2014 LLEBG Compliance Webinar

1. 2014 LLEBG Compliance Webinar January 8, 2014 MO Department of Public Safety

2. MO DEPARTMENT OF PUBLIC SAFETYCRIMINAL JUSTICE/LAW ENFORCEMENT UNITCONTACT INFORMATION Ashley Virgin, Program Representative (A to C) (573) 522-3455 Ashley.Virgin@dps.mo.gov Nancy Capps, Program Representative (D to F) (573) 522-4094 Nancy.Capps@dps.mo.gov TBH, Program Representative (G to N) (573) 526-1928 TBA Heather Haslag, Assistant Program Manager (O to Z) (573) 751-1318 Heather.Haslag@dps.mo.gov • Main Phone: (573) 751-4905 • Fax Number1: (573) 522-1908 • Fax Number2: (573) 751-5399 • CFDA #: 16.738 • MO Department of Public Safety • Attn: CJ/LE • PO Box 749 • 301 W. High Street, Room 870 • Jefferson City, MO 65102

3. OUTLINE FOR TODAY • General Grant Information • Budget Costs • Administrative & Financial Guidelines • Civil Rights Compliance • Reporting Requirement • Monitoring • WebGrants • Questions?

4. GENERAL GRANT INFORMATION

5. BACKGROUND Local Law Enforcement Block Grant (LLEBG) • provided through federal Byrne/JAG program • authorized by 42 U.S.C. 3751(a) • awarded to Missouri by the U.S. Department of Justice (DOJ), Office of Justice Programs (OJP) • provides federal criminal justice funding • streamlined the Byrne and LLEBG programs

6. FUNDING • Calculated by the Bureau of Justice Statistics (BJS) Missouri Base Allocation <$10K Allocations >$10K Allocations JAG (Base $) Department of Public Safety Local Units of Government LLEBG (<$10K $)

7. FUNDING cont’d • Things to remember: • Federal Fiscal Year = October 1 to September 30 • LLEBG Contract Period = January 1 to June 30 • 2014 LLEBG Awards are coming from FY 2011, FY2012, and FY2013 monies

8. GENERAL GRANT GUIDELINES • Contract Period: January 1, 2014 to June 30, 2014 • 6 onthProject Period • Local Match Requirement: 10% of Total Project Cost • Cash Match • Eligible Budget Category: • Equipment • Limited to quantity approved • Limited to type of item approved • Can purchase a different model or manufacturer • Can purchase from a different vendor

9. SOURCE OF INFORMATION • DPS Website: www.dps.mo.gov/dir/programs/cjle/llebg.asp • Solicitation • Pre-Bid Training • Compliance Training • Financial & Administrative Guidelines • Radio Interoperability Guidelines • WebGrants: https://dpswebgrants.dps.mo.gov • Opportunity (Funding Opportunity) • Solicitation • Certified Assurances • Office of Justice Programs (OJP) Financial Guide: http://www.ojp.usdoj.gov/financialguide/index.htm • Office of Management and Budget (OMB) Circulars: http://www.whitehouse.gov/omb/circulars_default • Missouri State Statutes: http://www.moga.mo.gov/

10. BUDGET COSTS

11. EQUIPMENT COSTS • Must adhere to most restrictive procurement policy • All equipment must be compatible with the current statewide system • Communication devices must adhere to the state’s interoperability plan • Portable radios, repeaters, and base stations have no specifications • Mobile radios must be P25 compliant and operate in the trunked mode at the time of purchase • List of compliant communication devices available at http://www.dps.mo.gov/dir/programs/cjle/llebg.asp

12. EQUIPMENT COSTS cont’d • Equipment must be tagged and identifiable for its source of funds (where feasible) • “Purchased with 2014 LLEBG Funds” • Contract Number (e.g. 2013-LLEBG-027) • Must maintain an inventory control listing • Item Description • Source of Property (General Revenue, 2014 LLEBG Grant) • Manufacturer’s Serial Number and/or Model Number • Acquisition Date • Total Cost & Federally-Funded Cost • Location, Use, and Condition of Property • Disposition Date • Disposition Method (e.g. trash, sale, trade)

13. ADMINISTRATIVE AND FINANCIAL GUIDELINES

14. PROJECT IMPLEMENTATION STATUS • If a project is not operational within 60 days of the contract start date, the Contractor must report to DPS, via the “Correspondence” component of WebGrants, the steps taken to initiate the project, the reasons for delay, and the expected start date. • If a project is not operational within 90 days of the contract start date, the Contractor must submit a second statement to DPS, via the “Correspondence” component of WebGrants, explaining the implementation delay. • Upon receipt of the second statement, DPS may decide whether to continue with the project or to terminate the contract.

15. FUNDS • Contractors must report actual cash expenditures and any program income/interest that was earned • Expenditures will be reported through a “Status Report” • Funds must be obligated within the contract period and expended within 60 days following the contract period end date • Contract Period: January 1, 2014 to June 30, 2014 • 60 days following: August 29, 2014 • Funds are obligated when a legal liability to pay a determinable sum for services or goods is incurred and will require payment during the same or future period (e.g. purchase order date) • Funds are expended when payment is made.

16. INTERNAL CONTROLS • Agency must track, account for, and report on all funds separately from all other funds • DPS encourages agencies to open a separate account for the LLEBG grant share and the local match share but does not require it if the unit of government has adequate internal controls • Account may be interest bearing • Any interest earned must be disclosed and reported as program income • Any interest not spent on program-related costs must be returned to DPS • Grant funds may be used in conjunction with other funding as necessary to complete projects but tracking and reporting must be separate • Agency should ensure appropriate internal controls exist for the programmatic and financial aspects of the project

17. PROCUREMENT All Contractors must adhere to the procurement standards contained in “Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments”, 28 CFR, Part 66 General Grant Guidelines: • All procurement transactions whether negotiated or competitively bid and without regard to dollar value shall be conducted in a manner to provide maximum open and free competition • All quotations and the rationale behind the selection of a source of supply must be retained, attached to the purchase order copy, and placed in the accounting files • When only one bid or positive proposal is received, it is deemed to be sole source procurement • Grant guidelines require prior approval from DPS for sole source procurement on amounts of $3,000 and more • Request for approval shall be submitted via the “Correspondence” component of WebGrants with the rationale and a copy of the sole source certification letter from the vendor, if available • Approval of the grant application does not constitute prior approval; must obtain separately State Procurement Policy: • Items costing less than $3,000 may be purchased with prudence on the open market • Items costing between $3,000 but less than $25,000 must be competitively bid, but need not be solicited by mail or advertisement • Items costing $25,000 or over shall be advertised for bid in at least two daily newspapers of general circulation in such places as are most likely to reach prospective bidders at least five days before bids for such purchases are to be opened

18. CONTRACT RECORDS • Establish and maintain accurate financial records and an adequate accounting system. • Records must be retained for a period of 5 years starting from the date of submission of the Status Report or from the date of submission of the audit for the contract period covered, whichever comes later. • Records must be retained beyond a 5 year period if an audit is in progress and/or the findings of a completed audit have not been resolved. • Must adhere to local policy if local retention period is longer than those stated herein. • Financial records must be kept in an orderly manner and be available for audit purposes. • Responsible for protecting records against fire, theft, or other possible damages.

19. PROPERTY RECORDS & DISPOSITION • Required to maintain property management records • Records shall contain copies of the purchase order and invoice • Control system shall be in effect to ensure adequate safeguards to prevent loss, damage, or theft to the property • Any loss, damage, or theft of non-expendable property shall be investigated, fully documented, and made part of the grant file • Adequate maintenance procedures shall be established to keep the property in good condition • May dispose of the personal non-expendable property when original or replacement equipment acquired under an award is no longer needed for the original project • Items with a current per unit fair market value of less than $5,000 may be retained, sold, or otherwise disposed of with no further obligation to DPS • Items with a current per unit fair market value inexcess of $5,000 may be retained or sold but the DPS shall have a right to an amount calculated by multiplying the current market value or proceeds from the sale by DPS’ share of the equipment • Records for non-expendable property acquired with grant funds shall be retained for 5 years after final disposition of property

20. AUDIT REQUIREMENTS • Comply with OMB Circular A-133 “Audits of States, Local Governments, and Non-Profit Institutions” • Audit is required if the agency expends $500,000 or more in federal funds within the organization’s fiscal year from any federal source • Audit must be performed organization-wide by an independent firm • Audit must be conducted with reasonable frequency, usually annually, but not less frequently than every two years • Doesn’t mean that the audit can include every other year though! • Must submit a copy of such audit to DPS via the Correspondence component of WebGrants, where possible • Can mail a copy to DPS if unable to scan the audit report • DPS will start contacting agencies if not submitted by 2/28/14

21. PRINTING AND PUBLICITY • BJA and DPS encourage recipients of federal funding to share success stories of their project • Award of funding • Major cases/investigations • Improvements in services provided as a result of equipment purchases • Agencies are required to disclose of the source of their funding with language such: Funding for this project made available by the Edward Byrne Memorial Justice Assistance Grant (JAG), which is administered by the U.S. Department of Justice, Bureau of Justice Assistance and the State of Missouri, Department of Public Safety

22. CIVIL RIGHTS COMPLIANCE

23. STATE CIVIL RIGHTS LAWS • Section 213.055 RSMo – Unlawful Employment Practices • Contractor may not discriminate on the basis of race, color, religion, national origin, sex, ancestry, age, or disability in its employment practices (e.g. hiring, compensation, conditions, or privileges) • Section 213.065 RSMo – Discrimination in Public Accommodations • Contractor may not discriminate on the basis of race, color, religion, national origin, sex, ancestry, or disability in the use and enjoyment of any place of public accommodation • It is unlawful to refuse, withhold from, or deny any of the accommodations, advantages, facilities, services, or privileges made available in any place of public accommodations

24. FEDERAL CIVIL RIGHTS LAWS • Civil Rights Act of 1964 (42 U.S.C. § 2000d) • Rehabilitation Act of 1973 (29 U.S.C. § 794) • Title IX of the Education Amendments of 1972 (20 U.S.C. § § 1681, 1683, and 1685-86) • Age Discrimination Act of 1975 (42 U.S.C. § § 6101-07) • Americans with Disabilities Act of 1990 (42 U.S.C. § § 12131-34) • U.S. Department of Justice Regulations – Non-Discrimination; Equal Employment Opportunity; Policies and Procedures (28 C.F.R. pt 42) • U.S. Department of Justice Regulations – Equal Treatment for Faith Based Organizations (28 C.F.R. pt 38) • Executive Order 13279 (equal protection of the laws for faith-based and community organizations)

25. EQUAL EMPLOYMENT OPPORTUNITY PLAN (EEOP) • U.S. Department of Justice (DOJ), Office of Justice Programs (OJP) & COPS • 28 C.F.R. 42.301 – 42.308 • A workforce report completed to ensure recipients of federal funding are providing equal employment opportunities to men and women regardless of sex, race, or national origin. • Effective for a 2-year period, commencing with the date of the approval letter from the Office forCivil Rights (OCR) • EEOP and Certification Form are both effective for 2 years • Should be prepared by the recipient of the federal funding (county, city, state department) • http://www.ojp.usdoj.gov/about/ocr/eeop.htm • Sample policies available for your perusal Not the same as an EEO4, which is required by the U.S. Equal Employment Opportunity Commission.

26. EEOP cont’d

27. “EEOP” – COVER PAGE SAMPLE COVER SHEET Date-stamped when prepared

28. “EEOP” – PAGE 2 SAMPLE • Must list every active award from DOJ monies • Must properly identify whether the award was direct from DOJ or a pass-thru from a state agency Direct awards from DOJ will ask for the DOJ Grant Manager Pass-thru awards from state agency will ask for the State Granting Agency’s information

29. “EEOP CERTIFICATION FORM” SAMPLE • Must complete this form for every active award from DOJ monies • Completed form includes the header and one of the sections (but not all three) • Emailed to OCR per the instruction page

30. NON-DISCRIMINATION • Contractor may not discriminate on the basis of race, color, national origin, religion, sex, or disability in its employment practices or in the delivery of services • If the Contractor has 50 or more employees and receives DOJ funding of $25,000 or more: • the Contractor must have written policies or procedures in place to notify program participants and employees on how to file complaints alleging discrimination • the Contractor must designate a person(s) to coordinate complaints alleging discrimination

31. FINDINGS OF DISCRIMINATION • Contractor must notify DPS of any findings of discrimination within 30 days of the court judgment • Submit the Court Judgment with a cover letter, which identifies your DPS-assigned contract number, as indicated on the Award of Contract • DPS must forward to the Office forCivil Rights (OCR) Missouri Department of Public Safety Attn: Director of Public Safety PO Box 749 301 W. High Street, Room 870 Jefferson City, MO 65102

32. LIMITED ENGLISH PROFICIENCY (LEP) • Contractor must take steps to provide meaningful access to its programs and activities to persons with LEP • Oral Interpretation • Written Interpretation • Individuals with hearing impairment • Individuals whose primary language is not English • Recommended (but not yet required by law) that the Contractor develop a written policy on providing language access services to LEP persons • For more information on LEP, planning tools, or a sample law enforcement policies, go to http://www.ojp.usdoj.gov/about/ocr/lep.htm

33. REPORTING REQUIREMENT

34. REPORTING REQUIREMENT – STATUS REPORT • Must report actual expenditures and to provide receipts to support the purchase(s) • Submitted via the “Status Report” component of WebGrants • Should submit shortly after all equipment has been purchased and funds have been fully expended • Must purchase between January 1, 2014 and June 30, 2014 • Must pay for purchases no later than August 29, 2014 • Status Report due by September 10, 2014 • Submit only 1 Status Report!

35. MONITORING

36. MONITORING • CJ/LE will conduct monitoring of the project to ensure compliance with state and federal laws, regulations, and guidelines • Desk Monitoring – tracking telephone and email communication, as well as reviewing all grant documents, reports, and correspondence • Site Monitoring – a visit to the agency’s office to review policies, receipts, and other records • CJ/LE will take appropriate action if determined the Contractor is acting inappropriately, misusing money, and/or not meeting reporting requirements • Such action may result in the cancellation of the contract and/or action to recoup any funds disbursed to the agency

37. MONITORING CHECKLIST – STATE STATUTES FOR LE AGENCIES • Section 43.505 RSMo - Monthly Uniform Crime Reporting (UCRs) • DPS will verify with MSHP on monthly compliance • Section 590.650 RSMo - Annual Racial Profiling Reporting • DPS will verify with the Attorney General’s Office on annual compliance • Section 513.653 RSMo - Annual Federal Forfeiture Report • DPS will verify internally on annual compliance, where applicable • Section 590.700 RSMo - Recording of Custodial Interrogations • Must present DPS with a copy of the department’s written policy • Section 577.005 RSMo - Forwarding Intoxication-Related Offenses • Must present DPS with a copy of the department’s written policy

38. MONITORING CHECKLIST The following items will be reviewed and/or discussed: • FISCAL • Purchase Order/Requisition (submitted with Status Report) • Invoices/receipts from vendor(submitted with Status Report) • Bid/quote records, where applicable • Sole source letters, where applicable (submitted as Correspondence) • PROGRAMMATIC • Inventory control listing for equipment • Tags/labels on equipment • Local procurement/purchasing policy • Internal controls

39. MONITORING CHECKLIST – FEDERAL CIVIL RIGHTS • Equal Employment Opportunity Plan (EEOP) • Is your agency required to prepare an EEOP? • If your agency is not required to prepare an EEOP, has your agency completed Section A of the Certification Form and submitted such form to OCR? • If your agency is required to prepare an EEOP, has your agency prepared an EEOP Short Form? • If your agency is required to prepare an EEOP but is not required to submit the EEOP to OCR, has your agency completed Section B of the Certification Form and submitted such form to OCR? • If your agency is required to prepare an EEOP and is required to submit a copy to OCR, has your agency submitted the EEOP Short Form to OCR? • If your agency is required to submit the EEOP to OCR, has your agency also completed Section C of the Certification Form and submitted such form to OCR?

40. MONITORING CHECKLIST – FEDERAL CIVIL RIGHTS cont’d • Non-Discrimination Policies and Procedures • How does your agency notify program beneficiaries that it will not discriminate in the delivery of services (e.g. posters, inclusion in brochures, or other program materials)? • How does your agency notify employees that it will not discriminate in employment (e.g. posters, dissemination of relevant orders or policies, inclusion in recruitment materials)? • Does your agency have written policies and procedures informing program beneficiaries and employees how to file a complaint if they feel like they’ve been discriminated against? • Has your agency designated a person(s) to coordinate complaints of discrimination? • Forwarding of Findings of Discrimination • Does your agency have court findings of discrimination within the contract period? • If so, has your agency compiled with the requirement to forward findings of discrimination to DPS, if applicable?

41. MONITORING CHECKLIST – FEDERAL CIVIL RIGHTS cont’d • Access to services for LEP individuals • How does your agency make meaningful access to persons with limited English proficiency (e.g. direct foreign language communication by fluent bilingual staff, interpretation conducted in-person or via telephone by qualified interpreters, translation by qualified translators, resources for hearing impaired individuals, etc.)? • Does your agency have written policies or procedures on LEP services? • Civil Rights Training • Does your agency provide civil rights training to its employees (e.g. cultural diversity, racial profiling, sexual harassment, etc.)? • How often does your agency provide civil rights training to its employees (e.g. video and/or trainer; at the time of hire, annually, bi-annually, etc)?

42. MONITORING CHECKLIST – STATE CIVIL RIGHTS • Section 213.055 RSMo – Unlawful Employment Practices For example: • Does your organization’s job announcements/applications include an “Equal Opportunity Employer” statement? • Does your organization display the required labor law posters? • Does your organization maintain a written policy on non-discrimination and/or non-harassment in the workplace? • Does your organization maintain a written policy to notify employees on how to file complaints alleging discrimination? • Section 213.065 RSMo – Discrimination in Public Accommodations For example: • Does your organization display the required labor law posters (e.g. Discrimination in Housing and Discrimination in Accommodations)? • Does your organization notify its citizens or program participants that it will not discriminate in the delivery of its services (e.g. brochures, posters, website, mission statement)? • Does your organization ensure its facilities are ADA accessible? • Does your organization maintain a written policy on ADA? • Does your organization maintain a written policy to notify employees and/or citizens on how to file complaints alleging discrimination in public accommodations?

43. WEBGRANTShttps://www.dpsgrants.dps.mo.gov

44. WEBGRANTS HOME SCREEN DEMO SCREENSHOT Returning Users or Organizations: enter UserID and Password For New Organizations only!

45. WEBGRANTS - MAIN MENU DEMO SCREENSHOT • Grantee Instructions: general instructions and navigational aids • My Profile: maintain contact information, reset password, & add users • Funding Opportunities: displays posted program funding opportunities • My Applications: displays previously created applications for the user’s organization • My Grants: displays awarded grants for a user’s organization

46. ‘MY PROFILE’ MODULE • Maintain profile and contact information • Maintain organization’s information • Do not change the Applicant Agency name though • Add additional registered users • Add only if individual is not already a registered user • Notify DPS to add if individual is already a user associated with a different grant • Notify DPS via the “Correspondence” component of WebGrants if you add a new individual; must use the Change of Information Form • Remove registered users • Notify DPS via the “Correspondence” component of WebGrants if you need an individual removed; must use the Change of Information Form • Do not delete a registered user yourself; the individual is not automatically removed from the General Information form as a grantee contact or from the Distribution List

47. CLARIFICATION OF ALERTS & NOTIFICATIONS • Two types of notifications: • Automated alerts triggered on application and grant phases (e.g. status change, submission, negotiation, approval, not approved) • Mass distribution list emails from DPS staff (e.g. reminders, updates, training notices) • Alerts/Notifications are sent from dpswebgrants@dps.mo.gov • Add to safe sender list or a contact list to avoid being treated as junk/spam • Do not overlook these alerts as they can contain important and time-sensitive information • While the record is in the “My Applications” module, only the Primary Contact receives system-generated alerts • While the record is in the “My Grants” module, the Primary Contact and Additional Grantee Contacts, as applicable, receive system-generated alerts

48. STATUS OVERVIEW My Applications: • Submitted – application has been submitted by the grantee • Under Review – application has been assigned for review • Correcting – application is being edited by the grantee • Approved – application has been approved, following any necessary revisions by the grantee • Awarded – award of contract documents being signed by grantee and grantor My Applications – Archived Applications: • Editing – application was initiated but never submitted prior to the close of the funding opportunity • Withdrawn – application has been withdrawn from consideration by the grantor (upon request) or grantee My Grants: • Underway – application officially becomes a grant • Suspended – grant has been “frozen” due to delinquent reporting and/or inappropriate activities My Grants – Closed Grants: • Closed – grant has been closed by grantor

49. LLEBG GRANT COMPONENTS • General Information • Contact Information • Correspondence • Budget • Contract Adjustments • Contract Adjustment Notices • Status Reports • Site Visits • Award Documents – Need Signatures • Award Documents – Final • Attachments • Closeout • Opportunity • Application DEMO SCREENSHOT

50. COMPONENT #1: GENERAL INFORMATION DEMO SCREENSHOT