Please review the information below regarding required 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 either of these requirements, please take the steps indicated below and/or contact your OJP grant manager with any questions.
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 grant manager.