Every effort must be made to refer family members to other free and low-cost services, and to assist them in accessing federal, state, or local programs for which they may be eligible, including Medicaid, TANF, subsidized or transitional housing programs, schools, and workforce development and employment programs. Please contact your grant manager with specific questions related to using grant-funding for services for family members.
Per OVC’s human trafficking victim assistance performance measures, the definition of an eligible family member is: A related family member of the principal individual that receives services under the given grant. These individuals are not counted as the principal individual clients for the purpose of reports, and services incurred will be counted separately. For minors, eligible family members may include parents, spouse, children, and unmarried siblings under 21. For adults, eligible family members include spouse and children.
Grantees that serve all human trafficking victims within a geographic service area may also serve victims from outside of that area, with written approval from the OVC grant manager, if the grantee determines that it has the capacity to serve the victim and no other OVC-funded grantee is available to serve the victim. Grantees planning to permanently expand their service area must submit a Grant Award Modification (GAM) for a change in project scope.
Yes. As long as the client is a victim of a severe form of trafficking in persons who currently resides in the United States, they are eligible to receive services.
Grantees are able to serve all human trafficking victims, regardless of when the client experienced trafficking, subject to the specific parameters detailed in their award funding opportunity.
Yes. Clients are never required to self-identify as a victim and services should not be contingent upon self-identification. If the grantee determines, in good faith, that the client is a victim of human trafficking, services may be provided.
Grantee program staff should record the date(s) when the eligibility requirement is met on the intake form, case management system, or the equivalent. This documentation should be maintained in the case file to demonstrate the completion and outcome of screening for OVC program eligibility for each client served. Specific details of the person’s human trafficking experience are not necessary and generally should not be kept in the file maintained by the case manager or other staff.
