Please review the information below regarding required grants financial management training, cash management procedures, and whistleblower protections that are applicable to Office of Justice Programs’ (OJP) award recipients. If you believe that your organization may not be in compliance with any or all of these requirements, please take the steps indicated below and/or contact your OJP grant manager with any questions.
Required Training for the Award Point of Contact and All Financial Points of Contact
All awards made by OJP in FY 2016 and later have a special condition requiring the Point of Contact (POC) and all Financial Points of Contact (FPOCs) in your organization to successfully complete an “OJP financial management and grant administration training.” Please check your organization’s compliance with this award condition and, if applicable, have the POC and all FPOCs complete the training as soon as possible. The training may be completed in person or online. Additional information about OJP’s financial management and grant administration training is available at https://www.ojp.gov/training/fmts.htm. An award recipient’s failure to comply with this condition may result in OJP immediately proceeding to withhold (“freeze”) award funds.
The text of the award condition is as follows:
Both the Point of Contact (POC) and all Financial Points of Contact (FPOCs) for this award must have successfully completed an “OJP financial management and grant administration training” by 120 days after the date of the recipient’s acceptance of the award. Successful completion of such a training on or after January 1, 2015, will satisfy this condition.
In the event that either the POC or an FPOC for this award changes during the period of performance, the new POC or FPOC must have successfully completed an “OJP financial management and grant administration training” by 120 calendar days after — (1) the date of OJP’s approval of the “Change Grantee Contact” GAN (in the case of a new POC), or (2) the date the POC enters information on the new FPOC in GMS (in the case of a new FPOC). Successful completion of such a training on or after January 1, 2015, will satisfy this condition.
A list of OJP trainings that OJP will consider “OJP financial management and grant administration training” for purposes of this condition is available at https://www.ojp.gov/training/fmts.htm. All trainings that satisfy this condition include a session on grant fraud prevention and detection.
The recipient should anticipate that OJP will immediately withhold (“freeze”) award funds if the recipient fails to comply with this condition. The recipient’s failure to comply also may lead OJP to impose additional appropriate conditions on this award.
Cash Management for Subrecipients
Recent Office of the Inspector General audits and OJP monitoring visits have found instances where prime award recipients have not required subrecipients to manage their cash drawdowns in accordance with the cash management guidance contained in the 2015 DOJ Grants Financial Guide. Where the conduct of a program or one of its components is delegated to a subrecipient, the direct recipient remains responsible for all aspects of the program including proper accounting and financial recordkeeping by the subrecipient. The award recipient is responsible for the accounting of receipts and expenditures, cash management, maintenance of adequate financial records, and refunding of expenditures disallowed by audits. Award recipients should establish reasonable procedures to ensure the receipt of reports on subrecipients’ cash balances and cash disbursements in sufficient time to enable them to prepare and submit complete and accurate financial reports to OJP.
An adequate financial system requires procedures for minimizing the time between the transfer of funds from the U.S. Department of the Treasury and disbursement by recipients and subrecipients whenever advance payment procedures are used. Also, when advances are made by electronic funds transfer (EFT), your system should help you as the award recipient to make drawdowns as close as possible to the time of making disbursements. Funds must be used within 10 calendar days of the date drawn for allowable expenditures, or they must be returned to OJP. A prime recipient’s financial management policies should include monitoring of cash drawdowns by subrecipients to ensure that they conform substantially to the same standards of timing and amount as apply to advances to the direct recipient.
Fund requests from subrecipients create a continuing cash demand on award balances of the award recipient. Award recipients should keep in mind that idle funds in the hands of subrecipients will impair the goals of effective cash management.
Recipients of OJP grants and cooperative agreements (and any subrecipients at any tier) must comply with, and are subject to, all applicable provisions of 41 U.S.C. 4712, including all applicable provisions that prohibit, under specified circumstances, discrimination against an employee of an OJP recipient by the OJP recipient as reprisal for the employee’s disclosure of information related to gross mismanagement of a federal grant, a gross waste of federal funds, an abuse of authority relating to a federal grant, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a federal grant.
Recipients of OJP grants and cooperative agreements (and any subrecipients at any tier) must inform their employees, in writing (and in the predominant native language of the workforce), of employee rights and remedies under 41 U.S.C. 4712. Potential fraud, waste, abuse, or misconduct involving or relating to funds under the OJP award should be reported to the Office of the Inspector General by– (1) mail directed to: Office of the Inspector General, U.S. Department of Justice, Investigations Division, 950 Pennsylvania Avenue, N.W. Room 4706, Washington, DC 20530; (2) e-mail to: email@example.com; and/or (3) the DOJ OIG hotline: (contact information in English and Spanish) at (800) 869-4499 (phone) or (202) 616-9881 (fax). Additional information is available from the DOJ OIG website at https://www.usdoj.gov/oig and in the DOJ Whistleblower Information document; Department of Justice Whistleblower Information for Contractors, Subcontractors and Grantees.
Thank you for your attention to these important requirements. As a reminder, financial management and other grant administration requirements are available for reference in the DOJ Grants Financial Guide https://ojp.gov/financialguide/doj/index.htm and in your award document. If you have any questions, please contact your OJP grant manager.