Report CopyRight/DMCA Form For : Office Of Criminal Justice Programs
OFFICE OF CRIMINALJUSTICE PROGRAMSOCJP Fiscal Training August 31 2018 Allowable CostsSee Chapter XIV of OCJP Grants Manual and Fund Source Chapters. Consistent with organization polices and procedures Must be approved in the budget Must follow federal fund source guidelines Consistent treatment of similar costs Follow generally accepted accounting principles. Ordinary and necessary for operation Document methodology Must be allowable reasonable and allocableSee Chapter XVII of the OCJP Grants Manual Agencies can move money within approved budget lines utilizing.the 20 Rule does not require prior approval unless it s a priorapproval item like personnel and indirect costs The 20 must be calculated on both the to and from line Once a line is increased by 20 it cannot be increased again If a line does not already have funding a zero dollar line it.cannot have money moved to it Line item changes include only items that are currently in theagency s approved budget 20 rule does not apply to the in kind line 20 Rule Example.Example There is 200 in the budget s travel line itemand you want to move more money into the travel line item The maximum amount that can be moved into thetravel line item is 40 for the entire fiscal year 200 x20 40 A separate approved line item s must be.reduced by the corresponding 40 and the reducedamount cannot exceed 20 of that line item NOTE Do not change column A of the OCJPInvoice for Reimbursement Form Prior Approval.See Chapters XIV XV XVII of the OCJP Grants ManualThe following budget items must be pre approved prior to beingimplemented by the subrecipient 1 Salary adjustments including grant funded staff percentages and salarychanges Funds may not be moved into or out of the Salaries Benefits Taxes.line without prior approval2 Overtime3 Staffing Changes if a position is added or deleted from the budget4 Capital Purchases5 Depreciation must include a depreciation schedule.6 Sensitive Minor Equipment see Chapter X Property and Equipment of theOCJP Administrative Manual for further details7 Furniture8 Clothing and or Uniforms Exception Emergency clothing for victims clients doesnot require prior approval .9 Meeting room audio visual services10 Indirect Costs Funds may not be moved into or out of Indirect Costs withoutprior approval The request must be accompanied by a copy of the agency sapproved indirect cost rate or approved cost allocation plan which includes anindirect rate should have approval letter from cognizant agency . Budget AmendmentsSee Chapter XVIII of the OCJP Grants Manual A budget amendment is necessary anytime the total federalfunding amount of a grant contract is increased or decreasedand or if movement of funds between budget line items is.greater than 20 of the line item amount The subrecipientmust secure prior written approval from OCJP for all contractbudget amendments The written request must be accompaniedby amendment detail and summary budget pages and anyrelated documentation supporting the change Budget.amendments will be considered on a case by case basis Unallowable CostsSee Chapter XIV Fund Source Chapters of the OCJP Grants Manual Construction Land Acquisition. Supplanting Compensation and or travel of federal employees Bonuses or Commissions Military Type Equipment Lobbying. Fundraising Corporate Formation State and Local Taxes Certain Conference Meeting and Training Expenses Unallowable.Conference Meeting Training1 Entertainment4 Passport Charges6 Bar Charges Alcoholic Beverages7 Laundry Charges.8 Lodging costs in excess of Federal per diem For events of 30 or moreparticipants that are funded with an OCJP award if lodging costs exceed theFederal per diem none of the lodging costs are allowable effective January9 Food and beverage costs are rarely allowable 10 Gifts Trinkets Memorabilia ... Items.Trinkets items such as hats mugs portfolios t shirts coins gift bags etc regardless of whether they include the conference name or OJP DOJ or OCJPlogo must not be purchased with DOJ or OCJP funds as giveaways forconferences Basic supplies that are necessary for use during the conference e g folders name tags may be purchased 8. Other Unallowable Expenses1 Legal fees2 Cost in applying for this grant3 Any expenses prior to the grant award date4 First Class Travel.5 Management and administrative training6 Sole source contracts without the prior written approval from the Officeof Criminal Justice Programs 7 Depreciation or a use allowance on idle or excess facilities 8 Cost incurred outside the project period Any costs that are incurred.either before the start of the project period or after the expiration of theproject period are not allowable 9 Severance packages the compensation that an employer provides toan employee who has been laid off whose job has been eliminated who through mutual agreement has decided to leave the company or.who has parted ways with the company for other reasons 10 Interest11 Credit Card Fees12 Membership fees to organizations whose primary activity is lobbying Audit Threshold.See Chapter V of the OCJP Grants Manual Nongovernmental agencies who expend at least 750 000 under astate contract which establishes a subrecipient relationship whichmay include federal pass through awards during a year arerequired to have an audit not just audited financial statements . Audit costs not performed in accordance with the appropriateOMB Circular are unallowable If the subrecipient expendedFederal funds less than the amount required for an audit and stillelected to contract with a certified public accountant to performan audit these costs may not be charged to the federal grant s . If an agency meets the audit threshold and is required to have anaudit prorated audit costs would be considered an allowable cost The total cost of the audit would need to be allocated across fundsources using a fair and equitable method 10 Supplanting.See Chapter XV of the OCJP Grants Manual Federal funds must be used to supplement existing State andlocal funds for program activities and must not supplant thosefunds that have been appropriated for the same purpose If reviewers think that supplanting may have occurred then the.applicant or recipient will be required to supply documentationdemonstrating that the reduction in non Federal resourcesoccurred for reasons other than the receipt or expected receiptof Federal funds For certain programs a written certification may be requested.by the awarding agency or recipient agency stating that Federalfunds will not be used to supplant State or local funds Supplanting Example To help clarify the difference betweensupplementing and supplanting we provide the.following example State funds are appropriated to hire 50 new policeofficers and Federal funds are awarded for hiring 60new police officers At the end of the year the Statehas hired 60 new police officers and the Federal.funds have been exhausted The State has not usedits funds towards hiring new officers but insteadreduced its appropriation for that purpose andassigned or appropriated the funds to anotherpurpose In this case the State has supplanted its.appropriation with the Federal funds If supplantinghad not occurred 110 new officers would have beenhired using Federal funds for 60 officers and State Supplanting cont Keys to avoiding a supplanting violation . 1 Hire or purchase only new additional personnel orequipment technology and or other approved costs 2 Pay only for personnel hired equipmentpurchased and or other approved costs incurred onor after the award start date and. 3 Make sure the grant funded purchases or hires areover and above the number of positions equipment and or other approved costs that otherwise wouldhave been funded by the granteeSee Chapter III of the OCJP Grants Manual. Match can be cash or in kind Match is restricted to the same use of funds as allowed for the Federal funds Match must be directly related to the project goals and objectives and mustbe documented in the same manner as grant funded activities Match cannot be from another federal source . Cash match is budgeted in the line in which it is expended not in the inkind line For example if the cash match was used for supplies it should bereported on that line of the reimbursement invoice if it was used for specificassistance it is budgeted in that line and so on Cash match must be documented verifiable and used for allowable costs . Cash match must be reported on the reimbursement invoice In Kind Match Examples Donations of expendable equipment supplies space valueof time contributed by volunteers if the services they provide are anintegral and necessary part of a funded project. Cannot be counted as match until it is used in the project for example goods given to a client Value placed on donated labor must be consistent with rate ofcompensation for similar work and must be documented in the samemanner as paid staff signed time sheets . Value placed on donated space must be consistent with fair marketvalue and documented at least 3 comps from Realtors use average Only space that is 100 donated will be considered for match purposes Document methodology for value placed on donated goods Goodwill In Kind Match Test. Agencies with in kind match can only draw down in kind inrelation to direct expenses In other words you can notovermatch For example if your YTD direct expenses are at 85 of the amount budgeted and your in kind is at 100 then youhave overmatched Each reimbursement invoice has an in kind.match test above the signature line If this number is negative it means you have overmatched This number cannot benegative on the final reimbursement invoice It notes on the Mayinvoice that the number cannot be negative the next month Below is how this appears on the May reimbursement invoice . As you can see here the number is negative so the agency hasovermatched by 12 081 53 and must bring that to zero on theJune invoice or the State will reduce the June invoice by thisamount 16 Purchasing Policies. All non federal entities were required to be in compliance withthe Uniform Guidance purchasing policies by FY18 Code of Conduct and purchasing guidelines begin with CFR Highlights include Code of Conduct 2 CFR sections 200 318 c 1 and 400 2 Develop a.code of conduct that addresses conflicts of interest Gratuities Favors or Gifts 2 CFR sections 200 318 c 1 and 400 2 Include a prohibition on soliciting or accepting gratuities favors oranything of monetary value from contractors potential contractors orparties to sub agreements . Suspension and Debarment 2 CFR Appendix II Section H Includeinstructions that disallow entering into a contract with parties that havebeen debarred or suspended and how staff make that determination Small and Minority Businesses Women Business Enterprises and LaborSurplus Area Firms 2 CFR Section 200 321 Describe the affirmative.process to ensure that minority businesses women businessenterprises and labor surplus area firms are used when possible 17 Purchasing Highlights continued Micropurchase Procedures 2 CFR Section 200 320 a Describe the process for procuring goods and or services.when the dollar amount does not exceed 3 500 perprocurement transaction Only required if you choose touse micropurchase Small Purchase Procedures 2 CFR Section 200 320 b Describe the process for procuring goods and or services.when the total dollar amount is less than your agency srelevant small purchase threshold per procurementtransaction Formal Purchase Procedures 2 CFR Section 200 320 c and d Describe the process for procuring goods and or services.when the dollar amount is more than your agency s relevantsmall purchase threshold per procurement transaction Noncompetitive Procurement 2 CFR Section 200 320 f Describe the process for procuring goods and or services thatcannot be conducted through normal competitive 18.procurement methods including emergency or sole source Purchasing Highlights Continued Cost and Price Analysis 2 CFR Section 200 323 Describethe process for performing a cost or price analysis for everyprocurement action in excess of the small purchase threshold. phone bids 3 quotes etc Clear Description 2 CFR Section 200 319 c 1 Describestaff requirements and required components for writing aclear description of the material product or service to be.Sole source contracts (without the prior written approval from the Office of Criminal Justice Programs) Depreciation or a use allowance on idle or excess facilities. Cost incurred outside the project period. Any costs that are incurred either before the start of the project period or after the expiration of the project period are not allowable.