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 [email protected].

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 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.

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.

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, 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.

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 [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.