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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.
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.
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.
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.
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.
