Edward Byrne Memorial Justice Assistance Grant (JAG) Program 2019 Non-DTF Compliance Training

1. Missouri Department of Public Safety Office of the Director Criminal Justice/Law Enforcement Unit Edward Byrne Memorial Justice Assistance Grant (JAG) Program2019 Non-DTF Compliance Training June 18, 2019

2. CJ/LE CONTACT INFORMATION Amelia Hentges, Program Representative P: (573) 522-4094 E: amelia.hentges@dps.mo.gov Alecia Cameron, Program Representative P: (573) 751-5997 E: alecia.cameron@dps.mo.gov Main Phone:(573) 751-4905 Fax Number:(573) 522-1908 Address: MO Department of Public Safety Attn: CJ/LE Unit PO Box 749 1101 Riverside Drive Jefferson City, MO 65102

3. 2019 DPS “INTERNAL CONTACT” Unless noted otherwise, all grant reports and correspondence will be reviewed and processed by the designated Internal Contact. All questions and concerns should be directed to the Internal Contact as well! Monitoring will be conducted by the Internal Contact.

4. OUTLINE FOR TRAINING • General Grant Information • Budget Costs • Administrative & Financial Guidelines • Civil Rights Compliance • Reporting Requirements • Monitoring • WebGrants Demo • Questions?

5. GENERAL GRANT INFORMATION

6. BACKGROUND Edward Byrne Memorial Justice Assistance Grant (JAG) • authorized by 34 U.S.C. §§ 10151-10158 • CFDA # 16.738 • awarded to Missouri by the U.S. Department of Justice (DOJ), Office of Justice Programs (OJP), Bureau of Justice Assistance (BJA) • provides federal criminal justice funding • streamlined the Byrne and LLEBG grant programs in federal FY 2015

7. FUNDING Population & Part 1 Crime Allocation Minimum Base Allocation • Calculated by the Bureau of Justice Statistics (BJS) • First, BJS determines a minimum base allocation to be awarded to each U.S. state and territory • Second, BJS calculates an additional allocation for each state and territory based on the state or territory’s share of population and Part 1 crime statistics (as compared to the other states and territories) • Once Missouri’s total is known, BJS next calculates each jurisdiction’s share of population and Part 1 crime statistics (as compared to the state’s) • Jurisdictions calculated as $10,000 or more receive direct awards from BJA (and are thus ineligible to apply for additional funding from Missouri, unless the project is multi-jurisdictional) • The remaining money, including the less than $10,000 shares, are awarded to the MO Department of Public Safety (MO DPS) • MO DPS is required to use the less than $10,000 shares for grants totaling less than $10,000 (funds the LLEBG Program) • MO DPS uses the remaining money to fund other grants under the JAG Program name Missouri Less than $10K Allocations $10K & More Allocations Direct Awards from BJA to Local Unit of Government MO Department of Public Safety JAG (Remaining $) LLEBG (<$10K $)

8. FUNDING cont’d • Things to remember: • The Federal Fiscal Year is October 1 to September 30 whereas the JAG Project Period is July 1 to June 30 • Therefore, 2019 JAG awards will be funded from a combination of FY 2018 federal monies and any balance of monies from prior FY federal awards

9. GENERAL GRANT GUIDELINES • Project Period: July 1, 2019 to June 30, 2020 • No local match • Eligible budget categories: • Personnel • Personnel Benefits • Personnel Overtime • Personnel Overtime Benefits • Travel/Training • Equipment • Supplies/Operations • Contractual

10. SOURCES OF INFORMATION • DPS – CJ/LE Website: https://dps.mo.gov/dir/programs/cjle/ • CJ/LE Grant Calendar • DPS, CJ/LE - JAG Website: https://dps.mo.gov/dir/programs/cjle/jag.php • JAG Fact Sheet • DPS Financial & Administrative Guidelines • Radio Interoperability Guidelines • DPS Subrecipient Travel Guidelines • WebGrants External User Manual • 2019 JAG Non-DTF Solicitation • 2019 JAG Non-DTF Notice of Funding Opportunity Training (and Audio) • 2019 JAG Non-DTF Compliance Training (and Audio) • WebGrants: https://dpsgrants.dps.mo.gov • Opportunity (Funding Opportunity) • 2019 JAG Certified Assurances • 2019 JAG Non-DTF Solicitation • WebGrants External User Manual • Office of Justice Programs (OJP) Financial Guide: http://ojp.gov/financialguide/DOJ/ • Code of Federal Regulation (C.F.R.): https://www.ecfr.gov/ • United States Code (U.S.C.): http://uscode.house.gov/ • Missouri State Statutes: http://www.moga.mo.gov/

11. BUDGET COSTS

12. PERSONNEL COSTS • Personnel costs must be supported with official payroll records and time/attendance reports. • Subrecipient should maintain documents to support all wages and fringe benefits claimed for reimbursement (preferably, but not necessarily, in the grant file). • Timesheets should document all paid hours (including leave, overtime, etc) and should be signed by the employee and authorizing supervisor. • If personnel costs (i.e. overtime) are paid from multiple funding sources, be sure to report grant-funded hours clearly. • Section 285.530.1 RSMo indicates that an agency will not knowingly employ, hire for employment, or continue to employ an unauthorized alien to perform work within the State of Missouri. • Federal law requires every employer hiring an individual for employment in the United States to verify his or her identity and employment authorization through completion of a Form I-9, Employment Eligibility Verification. • https://www.uscis.gov/

13. TRAVEL/TRAINING COSTS • Funds will not be reimbursed prior to the actual travel. • Must submit a copy of the training certificate for travel/training costs to be reimbursed. If a training certificate is not provided, must create a memo. • Should have pre-budgeted for travel expenses based on the location of the travel/training (e.g. airport parking for out-of-state travel by plane). Either: • Submit a budget revision prior to travel if you foresee incurring an expense that isn’t approved in the budget • Don’t claim an expense that isn’t approved in the budget • Some travel costs may be unpredictable – use “Miscellaneous” as a line item for shuttles, taxis, parking, toll bridges, etc. Must be tied to a specific training! • Travel must be by the most practical and direct route! • All costs should be reasonable and prudence should be used when making travel arrangements!

14. TRAVEL/TRAINING COSTS cont’d • Airfare/Baggage budget line • Reimbursable costs include the airline ticket, baggage fees, and travel agency processing fees • Other applicable fees are subject to review • Does not allow for airport parking or transportation to/from the airport • Costs must be supported by a receipt • Rental Car budget line • Reimbursable for the cost of the rental car • Cost must be supported by a receipt • Fuel budget line • Reimbursable for the fuel for a rental car and/or fuel for a vehicle to and from the airport or training location • Costs must be supported by a receipt

15. TRAVEL/TRAINING COSTS cont’d • Mileage budget line • Reimbursable based on the state’s mileage allowance • https://oa.mo.gov/travel-portal • Rate calculated on cost to operate the vehicle based on fuel and wear and tear (cannot request fuel and mileage reimbursement) • standard “state” rate represents cost to own and operate a personal vehicle • “fleet” rate represents average cost of operating a fleet vehicle • Must be supported by documentation (e.g. MapQuest, Google Maps) • does not include any miles involved in a normal commute • Lodging budget line • Reimbursable based on the federal GSA rates as determined for the destination • https://www.gsa.gov/travel/plan-book/per-diem-rates • The GSA rate is for the base nightly rate (not inclusive of taxes) • Where possible should request the hotel to honor the GSA rate since travel is federal funded • Does not allow for hotel parking, room service, internet, telephone calls, maid tips, etc. • Costs must be supported by the hotel statement with a $0.00 balance (confirmation emails are not allowed as they are considered quotes and reservations may be cancelled)

16. TRAVEL/TRAINING COSTS cont’d • Meal budget line • Reimbursable based on the state travel policy adopted by the Missouri Department of Public Safety • State travel policy allows for per diem rate based on the state CONUS rates as determined for the destination and for the particular meal (i.e. breakfast, lunch, or dinner) • Statewide meal per diems are set by region/city. If no city is listed, use the standard (Other) rate, which is the lowest listed. Reimbursement of meal expenses will be based on the location in which the meal expense was incurred. Therefore, the location of meals should be clearly identified. • https://oa.mo.gov/travel-portal • Receipts not required (or requested); still need to maintain some type of record of meals being requested for audit/monitoring purposes (e.g. employee expense report)

17. TRAVEL/TRAINING COSTS cont’d • Meal budget line (cont’d) • State travel policy states travelers may claim the applicable per diem rate for each eligible meal while in travel status. • Travel status begins when the traveler leaves his/her residence or domicile to travel on business. • Travel status ends when the traveler returns to his/her residence or domicile. • The traveler is not in travel status if any part of his/her trip involves a commute. When the traveler’s official domicile and residence are different, the travel status begins and ends based on whichever is less. • However, if the traveler’s residence is less but it is necessary for him/her to travel to his/her domicile before his/her travel status begins, the travel status begins when he/she leaves his/her domicile. • For example, if the traveler lives in Columbia but works in Jefferson City. • If the traveler leaves from Jefferson City to go to Kansas City on business, his/her travel status begins when he/she leaves Jefferson City. • But if the traveler leaves from Columbia to go to Kansas City on business, his/her travel status begins when he/she leaves Columbia.

18. TRAVEL/TRAINING COSTS cont’d • Meal budget line (cont’d) • To qualify for meal per diem when no overnight lodging is indicated, it must be documented that the traveler was in travel status for 12 hours or more. Therefore, time of travel status start and travel status end must be identified on the applicable meal documentation to confirm. • An eligible meal is defined as follows: • When twelve (12) hour travel status or overnight lodging is indicated: • Breakfast is eligible on the day of departure if travel status begins no later than 7:00 a.m. (and a meal cost is incurred). • Lunch is eligible on the day of departure if travel status begins no later than 10:00 a.m. and continues past 2:00 p.m. (and a meal cost is incurred). • Dinner is eligible on the day of departure if travel status begins no later than 5:00 p.m. and continues past 7:00 p.m. (and a meal cost is incurred).

19. TRAVEL/TRAINING COSTS cont’d • Meal budget line (cont’d) • Tips on meals are part of the per diem rate and may not be claimed separately. • When attending a meeting or training, the traveler may claim the applicable meal per diem for those meal times where it is documented that no meal was provided. However, the traveler must be in 12-hour travel status. • Travelers benefitting from a hotel provided meal should not claim that specific meal per diem. If the traveler cannot utilize the meal provided at the hotel, justification should be provided on the applicable meal documentation or within an attached letter or memo for the request of that meal.

20. TRAVEL/TRAINING COSTS cont’d • “Miscellaneous” budget line • Allows for reimbursement of the following types of costs: • Taxi or other ground transportation, including tips for taxis/shuttles (receipt required) • To/from the airport to the hotel • To attend official events outside the hotel • To get a meal outside the hotel • Hotel parking (receipt required) • Airport parking (receipt required) • Street parking (no receipt required but must create a receipt or memo as documentation of the type of expense, amount of expense, date of expense, location of expense, and any other pertinent information) • Toll charges for bridges and turnpikes (receipt required)

21. EQUIPMENT COSTS • Equipment is defined by the State of Missouri as non-expendable personal property having a useful life of more than one year and acquisition cost of $1,000 or more per unit • Subrecipients may use its own definition of equipment provided that the definition would, at a minimum, include the equipment described above • Purchases must adhere to the most restrictive procurement policy • Costs must be supported by a vendor invoice or receipt • Equipment must be tagged and identifiable for its source of funds (e.g. subaward number) • All equipment must be compatible with the current statewide system • Communication devices must adhere to the state’s interoperability plan • The Radio Interoperability Guidelines are available online at https://www.dps.mo.gov/dir/programs/cjle/jag.php

22. SUPPLIES/OPERATIONS COSTS • Includes non-expendable property with an acquisition cost less than $1,000, expendable property, and non-contractual operating costs • Costs must be directly attributable to the approved project • All software must be compatible with the current statewide system • Purchases for goods or services must adhere to the most restrictive procurement policy • Costs must be supported by a vendor invoice or receipt • Printed materials must acknowledge the funding source

23. CONTRACTUAL COSTS • Includes contractual expenses and consultant fees • All contractual and consultant services shall be supported by written contracts stating the services to be performed, rate of compensation, and length of time over which the services will be performed, as applicable • A copy of all written contracts must be made available to DPS staff during site visit monitoring (or upon request) • Purchases for contractual services must adhere to the most restrictive procurement policy • Costs must be supported by a vendor invoice or receipt • Subrecipients should attempt to enter into contracts that occur within the grant’s project period, where possible

24. ADMINISTRATIVE AND FINANCIAL GUIDELINES

25. PROJECT IMPLEMENTATION STATUS • “Operational” = beginning activities in which project-approved costs are being incurred (e.g. employing personnel, attending training, obtaining quotes/bids, etc) • If a project is not operational within 60 days of the project start date, the subrecipient must report to DPS, via the “Correspondence” component of the grant within WebGrants, the steps taken to initiate the project, the reasons for delay, and the expected start date. • If a project is still not operational within 90 days of the project start date, the subrecipient must submit a second statement to DPS, via the “Correspondence” component of the grant within WebGrants, explaining the implementation delay. • Upon receipt of the second statement, DPS may decide whether to continue with the project or to terminate the subaward.

26. FUNDS • Subrecipients must report, on a monthly basis, actual cash expenditures and request reimbursement. • Requests for reimbursement will be handled via a “Claim” report. • Funds must be obligated within the project period and must be expended within 60 days following the project period end date. • Project Period: July 1, 2019 – June 30, 2020 • 60 Days Following: August 29, 2020 • Funds are “obligated” when a legal liability to pay a determinable sum for services or goods is incurred and will require payment during the same or future period. • When a purchase order is issued, funds are considered obligated • Travel expenses will only be allowed for events, training, and other activities held during the project period • Funds are “expended” when payment is made.

27. INTERNAL CONTROLS • Subrecipients must track, account for, and report on all funds separately from all other funds. • Grant funds may be used in conjunction with other funding as necessary to complete projects but tracking and reporting must be separate. • Subrecipients should ensure appropriate internal controls exist for the programmatic and financial aspects of the project. • There should be separation of duties (or layers) when it comes to the approval of timesheets/payroll or purchase approvals and payments. • Procurement/purchasing policies generally outline internal controls, such as the selection, award, and administration of purchases.

28. PROCUREMENT General Grant Guidelines: • All procurement transactions whether negotiated or competitively bid and without regard to dollar value shall be conducted in a manner so as to provide maximum open and free competition. • All quotations and the rationale behind the selection of a source of supply must be retained, attached to the purchase order copy, and placed in the accounting files • When only one bid or positive proposal is received, it is deemed to be sole source procurement. • Sole source procurement on purchases to a single vendor of $3,000 or more requires prior approval from the Missouri Department of Public Safety. • Request for approval shall be submitted via the “Correspondence” component of the grant within WebGrants with the rationale and, if available, a copy of the sole source certification letter from the vendor. • Approval of the grant application does not constitute prior approval; must obtain separately. State Procurement Policy: • Purchases to a single vendor totaling less than $3,000 may be purchased with prudence on the open market. • Purchases to a single vendor totaling $3,000 but less than $25,000 must be competitively bid, but need not be solicited by mail or advertisement. • Purchases to a single vendor totaling $25,000 or over shall be advertised for bid in at least two daily newspapers of general circulation in such places as are most likely to reach prospective bidders at least five days before bids for such purchases are to be opened.

29. ACCOUNTING/FINANCIAL RECORDS • Subrecipients must establish and maintain accurate financial records and an adequate accounting system • Records must be retained for a period of five (5) years starting from the date of completion of the Closeout component of the grant within WebGrants or from the date of submission of the audit for the project period covered, whichever comes later • Records must be retained beyond a five (5) year period if an audit is in progress and/or the findings of a completed audit have not been resolved • Subrecipients must adhere to local policy if local retention period is longer than those stated herein • Records must be kept in an orderly manner and be available for audit purposes to DPS and/or representatives from the government of the State of Missouri • Responsible for protecting records against fire, theft, or other possible damages

30. PROPERTY RECORDS • Subrecipients are required to maintain property management records • Records shall contain copies of the purchase order and invoice • Quotes/bids ideally should also be maintained • Records shall include an inventory control listing for non-expendable property • Item Description • Serial Number or other identification number (e.g. VIN, make, model number, control number) • Source of Property (e.g. GR, JAG Grant), including the subaward number • Identification of the Title Holder • Acquisition Date • Total Cost of the property • Percentage of State and/or Federal participation in the cost of the property • Location, Use, and Condition of property • Disposition Date • Disposition Method (e.g. trash, sale, trade) • Property must be tagged and identifiable for its source of funds, where feasible • “Purchased with 2019 JAG Funds” • Subaward Number (e.g. 2018-JAG-001)

31. PROPERTY RECORDS cont’d • A control system shall be in effect to ensure adequate safeguards to prevent loss, damage, or theft to the property • Any loss, damage, or theft of non-expendable property shall be investigated, fully documented, and made part of the grant file • Subrecipients should take a physical inventory of the property and reconcile the results with the property records at least once every 2 years • Adequate maintenance procedures shall be established by the subrecipient to keep the property in good condition

32. PROPERTY DISPOSITION • Subrecipients are expected to use the approved equipment for the purpose for which it was acquired for as long as needed. • If a JAG-funded project ceases and there is still value in the property, DPS may request such property be made available for re-authorization to another JAG-funded project. • Replacement: Subrecipients may use the equipment to be replaced as a trade-in, or may sell the equipment and use the proceeds to offset the cost of the replacement equipment. • The purchase of replacement property must take place soon enough after the sale of property to show that the sale and the purchase are related. • Disposition: When original or replacement equipment acquired under an award is no longer needed for the original project, subrecipients may dispose of the personal non-expendable property. • Items with a current per unit fair market value of less than $5,000 may be retained, sold, or otherwise disposed of with no further obligation to DPS. • Items with a current per unit fair market value of $5,000 or more may be retained or sold, but DPS shall have a right to an amount calculated by multiplying the current market value or proceeds from the sale by DPS’ share of the equipment. • The seller is eligible for limited sale and handling costs of $500 or 10% of the proceeds, whichever is less. • Records for non-expendable property acquired with grant funds shall be retained for five (5) years after final disposition of property.

33. AUDIT REQUIREMENTS • Comply with OJP Financial Guide, Chapter 3.19, Audit Requirements in accordance with the provisions of Title 2 C.F.R. Subpart F (§ 200.500 et seq.) • Audit is required if the subrecipient expended $750,000 or more in federal funds within the organization’s fiscal year from any federal source (including, but not limited to, JAG) • If the subrecipient is not required to have an audit, the agency is still responsible for monitoring activities to provide reasonable assurance that the agency administers federal awards in compliance with federal requirements • If the subrecipient is required to have an audit: • The audit must be performed organization-wide by an independent firm • The audit must be conducted with reasonable frequency, usually annually, but not less frequently than every two (2) years • Doesn’t mean that the audit can include every other year though! • Must submit a copy of such audit to DPS via the “Correspondence” component of the grant within WebGrants, where possible • Can mail a copy to DPS if unable to scan the audit report • DPS will start contacting agencies if not submitted by 9/1/19

34. PRINTING AND PUBLICITY • Subrecipients are encouraged to make the results and accomplishments of their activities available to the public through printed publication or media release. • Award of funding • Major cases/investigations • Improvements in services • Educational training • All printed materials, however, must include an acknowledgement of the funding source similar to the following: Funding for this project made available by the Edward Byrne Memorial Justice Assistance Grant (JAG), which is administered by the U.S. Department of Justice, Bureau of Justice Assistance and the State of Missouri, Department of Public Safety.

35. CIVIL RIGHTS COMPLIANCE

36. STATE CIVIL RIGHTS LAWS • Section 213.055 RSMo – Unlawful Employment Practices • Subrecipients may not discriminate on the basis of race, color, religion, national origin, sex, ancestry, age, or disability in its employment practices (e.g. hiring, compensation, conditions, or privileges) • Section 213.065 RSMo – Discrimination in Public Accommodations • Subrecipients may not discriminate on the basis of race, color, religion, national origin, sex, ancestry, or disability in the use and enjoyment of any place of public accommodation • It is unlawful to refuse, withhold from, or deny any of the accommodations, advantages, facilities, services, or privileges made available in any place of public accommodations

37. FEDERAL CIVIL RIGHTS LAWS • Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d) • Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) • Title II of the Americans with Disabilities Act of 1990 (42 U.S.C. § § 12131-34) • Title IX of the Education Amendments of 1972 (20 U.S.C. § § 1681, 1683, and 1685-86) • Age Discrimination Act of 1975 (42 U.S.C. § § 6101-07) • U.S. Department of Justice Regulations – Non-Discrimination; Equal Employment Opportunity; Policies and Procedures (28 C.F.R. pt 42) • U.S. Department of Justice Regulations – Equal Treatment for Faith Based Organizations (28 C.F.R. pt 38) • U.S. Department of Justice Regulations – Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance (28 C.F.R. pt 54) • Executive Order 13279 (equal protection of the laws for faith-based and community organizations) • Executive Order 13559 (fundamental principles and policymaking criteria for partnerships with faith-based and other neighborhood organizations

38. EQUAL EMPLOYMENT OPPORTUNITY PLAN (EEOP) • A workforce report that some organizations must complete as a condition for receiving U.S. Department of Justice funding authorized by the Omnibus Crime Control and Safe Streets Act of 1968. • EEOPs are intended to ensure recipients (and subrecipients) of federal funding are providing equal employment opportunities to men and women regardless of sex, race, or national origin. • The U.S. Department of Justice regulations pertaining to the development of a comprehensive EEOP can be found at 28 C.F.R. § 42.301-42.308. • The U.S. Department of Justice, Office for Civil Rights (OCR) is the federal branch that collects, reviews, and approves EEOPs. • Effective in December 2016, the OCR developed an Equal Employment Opportunity (EEO) Reporting Tool to streamline the EEO reporting process. The deployment of the EEO Reporting Tool, however, changed the reporting requirements for recipients of funding from the U.S. Department of Justice.

39. OCR’s EEOP WEBPAGE Provides access to the “EEO Reporting Tool” portal https://ojp.gov/about/ocr/eeop.htm Provides access to the “EEO Reporting Tool Job Aid” Contact information for OCR if assistance is needed NOTE: The link to the “EEO Reporting Tool Job Aid” will assist in the completion of the EEO requirements.

40. EEO REPORTING DETERMINATION For calculating the total number of employees, include part-time and full-time workers but exclude seasonal employees, political appointees, and elected officials.

41. EEO CERTIFICATION FORM • The Certification Form’s purpose is to identify the EEO reporting requirement (or lack thereof) of recipients (and subrecipients) of funding from the U.S. Department of Justice. • Recipients (and subrecipients) exempt from the EEO reporting requirements must claim such exemption. • Effective with the “EEO Reporting Tool”, a “Certification of Exemption” form will populate and be submitted to OCR. The Form must be submitted each calendar year for which DOJ funding is received (and be updated in the event a new award is received within the same calendar year that changes the status to no longer being exempt from the EEO reporting requirement). • Recipients (and subrecipients) are required to prepare an EEO Plan must acknowledge such requirement. • Effective with the “EEO Reporting Tool”, a “Notice of Acknowledgement of Requirement” form will populate and be submitted to OCR. The Form must be submitted each calendar year for which DOJ funding is received. • The EEO Certification Form must be prepared for the recipient (or subrecipient) of the federal funding (i.e. county, city, or state department); the EEO Certification Form is not just for the project agency (i.e. Sheriff’s Office, Police Department, State Division).

42. EEO CERTIFICATION FORM cont’d • Navigate to the OCR EEOP webpage • Sign into the EEO Reporting Tool • The applicable EEO Certification Form will populate based on responses to the type of agency, number of employees, and single largest DOJ award • When completed, the EEO Certification Form must be e-signed by the designated official (the EEO Reporting Tool Job Aid provides instruction on how to designate this individual) • Once e-signed, the EEO Certification Form is then submitted electronically through the EEO Reporting Tool and a confirmation email will be received SAMPLE NOTE: Be sure to share this instruction with the applicable human resources individual within the organization to ensure the requirement is completed. It would be helpful if a copy of the EEO Certification Form and confirmation email are retained for future site visit monitoring.

43. EEO UTILIZATION REPORT • OCR developed the EEO Utilization Report to help recipients (and subrecipients) of funding from the U.S. Department of Justice to comply with the EEOP regulations. • Instead of requiring recipients (and subrecipients) to report all of the employment data that federal regulations require them to keep (see 28 C.F.R. § 42.301-42.308), OCR uses the EEO Utilization Report to prompt recipients (and subrecipients) to collect and analyze key employment data, organized by race, national origin, and sex. • The EEO Utilization Report is effective for a 2-year period, commencing with the date of approval of the EEO Utilization Report from the OCR. • During previous years, written approval seemed to only be received by larger metropolitan organizations (i.e. larger award dollars triggered thorough review). • If written approval is not received, the EEO Utilization Report is effective for a 2-year period from the date of submission of the EEO Utilization Report. • The EEO Utilization Report must be prepared for the recipient (or subrecipient) of the federal funding (i.e. county, city, or state department); the EEO Certification Form is not just for the project agency (i.e. Sheriff’s Office, Police Department, State Division). NOTE: The EEO Utilization Report is not the same as an EEO4. A EEO4 is required by the U.S. Equal Employment Opportunity Commission. The EEO Utilization Report is required by the U.S. Department of Justice.

44. EEO UTILIZATION REPORT cont’d • Navigate to the OCR EEOP webpage • Sign into the EEO Reporting Tool • Complete the EEO Utilization Report with the requested data • When completed, the EEO Utilization Report must be e-signed by the designated official (the EEO Reporting Tool Job Aid provides instruction on how to designate this individual) • Once e-signed, the EEO Utilization Report is then submitted electronically through the EEO Reporting Tool SAMPLE COVER SHEET NOTE: the date-stamp on the cover sheet indicates the print date (not the preparation date) NOTE: Be sure to share this instruction with the applicable human resources individual within the organization to ensure the requirement is completed. It would be helpful if a copy of the EEO Utilization Report and approval notice (if received) are retained for future site visit monitoring.

45. NON-DISCRIMINATION • Subrecipients may not discriminate on the basis of race, color, national origin, religion, sex, or disability in its employment practices or in the delivery of services • If the subrecipient has 50 or more employees and receives OJP, OVW, or COPS funding of $25,000 or more: • the subrecipient must have written policies or procedures in place to notify program participants and employees on how to file complaints alleging discrimination • the subrecipient must designate a person(s) to coordinate complaints alleging discrimination

46. FINDINGS OF DISCRIMINATION • Subrecipients must notify DPS of any findings of discrimination within 30 days of the court judgment • Submit the Court Judgment with a cover letter to DPS; the cover letter should identify the DPS-assigned subaward number, as indicated on the Subaward document • DPS must forward to the Office for Civil Rights (OCR) Missouri Department of Public Safety Attn: Director of Public Safety PO Box 749 1101 Riverside Drive Jefferson City, MO 65102

47. LIMITED ENGLISH PROFICIENCY (LEP) • Subrecipients must take steps to provide meaningful access to its programs and activities to persons with LEP • Oral Interpretation • Written Interpretation • It is recommended that subrecipients develop a written policy on providing language access services to LEP persons • For more information on LEP, planning tools, or sample policies, go to https://ojp.gov/about/ocr/lep.htm

48. REPORTING REQUIREMENTS

49. REPORTING REQUIREMENT #1 – CLAIMS • Reminder emails will be sent by DPS staff from WebGrants approximately 1-2 weeks prior to the deadline • Subrecipients must report actual expenditures and request reimbursement • Requests for reimbursement are submitted via the “Claims” component of WebGrants • Funds must be obligated no later than June 30, 2020 • Funds should be expended no later than August 31, 2020 • Subrecipients can claim an amount over the total budgeted line item • Allowed up to a 10% increase in a single budget line without a budget revision • Not receiving additional monies but rather “borrowing” it from elsewhere in the budget • Increases in excess of 10% within a particular budget line require a budget revision through the “Subaward Adjustment” component of WebGrants • Exceeding the 10% increase will be subject to review by DPS • Nominal increases over the 10% allowance may be allowable without a budget revision; should consult with DPS Internal Contact • Claims will be reviewed, negotiated, and approved by the designated Internal Contact (if revisions are made by DPS, comments will be added to Feedback) • Payments are made around the 25th of each month via EFT • Vendor Services Portal: https://www.vendorservices.mo.gov/vendorservices/Portal/Default.aspx • JAG Prefix Payment Code = PG029

50. CLAIMS COMPONENTS There are 5 components (forms) to the Claim : • General Information: used to identify the reporting period and the type of report • Detail of Expenditure: used to identify the pay date, check number, payee, description, total cost, percent of funding requested, and amount claimed to grant for reimbursement per cost activity • Reimbursement: used to identify the Expenses This Period (Federal Share) per budget line; the totals are aggregate totals from the ‘Detail of Expenditure’ form • Program Income: used to identify any monies earned and/or expended as a result of the grant-funded project • Attachments: used to upload copies of documentation to support the expenditures