The BJA Grant Writing and Management Academy
Managing Your BJA Funds

Introduction

Being successful as a grant recipient takes more than an idea and a funding source. It takes an organization that is well-managed and able to be a proper steward of public funds.

Project managers often wear many hats. Management responsibilities include fiscal affairs, the programmatic and project implementation aspects of the grant, and administrative and reporting requirements. Some of these responsibilities can be delegated, but ultimately the project manager is responsible for overseeing all areas of the project. It is critical to read the fine print at all stages of the process, paying close attention to details and understanding that full compliance is the grantee’s responsibility. Failure or lack of follow-through in any of these areas can result in time spent explaining actions—or lack of action—instead of implementing the project.

Proper oversight and management of the grant will help ensure that public resources are properly used and produce the best results for BJA and the grant recipient. 

Process

Once the grantee has been notified of its award, there are several key steps to be taken.

In addition to the required steps, here are some suggestions to help your project get off on the right foot.

Again, after being notified of an award, a grantee must take the following steps:

In addition to the required steps, it is recommended that the grantee:

Compliance Management

Conditions and Rules

Compliance requirements are outlined at the time of application and again when the grant is awarded. There are Assurances, Certifications, and Special Conditions that must be agreed to before funding is accepted. The grantee is required to monitor compliance throughout the life of the project to ensure that all requirements are being met.

Compliance requirements are mandatory for both the grantee and any subrecipients or contractors who do business with the direct grant recipient. Therefore, it is critical to educate them about these requirements and provide adequate oversight to ensure that they are also in compliance. Remember, some of the Assurances and Certifications made at the time of application will have relevance throughout the life of your grant.

Reporting

The primary requirement to ensure grant compliance is reporting. There are two types of reporting each grantee is required to undertake: programmatic and financial. The reporting requirements will be outlined in the special conditions and can be different for each program. For each quarter the grant is active, a financial report has to be filed even if there is no activity or expenditure. The OJP Financial Guide governs all financial transactions and reporting. All financial reports are submitted online through GMS.

Expenditures and obligations are reported on the Federal Financial Report, Standard Form 425. This report reflects the cumulative actual federal monies and unliquidated obligations incurred, local matching contributions, and the unobligated balance of federal funds. Each report is due within 30 calendar days of the end of the calendar quarter. It does not matter when the award was received—this is when the reports are due even if the report reflects no obligations or expenditures. If an award was received on March 25th, a report is required for the six-day period ending on March 31st. The financial report reflects the obligations and expenditures in a cumulative fashion for that reporting period and since the beginning of the grant.

Programmatic progress reports are used to monitor grant progress towards meeting goals and objectives of the program. As snapshots of grant activity consisting of performance measures and narrative questions, they are used to report activities conducted during a specified reporting period. These reports should include:

BJA is currently migrating programmatic performance reporting to an online data tool called the Performance Measurement Tool (PMT). The type of program funded will determine whether performance measures are submitted through the PMT and then uploaded into GMS or submitted directly into GMS.

To capture even more valuable and pertinent information on a consistent basis, BJA has added seven new questions to the Progress Report template in the Grants Management System (GMS) Performance Metrics section. The new questions, which always appear as the first seven, will not only provide BJA with sufficient information to monitor grant implementation and goal achievement but also will highlight innovative programs and capture information essential to BJA’s mission.

  1. What were your accomplishments within this reporting period?

  2. What goals were accomplished, as they relate to your grant application?

  3. What problems or barriers did you encounter, if any, within the reporting period that prevented you from reaching your goals or milestones?

  4. Is there any assistance that BJA can provide to address any problems/barriers identified in question #3 above?

  5. Are you on track to fiscally and programmatically complete your program as outlined in your grant application?

  6. What major activities are planned for the next 6 months?

  7. Based on your knowledge of the criminal justice field, are there any innovative programs or accomplishments that you would like to share with BJA?

All questions (narrative and numeric) in the Performance Metrics section must be answered in the fields provided. Please do not answer the questions in another section or attachment. In addition, there may be specific data or statistical information collected during the reporting period that will need to be included. Some questions may require a numerical answer; please provide the number only in the field. Any supporting text can be provided as an attachment or in the narrative field. If a question does not apply to the program, grantees should answer with the number 0 and explain in the Narrative section. Activities should be reported only for the BJA grant under which they were funded and within the specified reporting period.

BJA requires that all progress reports be submitted within 30 days after the end of the reporting period. Failure to submit financial and programmatic progress reports on time could result in the freezing of grant funds or future high-risk designation.

In addition to the existing reporting requirements, grantees receiving American Recovery and Reinvestment Act (or ARRA) funding must submit quarterly according to Section 1512c of the ARRA. Both financial and programmatic data for the specified reporting period is submitted at www.federalreporting.gov. ARRA reports are due within 10 calendar days for the specified reporting period.

Remember, submission of programmatic and financial reports is critical to the success and compliance of your grant-funded project. Be sure to examine and understand the reporting requirements outlined in the special conditions of your grant, since they can be different for each program.

Compliance Responsibilities

During the life of the grant, changes or updates to administrative information, project activities, or the project budget may need to be made. All grant adjustment requests should be made in writing and submitted electronically though GMS and approved by BJA. BJA will then issue a grant adjustment notice (GAN), which will document the funding agency’s approval of the changes made from the original application.

Some circumstances requiring a grant adjustment include:

Not following proper grant management procedures may have a negative impact on the grantee. During the grant period, there should be frequent communication with the funding agency. There are four sanctions for noncompliance that can be used in whole or in part: temporary withholding of payment, disallowing cost of activity or action that is found to be in noncompliance, suspending or terminating the current award, and withholding future awards through suspension or disbarment.

Closeout

Once all grant activities have been completed or the grant has expired, it must be officially closed out. The grantee should provide the following documentation:

Final reports are due no later than 90 days after the grant end date and should cover the cumulative activities and expenditures of your project.

Be sure to provide any products produced by the project to the funding agency, such as publications, training curricula, etc.

The OCFO will review the final financial status report and advise the grantee if there are unobligated funds that need to be returned for deobligation. The grant cannot close until all final reports are submitted and all unobligated funds are returned.

Records should be retained for three years after closeout. If the grant is subjected to an audit, records should be retained for three years after the successful conclusion of that audit. Some state laws may require records to be maintained longer.

Fiscal Management

Grantee Responsibilities

In accepting any type of grant funds, the grantee has a responsibility to establish and maintain a fiscal management system that ensures fiscal integrity in the project. Fiscal integrity can be the lifeblood of successful grant management and project implementation. The grantee should establish and maintain an adequate accounting system and appropriate fiscal controls and records, ensure compliance with all the applicable laws and regulations regarding use of the funds, and conduct its activities in a manner that is transparent and provides accountability. The fiscal agent is responsible for ensuring adequate oversight and monitoring is provided for the grantee and any subrecipients.

Availability of Funds

Grant funds can be obligated as of the start date of the grant period, provided the budget has been approved. The obligation of funds, including all program income, must end on the last day of the grant period. The grantee will have 90 days from the end date of the grant period to pay or liquidate any outstanding obligations incurred during the grant period. There are exceptions to this rule, so review the project’s rules closely. In addition, a grantee may request a no-cost grant extension to allow for completion of grant activities and expenditure of any unspent funds. The request for an extension should be made via a GAN through GMS along with a letter of request stating the need at least 30 days prior to the end of the grant period.

Financial Requirements

The Office of Justice Programs (OJP) Financial Guide, a primary reference manual, provides guidance on management and proper usage of OJP-administered grant funds. It contains the financial rules and regulations all BJA grantees must adhere to and use. Grantees must ensure that all grant management personnel and contractors are familiar with this Guide.

Several of the major requirements are highlighted in this module, including:

Grantees must ensure that personnel and other officials connected with grant-funded projects adhere to the requirements regarding conflict of interest. To avoid conflict of interest, grantees must ensure transparency and fairness in their decision making and project operations.

In addition, grantees must ensure that they operate according to established standards, including but not limited to:

Grantees must use their own procurement procedures and regulations if they are more restrictive than the federal regulations. In the absence of local or state procurement rules, grantees must use the federal regulations. All transactions should be conducted in a manner that provides maximum, open, and free competition. If a contractor participates in the drafting or preparation of a Request for Proposal, that contractor cannot bid on the contract. And sole-source contracts in excess of $100,000 require prior approval from BJA via a GAN.

Allowable costs are those costs identified in the grant program’s authorizing legislation. Costs must be reasonable, allowable, and necessary for the project and must comply with the funding statute requirements. Applicants will need to remove all unallowable costs identified by the funding agency. It is important that you provide adequate supporting documentation for all costs.

Some programs require grantees to “match” their grant funds with either cash or in-kind services or donations or a combination of both. These are resources committed by the grantee to the project. Match funds must be spent, accounted for, and documented in the same manner as regular grant funds. Cash match is the contribution of additional cash to the project. It is normally between 10 percent and 50 percent of the total project cost. In-kind donations are donations of goods or services. The grantee should establish the fair market value for the item or service to determine the value of the donation.

It is uncommon to earn interest on grant funds, since funding typically is distributed throughout the grant period, not up front or all at once. However, there are some exceptions, such as the interest earned on formula block grants. For example, interest earned under a Justice Assistance Grant (or JAG) and a Juvenile Accountability Block Grant (or JABG) must be accounted for and reported as program income.

Program income is income generated as a result of grant-funded activities. Examples include royalties, conference/training registration fees, asset seizures and forfeitures, and interest earned on formula block grants, such as JAG or JABG. The federal portion of program income must be accounted for up to the same ratio of federal participation as funded in the project. Award documents may specify when and how you may use any program income, and this income must be spent and accounted for in the same manner as the original grant funds. To verify, please review the program requirements outlined in the solicitation or contact the grant-funding agency.

Some items or costs may not be approved as part of the budget clearance process and require the grantee to submit a request for approval prior to obligating the funds. Examples of these costs are a sole-source request for equipment or services from a single vendor that exceeds $100,000 or payment of consultants over the maximum $450-per-day federal allowable rate, based on an eight-hour day.

Indirect costs are costs not readily identifiable with a particular grant or costs that cannot be articulated on a direct-charge basis. Indirect costs might include building maintenance, telephone expenses, and depreciation. In order to charge indirect costs, a grantee must have a federally approved rate. The formal negotiation process is undertaken with your federal cognizant agency, which is the federal agency from which your agency receives the most federal dollars.

Confidential funds may be used for the purchase of services, evidence, or specific information from an informant. Normally, confidential funds are associated with a multi-jurisdictional task force or some other law enforcement operation, and the use of such funds in this manner is subject to prior approval. The oversight on confidential funds must be very stringent; it is important to ensure that there is no perception of mismanagement or misuse.

Remember, there are several financial requirements to which each grantee must adhere, regarding items such as:

A complete guide to the financial rules and regulations to which all BJA grantees must adhere is provided by the OJP Financial Guide.

Audits

When an organization-wide threshold of $500,000 is reached for all federal grant funds expended in the organization’s fiscal year, the organization must pay for an audit that can be performed either by state auditors or an independent certified public accountant firm. The audit requirements are covered by OMB Circular A-133. Your organization type dictates the audit’s parameters. The audit report is due nine months after the end of the grantee’s fiscal year. Any findings or questioned costs must be addressed in a corrective action plan submitted by the grantee. Once all issues have been resolved, the audit is closed. An audit is a tool to determine adequacy of administrative oversight. It looks at the allowability of costs, timeliness of report submissions, budget versus actual expenditures, and appropriate documentation. It is a report card. It highlights where the weaknesses are and verifies the accuracy and integrity of the information provided.

The Top 10 Audit Findings, as provided in the OJP Financial Guide, include:

  1. Financial Status Reports not submitted timely;
    (effective October 1, 2009, these are submitted as Federal Financial Report, Standard Form 425)
  2. Accounting procedures need improvement;
  3. Suspension and Debarment Certifications not obtained;
  4. Programmatic reporting requirements not met;
  5. Subrecipients not adequately monitored;
  6. Fixed assets not adequately monitored;
  7. Grant management procedures need improvement;
  8. Segregation of duties not adequate;
  9. Cash management procedures need improvement; and
  10. Procurement procedures need improvement.

Audit requirements are applicable to subrecipients as well. Failure to comply with audit requirements may result in the withholding of new awards and/or the withholding of funds or change in the method of payment on active awards.

Project Management

Project management relates to the operational issues of the project. Project management typically focuses on implementation, risk, monitoring, and assessment.

Managing implementation is focused on project activities. This entails making sure that activities are completed in the time frames in which any deliverables are being produced and that progress is being made in achieving project goals and objectives. One of the most challenging aspects of project implementation is ensuring that activities are carried out as proposed and deadlines are met. The time and task plan should be used to help track progress and identify deviations from the plan. The plan should be a living document that adjusts over time.

Another aspect of project management is risk management. For some projects, particularly complex multicomponent initiatives, it is wise to conduct an up-front evaluation of risk to a project’s success. This means looking at everything from funding to participation, agency commitment, political climate, and community support to identify potential challenges and barriers to a project’s implementation and overall success. If a grantee assumes that some of these risks will become a reality, it can devise a plan for preventing the risk or mitigating its effects in a timely response. In addition, it is important to create a risk escalation process so that as challenges arise, the project’s management knows when to move issues up the chain of command. Good risk management includes communicating potential and identified risk with key project team members, partners, and community stakeholders who can help create solutions to various project challenges.

Monitoring is the responsibility of both the funding agency and the grantee. The grantee should implement a mechanism to monitor progress: financially, programmatically, and administratively. Do not just spend or give out the money. Talk to people responsible for implementation: How is the project progressing? What progress has been made at project locations? Be proactive about ensuring that the project is doing what it proposed in the application, managing risk, and staying on track. Remember, your grant-funding agency will be monitoring you too.

Grantees should monitor using a variety of methods, such as telephone interviews, desk reviews, and site visits.

Factors for choosing site visits include:

Assessment, like monitoring, is a valuable tool for getting feedback about your project that helps you maximize project effectiveness. During a monitoring visit, the funding agency will work with the grantee to assess the outcome of the project. In some situations, you may encounter indications that project activities are not working as proposed or intended; hence, there may be a need to change the proposed activities, necessitating a request for a grant adjustment notice (or GAN).

Whereas feedback from monitoring is based on observation or review of documents, feedback from assessment is often data-driven. Statistical information can provide valuable insight about the project’s implementation or progress in achieving outcomes. For example, if we anticipate that we will serve 100 offenders in the first year of the project, but only a few offenders have been served after several months of implementation, it is probably necessary or worthwhile to examine why implementation is not proceeding as expected. Similarly, if finding out that the offenders failed to learn new skills provides the opportunity to investigate, corrective action can be taken; this ensures that the project can produce desired outcomes, such as reducing recidivism.

A good management plan will include a sound assessment plan, including the data that will be collected, the specific types of measures that will be used, and the data sources that will be employed. For additional detail about assessment plans, see the Strategic Planning module.

Projects are more likely to succeed if they: