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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 solicitation under which the award was made, and with the terms and conditions contained in their award documents.

Simply stated: when in doubt, refer to the solicitation and your award documents.

The solicitation 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 solicitation and review the award conditions in JustGrants before consulting your OVC grant manager.

Below are some frequently asked questions and responses about the OVC human trafficking awards.


Question Answer Topic

Where can I find information about allowable costs or specific financial questions?

You may consult the Department of Justice (DOJ) Grants Financial Guide, which serves as the primary reference manual to assist the Office of Justice Programs (OJP) in fulfilling their fiduciary responsibility to safeguard grant funds and ensure funds are used for the purposes for which they were awarded. It compiles a variety of laws, rules and regulations that affect the financial and administrative management of your award. The solicitation under which the award was made may also provide guidance about allowable and unallowable costs. Grantees are responsible for ensuring that no federal or match funds are expended for unallowable costs. The Financial Guide should be the starting point for all award recipients of DOJ grants and cooperative agreements in ensuring the effective day-to-day management of awards. Additionally, grantees may refer to the 2 C.F.R. § 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

If you have questions about information presented in the Financial Guide, please contact the Office of the Chief Financial Officer via phone at 800–458–0786 or via email: [email protected].

Financial

Can award funds be used for gift cards?

Gift cards should be used only when reasonably necessary for urgent and short-term victim needs. OVC-funded organizations using gift cards should have a written gift card policy and internal controls over the purchase, storage, custody, use of, and accounting for, gift cards.

For additional information, please consult the Gift Card Best Practices for OVC-funded Victim Service Providers.

Financial
Can award funds be used for participation incentives?

Neither cash nor non-cash stipends or incentives may be paid to victims to encourage their participation in services. While it is unallowable to offer incentives for participation in services, funds can be used to lower the barrier to access participation. For example, transportation or childcare allotments could be used to encourage participation.

Gift cards may sometimes be used for as incentives for participation in research or program assessment.  However, there are separate restrictions on these, and they must have prior approval from OVC.

Financial
Can match be waived?

No. By statute, OVC human trafficking grants funded under the Trafficking Victims Protection Act (TVPA) of 2000 require a 25 percent match. Because it is a law, OVC has no authority to issue a waiver. Please note that OVC human trafficking grants expressly funded under training and technical assistance solicitations are not subject to match. Refer to your solicitation and award documents for more information on match.

Grantees subject to audit or in-depth financial review who do not maintain complete records documenting match may be required to reimburse the government for the match value. Please note that matching contributions are restricted to the same use of funds as allowed for the Federal funds. Please consult award documents to confirm award requirements and authorizing statutes.

Financial
We didn’t get a cleared (i.e., “approved”) budget until several months after the award start date. Does my award end date change? No. The award start and end dates will remain the same. Please reference your award documents to confirm the start date. Project period extensions may be available; however, this is generally not considered until the last year of your award. Financial
How can I extend my award project period?

If needed, grantees, in consultation with their OVC grant manager, may request a project period extension during the final year of their project period. Grantees must submit the request as a Grant Award Modification (GAM) in JustGrants at least 30 calendar days prior to the end of the award. The award period will not be extended merely for the purpose of using unobligated funds. All project period extension requests must include:

  • A letter of request on letterhead signed by leadership with detailed justification.
  • A revised timeline.

Generally, the following shall apply to all grants and cooperative agreements:

  • No more than one project period extension may be made to the award.
  • A project period extension may not exceed 12 months.
  • An extension may be made only if the period of performance has not expired.
  • Award recipients requesting an extension should have no significant performance or compliance issues.
  • A robust narrative justification must be included establishing that the extension is for the benefit of the Federal Government, and containing a plan and timeline for completion within the project period extension.
  • A project period extension may not be made merely for the benefit of the recipient or for the purpose of enabling the recipient to use unobligated balances.

All extension requests will be evaluated on a case-by-case basis. Please consult the DOJ Grants Financial Guide for additional guidance on no-cost extension requests.

Financial
When are my financial reports due?

OVC grantees are required to file a Federal Financial Report (FFR) on a quarterly basis in JustGrants. The FFR is used to track actual expenditures and unliquidated obligations and is due no later than 30 days after the calendar quarter ends. The final FFR is due 120 days after the award end date. Grantees are encouraged to submit the FFR as soon as the quarter ends to avoid delays in processing and access to grant funds. Any questions about FFR submissions should be directed to the Office of the Chief Financial Officer via phone at 800-458-0786 or via email: [email protected]. The schedule for submitting FFRs is:

Reporting Quarter

Due no Later Than

January 1 – March 31

April 30

April 1 – June 30

July 30

July 1 – September 30

October 30

October 1 – December 31

January 30

Financial
Is there a limit on how often I can draw down award funds?

No. Organizations should request funds based upon immediate disbursement/reimbursement requirements. Funds will not be paid in a lump sum, but rather disbursed over time as project costs are incurred or anticipated.

Draw down requests should be timed to ensure that Federal cash on hand is the minimum needed for disbursements/ reimbursements to be made immediately or within 10 days. If not spent or disbursed within 10 days, funds must be returned to the awarding agency.

Financial
What are the reasons that my funds may be frozen or withheld?

Under certain circumstances, an award recipient may be unable to access or draw down funds on an award. If either a financial or performance report is delinquent, JustGrants will automatically place a hold on grant funds. Once the delinquent report has been submitted, the hold on funds will be removed and the suspension is typically lifted within 24 hours. Additionally, OVC may withhold funds from the organization if any of the following conditions exist:

  • Program or project goals have not been timely met.
  • Cash has been drawn down in excess of immediate needs for disbursement.
  • Award terms and conditions or guidelines have not been met.
  • Programmatic/financial monitoring, Office of the Inspector General Audits, or single audits revealed serious concerns regarding the administration of the award, subawards, or contracts.
  • A closeout of the award has not been initiated within 120 days of the end of the project period.
  • The recipient has been designated as a DOJ high-risk grantee.
  • When a closeout is submitted, funds are frozen.

In such circumstances, OVC will provide the recipient with an opportunity to object and provide information and documentation challenging the suspension or termination action (2 C.F.R. § 200.342). Hearing and appeal procedures will follow those in DOJ regulations at 28 C.F.R. § Part 18, as applicable.

Financial
I did not spend the entire amount of the Year 1 budget: do I need to do a budget modification?

Not necessarily. Once the initial budget submission receives final approval from the Office of the Chief Financial Officer, the budget is implemented for the entire award period. Any unused funds from one year automatically rollover to the next year. However, if you need to make changes to your budget, such as moving funds from one budget line item to another, please consult the DOJ Grants Financial Guide.

All budget changes should be discussed with, and may require formal approval from, your OVC grant manager. See the "When is a Financial Budget Modification Grant Award Modification (GAM) required?" question on when budget modifications are needed.

Financial
When is a Financial Budget Modification Grant Award Modification (GAM) required?

OJP grantees must initiate a GAM in JustGrants for budget modification, if:

  • The proposed cumulative change is greater than 10 percent of the total award amount. The 10 percent rule does not apply to an award of less than $250,000.
     
  • The budget modification changes the scope of the project. Examples include altering the purpose of the project, authorizing the use of a subcontractor or other organization that was not identified in the original approved budget, or contracting for or transferring of award-supported efforts.
     
  • A budget adjustment affects a cost category that was not included in the original budget. For example, if the direct cost category “Travel” did not exist in the original budget, the adjustment to transfer funds from “Equipment” to “Travel” requires a GAM.
     
  • There is a dollar increase or decrease to the indirect cost category of an approved budget.
     
  • If none of the above stipulations are met, then grantees can work with their OVC grant manager to document the requested budget modifications. Please note that the 10 percent rule is cumulative so it is important for finance staff to track any smaller adjustments and submit a formal GAM in JustGrants once the cumulative 10 percent is met, documenting all previous adjustments in the request.
Financial

Can my organization use the de minimus indirect cost rate?

Please refer to 2 C.F.R. § 200.414(f) and the DOJ Grants Financial Guide for information governing the use of the de minimus indirect cost rate. Financial
What administrative and financial training is required by OVC?

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.

Administrative
Are there any requirements related to mandated reporting? 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. Administrative

Can I limit my program to certain kinds of victims?

Please refer to the solicitation 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 [email protected].

Administrative
Are grantees required to provide language access as part of our grant-funding programming?

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.

Administrative
Do I need to add my OVC grant number and a disclaimer to any products developed under this award? Where can I find this language?

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.

Administrative
Am I required to report subaward/subrecipient funding?

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 FFATA Subaward Reporting System (FSRS) is the reporting tool grantees must use to capture and report subaward information, including any executive compensation data on subgrantees required by FFATA. The subaward information entered in FSRS will then be displayed on USASpending.gov and associated with the prime award.

Administrative
Am I required to monitor subrecipient activities? 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 DOJ Grants Financial Guide section on Subrecipient Management and Monitoring, and this OVC Mini Toolkit for Subrecipient Monitoring. Administrative
What are OVC’s expectations around client privacy and confidentiality?

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.

Administrative
Which award conditions require additional documentation and follow up actions?

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.
       
  • 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.
       
  • 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.
Administrative
Where can I find the performance measures for my award? Information about grantee performance measures can be located on the OVC Human Trafficking Performance Measures website. 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. Administrative
What is the performance reporting schedule?

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

Administrative
What should I include in my final performance report? The final report should document all relevant 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 actually 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 is due in JustGrants no later than 120 days following the close of the award project period or the expiration of any extension periods. Administrative
Who is considered a victim of human trafficking and potential victim of trafficking for the purposes of 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 where a client lives, works, 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.

Programmatic
Are there age restrictions for clients who can be served? Your solicitation will outline client eligibility and any specific age range limitations, if any exist. Programmatic
Can I work with another OVC grantee to jointly provide services to the same client?

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.

Programmatic
Can I use OVC funds to provide services to a client who is already receiving services through another federal funding stream? 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. Programmatic

Can grant funds be used to provide services to trafficking victims’ family members?

Please refer to the solicitation 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.

Programmatic
Can I serve victims who are outside the geographic area of the grant? 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. Programmatic
Can I serve a victim whose trafficking experience took place outside of the United States? 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. Programmatic
Can I only provide services to current or recent victims of trafficking? 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 solicitation. Programmatic
Can I provide services to a client who does not self-identify as a victim of human trafficking? 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. Programmatic
How should I document client eligibility?

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.

Programmatic
Are there any approval and supervision requirements for grant-funded staff providing direct services to clients?

Grantees should have policies and procedures in place to ensure that staff working directly with clients receive adequate training, support, and supervision. OVC requires that key staff, including case managers, must have prior victim service experience or be under the direct supervision of a senior case manager or project director with such experience. OVC recommends that case managers receive clinical supervision from a licensed social worker.

Grantees should note that the OVC award condition that states that the project director and/or any other key program personnel designated in the application shall be replaced only for compelling reasons. Successors to key personnel must be approved by OJP, and such approval is contingent upon submission of appropriate information, including, but not limited to, a resume. Changes in program personnel, other than key personnel, require only notification to OJP and submission of resumes, unless otherwise designated in the award document.

Any human trafficking grantee (and any subrecipient thereof) may not permit any grant staff to interact with any minor in the course of activities under the award, unless the recipient or subrecipient first has made a written determination of the suitability of that individual to interact with participating minors, based on current and appropriate information.

Programmatic
Does OVC have a recommended or required anti-trafficking training for grant-funded staff?

Yes. OVC strongly encourages the project coordinator or program director and one other key staff member from your organization to attend an in-person or remote OVC grantee orientation and have relevant staff participate in OVC-sponsored training and technical assistance throughout the award project period.

OVC recommends that new staff and community partners take the Understanding Human Trafficking foundational training. 

Programmatic
Can I use OVC award funding to support prevention activities?

Please refer to the solicitation an award was funded under for program-specific requirements.

For most OVC Human Trafficking programs funded under the Trafficking Victims Protection Act (TVPA), the purpose of the funding is to support victim service programs: therefore, applicants should not propose primary prevention activities under this program. Primary prevention activities are any activities designed to protect individuals prior to victimization (i.e., stopping victimization before it occurs). Examples of primary prevention activities may include activities focused on the perpetrator of a crime, or that are focused primarily on crime prevention. Training and outreach conducted using OVC anti-trafficking funding should have the primary purpose of identification and referral of victims, but prevention may be an ancillary outcome of the program. Activities focused on preventing the revictimization of trafficking survivors are allowable.

One exception to the paragraph above is OVC’s Preventing Trafficking of Girls Program, which is funded under the Juvenile Justice and Delinquency Prevention Act of 1974 and does support prevention and early intervention programming for girls who are at risk of, or are victims of, sex trafficking.

Programmatic
What expectations does OVC have for the programmatic policies and procedures of ant-trafficking award recipients?

OVC is committed to an approach to human trafficking that is trauma-informed, victim- centered, survivor informed, culturally competent; and evidence-based. Definitions of these concepts are available in the glossary of OVC’s Model Standards for Serving Victims and Survivors of Crime.

In line with these concepts and to enhance survivors’ access to victim services, starting in FY 2022, OVC anti-trafficking programs selected for award will be required to attest that they engage in practices that remove barriers to receiving services and support survivor autonomy. Such practices will reduce requirements to engage in services, promote survivors’ choice within service delivery, and protect victim privacy and confidentiality.

Funded programs will demonstrate their commitment to this approach by maintaining the following. (Note: Many of these requirements are mandated by federal civil rights laws, while others reflect OVC’s policy direction to recipients to enhance access to services and promote survivor autonomy.)

  • Procedures or policies that provide all survivors access to safe shelter, advocacy services, counseling, and other assistance without exclusions based on actual or perceived sex, age, immigration status, race, religion, sexual orientation, gender identity, mental health condition, physical health condition, criminal record, involvement in commercial sex, income or lack of income, or the age and/or sex of their children. For those programs that by their design target a particular population (e.g., youth, gender specific) there should be procedures or policies in place to ensure access to comparable, qualified services for other survivors seeking support.
     
  • Procedures or policies that protect the confidentiality of information and/or privacy of persons receiving services.
     
  • Procedures or policies that do not require victims to take certain actions (e.g., receive counseling, report to law enforcement, commit to sobriety) to be eligible for, or to receive services. For youth serving programs with justifiable mandatory requirements, a shared decision making model should be used to provide minors with agency in determining a course of action.
     
  • Project designs, products, services, and/or budgets that consider the unique needs of individuals with disabilities, with limited English proficiency, or who are Deaf or hard of hearing, including accessibility for such individuals.
Programmatic
How should my organization document its match?

Grantees must keep detailed accounting records and documentation to track match funding. The grantee’s financial records must clearly show the source, amount, and timing for all matched contributions. The grantee has the primary responsibility for meeting the match requirement and for ensuring subrecipient compliance with match requirements. In addition, if a recipient or subrecipient has included a match that exceeds the required matching portion within the approved budget, the records of those additional amounts must be included and maintained as if they are a part of the regular match amount. Matching funds are restricted to the same use of funds as allowed for the Federal funds, and subject to audit.

Grantees are required to report the match (both cash and in-kind) on the quarterly Federal Financial Report (FFR). Additionally, the full matching share provided (both cash and in-kind) must be reported on the final FFR submitted at the end of the period of performance. If the matching share is not reported, DOJ will assume the grantee did not meet the required match and will initiate collection of a cash match from the grantee. The DOJ Grants Financial Guide includes additional information on matching and cost sharing requirements.

For general government-wide rules regarding match and match requirements, see 2 C.F.R. § 200.306.

Financial
Does my agency need to submit an annual audit report?

A non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of 2 C.F.R. § 200 Subpart F – Audit Requirements. Audit reports must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or 9 months after the end of the audit period.

Federal agencies can no longer grant due date extensions for submission of single audit reports. The Federal Audit Clearinghouse (FAC) requires all grant award recipients to use the Internet Data Entry System (IDES) to submit the Standard Form-Single Audit Component (SF-SAC) and the Single Audit Reporting package online.

Financial
Who should I refer my organization’s auditor to when conducting an audit of financial statements for this award? Please send any requests for the auditor of your organization to OJP’s Audit Confirmation email: [email protected]. Financial
If I am giving a training that was not developed using award funds, but I am using time charged to the award to deliver the training, do I need to add the OVC disclaimer language? 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.” Administrative
Who should I contact if I have concerns about or have witnessed misconduct related to an OVC award? 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. Administrative
What is the Trafficking Victim Assistance Program (TVAP) and how does it relate to my OVC-funded anti-trafficking program? TVAP is a grant program offered through the Office on Trafficking in Persons within the U.S. Department of Health & Human Services Administration for Children & Families that funds comprehensive case management services for adult foreign national victims of a severe form of trafficking in persons, potential victims of trafficking seeking HHS Certification, and their qualified family members through a national network of service providers. OVC anti-trafficking grantees should expect that at times they may receive requests for referrals from TVAP-funded programs. Please consult the TVAP website for additional information on the program. Programmatic
What is the Aspire: Child Trafficking Victim Assistance Demonstration Program and how does it relate to my OVC-funded anti-trafficking program? Aspire is a grant program offered through the Office on Trafficking in Persons within the U.S. Department of Health & Human Services Administration for Children & Families that funds comprehensive case management services for foreign national children and youth victims of a severe form of trafficking in persons, potential victims of trafficking seeking HHS Certification, and their qualified family members through a national network of service providers. OVC anti-trafficking grantees should expect that at times they may receive requests for referrals from Aspire-funded programs. Programmatic
How does OVC’s Human Trafficking Division define “key personnel”? For purposes of OVC anti-trafficking awards, “key personnel” refers to the project director, and any other personnel designated in the application or award whose positions are essential to the successful implementation of the award. This includes, but is not limited to, project staff in leadership, supervisory, coordination, or project lead roles. Additional questions about key personnel may be directed to your OVC Grant Manager. Programmatic
Date Modified: September 23, 2022
Date Created: February 11, 2022