27
Project Safe Neighborhood FY19 New Grantee Webinar Stephen Fender, BJA Programs Office Kate McNamee, BJA Policy Office
Project Safe Neighborhood FY19 New Grantee Webinar
Stephen Fender, BJA Programs OfficeKate McNamee, BJA Policy Office
Webinar Overview
• FY 19 PSN Grant Program Changes• Subaward Competition • 1373• Gang Set-Aside• Grant Action Plan
• Funding Considerations• Reporting Requirements• Subrecipient Requirements
2
2019 Grant Program Changes
3
Competition Requirements
• Competition of subawards not required for FY 2019.
• Use of federal funds for contract services still requires competition.
• All subawards still require BJA approval before funds can be obligated and/or subawards can be made.
4
Subaward Approval• BJA will need three things in order to approve subawards:
• A) DHS/ICE Responses: Each subaward applicant needs to provide responses in a yes/no format to the questions outlined in the solicitation.
• B) Letter of Subaward Information: Letter on official letterhead with the following information on each of your subawards:
• Legal name • Award amount • Project summary (a short paragraph) of how funds will be used
• C) Budget: Detailed information on how funds will be used, in order to ensure that they are allowable costs under the PSN program.
5
1373 Requirements • No Chief Legal Officer form required this year.
• Those requirements remain but are confirmed using the award documents.
• Communication with DHS and/or ICE questions still required for primary and all tiers of subawards.
• 1373 review of all subawards still required before funds released.
6
Gang Set-Aside Requirement
• Authorizing Language Requirement: • “Thirty percent of the amounts made available as
grants under the Program each fiscal year shall be granted to Gang Task Forces in regions experiencing a significant or increased presence of criminal or transnational organizations engaging in high levels of violent crime, firearms offenses, human trafficking, and drug trafficking.”
7
Gang Task Force Defined:• Any coordinated effort involving more than one federal, state,
local, or tribal law enforcement agency to collaboratively investigate and prosecute criminal and/or transnational organizations that are committing the crimes listed in the PSN Authorization Act (high levels of violent crime, firearms offenses, human trafficking, and drug trafficking)
• A task force does not need to be led by or include participation of a federal agency; a task force composed entirely of state, local, and/or tribal agencies can qualify. If a federal agency is involved, that agency cannot receive grant funds.
8
Gang Task Force Defined:• The collaborative, coordinated effort does not need
to be officially designated a “Gang Task Force,” so long as it is focused on the investigation and prosecution of criminal and/or transnational organizations engaging in the categories of offenses outlined in the Act.
• Both pre-existing and newly created “Gang Task Forces” may qualify for the 30% set-aside funds under the Act.
9
Do the 30% set-aside funds have to be used specifically for anti-gang activities?
• No, the 30% set-aside funds must be used for collaborative, coordinated law enforcement efforts focused on criminal and/or transnational organizations, including but not limited to gangs, that are engaged in high levels of violent crime, firearms offenses, human trafficking, and drug trafficking.
10
Do the 30% set-aside funds have to be used specifically for enforcement activities?
• No. The 30% set-aside funds may be used for non-enforcement activities, such as outreach, prevention, and reentry programs, so long as the funds are used to address criminal and/or transnational organizations that are committing the categories of offenses outlined in the Act.
11
For purposes of the 30% set-aside, what is a “criminal organization”?
• For this purpose, a “criminal organization” is a group of two or more individuals that exists for a period of time and that acts in concert with the aim of committing any of the categories of offenses outlined in the PSN Authorization Act, whether successful or not.
12
For the purposes of the 30% set-aside, what is a “transnational organization”?
• For this purpose, a “transnational organization” is a group of two or more individuals, one or more of whom is a citizen of a foreign country, that exists for a period of time and that acts in concert with the aim of committing any of the categories of offenses outlined in the PSN Authorization Act, whether successful or not.
13
Budgeting • The 30% should be calculated after the 10%
administrative costs are removed from the total. • For example:
• If your award is $100k, subtract 10% = $90k and calculate the 30% from that amount = $27k.
• These costs can be supported using an indirect cost agreement, but that is not mandatory.
• Indirect cost rates must be approved.
14
Grant Action Plan (GAP)
15
GAP Process• Revised, streamlined process for 2019
• Replaces the Strategic Action Plan (SAP) previously required.
• PSN Coordinator in partnership with PSN Task Force contributes to content of the GAP, which is completed and submitted to BJA online by fiscal agent as a grant administration responsibility.
• Meant to capture same information for all PSN districts, as program narratives vary widely.
• Intended to uniformly document 30% gang set-aside.
16
Grant Action Plan (GAP) Goals• Provide BJA information about the planned use of
the PSN funding.• Support effective implementation and sustainment
of strategies.• Get partners from a variety of organizations on the
same page.• Flag Training and Technical Assistance needs.• Establish processes and assign responsibilities.• Support the development of a logic model,
performance metrics, and evaluation plan.17
GAP Process
• GAPs reviewed by BJA and PSN TTA Team.• If necessary, feedback provided to fiscal agent for
GAP revision.• Once GAP is approved, send subawards list to BJA for
approval.• Once approved, any changes to plan presented in
GAP need to be reviewed and approved by BJA.
18
Funding Considerations• Must reserve funds in budget to support three non-
federal members of the PSN task force’s participation in the upcoming 2020 PSN National Conference.
• Funding decisions should be made by non-federal, non-conflicted task force members with clear documentation of the decisions and task force participants.
• Project periods are up to three years.
19
Selection CommitteeFunding decisions should be made by a group of PSN partners, who should meet the following criteria:Do not play a role in the production of all or part of
any subaward application.Are not employed by the federal government. Are not employed by a subaward applicant.Are otherwise non-conflicted.
20
Allowable Costs 2019 PSNAllowable uses of funding include:
• Salary, wage, and fringe benefits of individuals supporting the PSN project
• Overtime compensation of individuals supporting the PSN project• Workshops and events associated with the support of the PSN
project (pending approval by OJP/BJA)• Travel associated with implementation and evaluation of the PSN
project• Equipment purchased to support the execution of the PSN project• Printing, publication, and duplication of materials that support the
PSN project• Administrative costs (up to 10 percent of the award) incurred by the
fiscal agentNo grant funds can be used to purchase food as this is a prohibited expense.
21
Reporting Requirements
Report Purpose Completed in: Submitted in: Report Due Date
Progress Report
• To identify your (grantee) successes and potential areas of improvement.
• To help us (BJA/DOJ) understand your (grantee) activity and progress
• To help us (BJA/DOJ) understand what funds are being used for
PerformanceManagement Tool
System (PMT)
Grant Management
System (GMS)
The PMT includes performance
measures (completed and
submittedquarterly in PMT)
and narrative questions
(submitted in GMSsemiannually).
Financial Status Report (FSR)
PSN grantees are required to report their financial activity for the previous 3 months of their award.
Grant Management System (GMS)
Grant Management
System (GMS)
The FSRs are due quarterly.
Important Note: Progress Report and Financial Status Report due dates are fixed and cannot be adjusted. Late reports submitted (after the grace period) into GMS will automatically result in a Withhold of Funds placed on the award, which will be removed once the Progress Report or Financial Status Report is submitted.
Importance of Performance Reporting
23
To identify areas of success and potential areas of improvement Includes system improvements, including internal training and technical
assistance (TTA) and external messaging.
To track activity and progress Informs BJA reviews and decision-making.
To understand how funds are being distributed Informs budget, strategic plan, and future funding. Enables BJA to respond to external requests (e.g., congressional
inquiries, media requests).
To comply with the law Government Performance and Results Modernization Act of 2010
Subrecipient Management and Monitoring Requirements
2 CFR 200.331 requirements for pass-through entities:(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes federal award identification information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.(c) Consider imposing specific subaward conditions upon a subrecipient if appropriate. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.
24
PSN Training and Technical Assistance (TTA)• TTA assists PSN task forces, local and state law
enforcement, criminal justice agencies, and communities with planning, implementing, and assessing their violence reduction PSN strategies.
• TTA can be provided in a variety of different formats. PSN sites also have access to national training and networking opportunities.
• For additional information, visit https://psntta.org/or attend the December 11 webinar on Building and Enhancing PSN Partnerships and Strategies.
25
Questions?
27
