State Cyber Crime Grant (SCCG) 2014 Compliance Webinar Missouri Department of Public Safety November 26, 2013
MO DEPARTMENT OF PUBLIC SAFETYCRIMINAL JUSTICE/LAW ENFORCEMENT UNITCONTACT INFORMATION Eric Shepherd, Program Manager (573) 751-5997 firstname.lastname@example.org Heather Haslag, Assistant Program Manager (573) 751-1318 email@example.com Sarah Verhoff, Program Representative (573) 526-1928 firstname.lastname@example.org Ashley Virgin, Program Representative (573) 522-3455 email@example.com • Main Phone: (573) 751-4905 • Fax Number1: (573) 522-1908 • Fax Number2: (573) 751-5399 • MO Department of Public Safety • Attn: CJ/LE • PO Box 749 • 301 W. High Street, Room 870 • Jefferson City, MO 65102
2014 SCCG POINT-OF-CONTACT“INTERNAL CONTACT” Unless noted otherwise, all grant reports and correspondence will be reviewed and processed by your designated Internal Contact. All questions and concerns should be directed to your Internal Contact as well! Monitoring will be conducted by the Internal Contact.
OUTLINE FOR TODAY • General Grant Information • Budget Costs • Administrative & Financial Guidelines • Civil Rights Compliance • Reporting Requirements • Monitoring • WebGrants • Questions?
BACKGROUND State Cyber Crime Grant (SCCG) • Supports the continued operation of multi-jurisdictional law enforcement cyber crime task forces. • Prior to SCCG, the cyber crime task forces were funded with state Internet Cyber Crime Grant (ICCG) monies until May 2009 and then with federal Multi-Jurisdictional Cyber Crime Grant (MJCCG) monies until February 2013. • The overall purpose of the SCCG program retains the same mission, which is to support a broad range of activities to prevent and control internet crime as it relates to children.
GENERAL GRANT GUIDELINES • Contract Period: June 1, 2013 to May 31, 2014 • No local match requirement • Eligible budget categories: • Personnel • Personnel Benefits • Personnel Overtime • Personnel Overtime Benefits • Travel/Training • Equipment • Supplies/Operations • Contractual
SOURCE OF INFORMATION • DPS Website: www.dps.mo.gov • Solicitation • Financial & Administrative Guidelines • Travel Policy • WebGrants: https://dpswebgrants.dps.mo.gov • Opportunity (Funding Opportunity) • Solicitation • Certified Assurances • Missouri State Statutes: http://www.moga.mo.gov/
PERSONNEL COSTS • Personnel costs must be supported with official payroll records and time/attendance reports. • DPS will not accept “cover letters” to solely support expenses from member agencies • Agency should obtain documents to support all fringe benefits claimed for reimbursement and maintain such documents in the grant files • Time/attendance records should document all paid hours (including leave, overtime, etc) and should ideally be signed by the employee and authorizing supervisor • If personnel costs (i.e. overtime) are paid from multiple funding sources, be sure to report 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 Form I-9, Employment Eligibility Verification • http://www.uscis.gov/portal/site/uscis
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. 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!
TRAVEL/TRAINING COSTS cont’d • Airfare/Baggage • 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 • Rental Car • reimbursable for the cost of the rental car • Fuel • reimbursable for the fuel for a rental car and/or fuel for a vehicle to and from the airport or training location
TRAVEL/TRAINING COSTS cont’d • Mileage • reimbursable based on the state’s mileage allowance • reimbursement may not exceed state mileage allowance • http://content.oa.mo.gov/travel-portal • rate based on cost to operate the vehicle based on fuel and wear and tear (cannot request fuel and mileage reimbursement) • Lodging • reimbursable based on the federal GSA rates as determined for the destination • reimbursement must adhere closely to the federal GSA rate • http://www.gsa.gov/portal/category/21287 • 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 state funded • does not allow for hotel parking, room service, internet, telephone calls, maid tips, etc.
TRAVEL/TRAINING COSTS cont’d • Meals • reimbursable based on the most restrictive travel policy – local or state • 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) • State travel policy states individuals may claim the applicable per diem rate for each eligible meal while in travel status. • Travel status begins when you leave your residence or domicile to travel on business. • Travel status ends when you return to your residence or domicile. • You are not in travel status if any part of your trip involves a commute. When your official domicile and residence are different, the travel status begins and ends based on whichever is less. • When overnight lodging is not needed, it must be documented that the individual was in travel status for 12 or more hours. • State travel policy states when attending a meeting or conference, an individual may claim the applicable meal per diem for those meal times where such meal is not provided by the training host. • http://content.oa.mo.gov/travel-portal • receipts are no longer required (unless required by your local travel policy); still need to maintain record of meals being requested for audit/monitoring purposes
EQUIPMENT COSTS • Equipment is generally defined as a non-expendable personal property having a useful life of more than one year an acquisition cost of $1,000 or more per unit • Must adhere to most restrictive procurement policy • Costs must be directly attributable to the approved project • Equipment must be tagged and identifiable for its source of funds (where feasible) • “Purchased with 2014 SCCG Funds” • “2014 SCCG Grant” • Must maintain an inventory control listing • Item Description • Source of Property (2014 SCCG) • Manufacturer’s Serial Number and/or Model Number • Acquisition Date • Total Cost & State-Funded Cost • Location, Use, and Condition of Property • Disposition Date • Disposition Method (e.g. trash, sale, trade)
SUPPLIES/OPERATIONS COSTS • Includes expendable property and operating costs • Costs must be directly attributable to the approved project • Must adhere to most restrictive procurement policy • Printed materials must acknowledge the funding source
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 • Copy of all written contracts must be made available to DPS staff • Must adhere to most restrictive procurement policy • Agencies should attempt to enter into contracts that occur within the grant’s contract period, where possible
PROJECT IMPLEMENTATION STATUS • If a project is not operational within 60 days of the contract start date, the Contractor must report to DPS, via the “Correspondence” component of WebGrants, the steps taken to initiate the project, the reasons for delay, and the expected start date. • If a project is not operational within 90 days of the contract start date, the Contractor must submit a second statement to DPS, via the “Correspondence” component of WebGrants, explaining the implementation delay. • Upon receipt of the second statement, DPS may decide whether to continue with the project or to terminate the contract.
FUNDS • Contractors must verify, on a monthly basis, actual cash expenditures and request reimbursement • Request for reimbursement will be handled via a “Claim” report • Funds must be obligated within the contract period and expended within 10 days following the contract period end date • 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 contract period • Funds are expended when payment is made.
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 • Prior approval from DPS required for sole source procurement of $3,000 and more • Request for approval shall be submitted via the “Correspondence” component of WebGrants with the rationale and a copy of the sole source certification letter from the vendor, if available • Approval of the grant application does not constitute prior approval; must obtain separately State Procurement Policy: • Items costing less than $3,000 may be purchased with prudence on the open market • Items costing between $3,000 but less than $25,000 must be competitively bid, but need not be solicited by mail or advertisement • Items costing $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 NOTE: The above thresholds are based on the total amount due to the vendor, not just the unit cost.
CONTRACT RECORDS • Establish and maintain accurate financial records and an adequate accounting system • Records must be retained for a period of 5 years starting from the date of submission of the final Claim Report or from the date of submission of the audit for the contract period covered, whichever comes later. • Records must be retained beyond a 5 year period if an audit is in progress and/or the findings of a completed audit have not been resolved. • Must adhere to local policy if local retention period is longer than those stated herein. • Financial records must be kept in an orderly manner and be available for audit purposes • Responsible for protecting records against fire, theft, or other possible damages.
PROPERTY RECORDS & DISPOSITION • Required to maintain property management records • Records shall contain copies of the purchase order and invoice • 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. • Adequate maintenance procedures shall be established to keep the property in good condition. • May dispose of the personal non-expendable property when original or replacement equipment acquired under an award is no longer needed for the original project • 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 in excess of $5,000 may be retained or sold but the 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 • Records for non-expendable property acquired with grant funds shall be retained for 5 years after final disposition of property.
AUDIT REQUIREMENTS • Audit is required if the agency expends $250,000 or more in state funds within the organization’s fiscal year from any state source • Audit must be performed organization-wide by an independent firm • Audit must be conducted with reasonable frequency, usually annually, but not less frequently than every two 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 WebGrants, where possible • Can mail a copy to DPS if unable to scan the audit report
INTERNAL CONTROLS • Agency 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 • Agency should ensure appropriate internal controls exist for the programmatic and financial aspects of the project
PRINTING AND PUBLICITY • BJA and DPS encourage recipients of state funding to share success stories of their project • Award of funding • Major cases/investigations • Improvements in services • Educational training • Agencies are required to disclose of the source of their funding with language such as: This project was supported by funding made available through the State Cyber Crime Grantadministered by the Missouri Department of Public Safety.
STATE CIVIL RIGHTS LAWS • Section 213.055 RSMo– Unlawful Employment Practices • Contractor 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 • Contractor 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
REPORTING REQUIREMENT #1 - CLAIM • Must report actual expenditures for reimbursement • Submitted via the “Claims” component of WebGrants • Funds must be obligated no later than May 31, 2014 • Funds must be expended no later than June 10, 2014 • 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 • Exceeding the 10% increase will be subject to review by DPS • 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 “Contract Adjustment” component of WebGrants • Will be reviewed, negotiated, and approved by your designated Internal Contact • Payments made around the 25th of each month via EFT • State Vendor Portal: https://vendorservices.mo.gov • SCCG Prefix Payment Code = PG087
CLAIM REPORT NOTES • Manmade “invoices” will not be accepted in place of official documentation for expenditures • Official company documents must be provided to verify costs • Can submit supporting documentation with Claim report or can make available for monitoring during site visit • Reimbursement is only allowed for employer costs • Watch your payroll and billing periods • Costs must be pro-rated by the total number of days in the billing or payroll period • Familiarize yourself with the billings • Pre-tax deductions reduce the amount of Social Security and Medicare withholdings for the employee and employer • Help DPS in identifying which codes or lines are pre-tax deductions! • Insurance premiums are often paid the month prior to the coverage period • Help DPS in identifying the period for which the insurance is being paid • Unemployment Comp is typically paid on the first $13,000 of wages for the calendar year OR not paid at all until a claim is filed by the former employee • Workers Comp is not based on a straight job classification rate • DPS can send a Workers Comp calculator spreadsheet to your agency, if requested
SCCG CLAIM REPORT SCHEDULE *Due dates have been adjusted due to the late start of contracts
REPORTING REQUIREMENT #2 – STATUS REPORTS • Recipients must report activities, successes, obstacles, and statistical information • Compiled for publications and state reporting purposes • Reminder alerts will be sent from WebGrants approximately 2 weeks prior to the deadline • Reports must be submitted via the “Status Reports” component of WebGrants • Will be reviewed, negotiated, and approved by Sarah Verhoff (despite grant point-of-contact)
SCCG STATUS REPORT SCHEDULE * Due date has been adjusted due to the late start of contracts
MONITORING • CJ/LE will conduct monitoring of the project to ensure compliance with state laws, regulations, and guidelines • Desk Monitoring – tracking telephone and email communication, as well as reviewing all grant documents, reports, and correspondence • Site Monitoring – a visit the agency’s office(s) to review policies, payroll records & receipts, and other documents • CJ/LE will take appropriate action if determined the Contractor is acting inappropriately, misusing money, and/or not meeting reporting requirements • Such action may result in delay of reimbursement of funds and/or cancellation of the contract
MONITORING CHECKLIST - FISCAL • Personnel • official payroll records to support salary and fringe benefits • time and attendance records • Travel/Training • receipts and travel vouchers • Equipment • Invoices/receipts from vendor (submitted with claim report) • bid records and/or sole source letters, where applicable • Supplies/Operations • receipts/invoices • bid records and/or sole source letters, where applicable • Conctractual • receipts/invoices • bid records and/or sole source letters, where applicable • contractual agreements, where applicable
MONITORING CHECKLIST - PROGRAMMATIC • Personnel records for grant-funded staff • Training plan for grant-funded staff • Personnel manual; standard operating procedures • Local travel policy • Local procurement/purchasing policy • Inventory control listing for equipment • Tags/labels on equipment • Internal controls
MONITORING CHECKLIST – STATE STATUTES If the project agency is a law enforcement agency: • Section 43.505 RSMo - Monthly Uniform Crime Reporting (UCRs) • Section 590.650 RSMo - Annual Racial Profiling Reporting • Section 513.653 RSMo - Annual Federal Forfeiture Report • Section 590.700 RSMo - Recording of Custodial Interrogations • Section 577.005 RSMo - Forwarding Intoxication-Related Offenses
MONITORING CHECKLIST – STATE CIVIL RIGHTS • Section 213.055 RSMo – Unlawful Employment Practices For example: • Does your organization’s job announcements/applications include an “Equal Opportunity Employer” statement? • Does your organization display the required labor law posters? • Does your organization maintain a written policy on non-discrimination and/or non-harassment in the workplace? • Does your organization maintain a written policy to notify employees on how to file complaints alleging discrimination? • Section 213.065 RSMo – Discrimination in Public Accommodations For example: • Does your organization display the required labor law posters (e.g. Discrimination in Housing and Discrimination in Accommodations)? • Does your organization notify its citizens or program participants that it will not discriminate in the delivery of its services (e.g. brochures, posters, website, mission statement)? • Does your organization ensure its facilities are ADA accessible? • Does your organization maintain a written policy on ADA? • Does your organization maintain a written policy to notify employees and/or citizens on how to file complaints alleging discrimination in public accommodations?
WEBGRANTS HOME SCREEN Returning Users or Organizations: enter UserID and Password For New Organizations only!
WEBGRANTS - MAIN MENU • Grantee Instructions: general instructions and navigational aids • My Profile: maintain contact information, reset password, & add users • Funding Opportunities: displays posted program funding opportunities • My Applications: displays previously created applications for the user’s organization • My Grants: displays awarded grants for a user’s organization
‘MY PROFILE’ MODULE • Maintain profile and contact information • Maintain organization’s information • Do not change the Applicant Agency name though • Add additional registered users • Add only if individual is not already a registered user • Notify DPS to add if individual is already a user associated with a different grant • Notify DPS via the “Correspondence” component of WebGrants if you add a new individual; must use the Change of Information Form • Remove registered users • Notify DPS via the “Correspondence” component of WebGrants if you need an individual removed; must use the Change of Information Form • Do not delete a registered user yourself; the individual is not automatically removed from the General Information form as a grantee contact or from the Distribution List
CLARIFICATION OF ALERTS & NOTIFICATIONS • Two types of notifications: • Automated alerts triggered on application and grant phases (e.g. status change, submission, negotiation, approval, not approved) • Mass distribution list emails from DPS staff (e.g. reminders, updates, training notices) • Alerts/Notifications are sent from firstname.lastname@example.org • Add to safe sender list or a contact list to avoid being treated as junk/spam • Do not overlook these alerts as they can contain important and time-sensitive information • While the record is in the “My Applications” module, only the Primary Contact receives system-generated alerts • While the record is in the “My Grants” module, the Primary Contact and Additional Grantee Contacts, as applicable, receive system-generated alerts
STATUS OVERVIEW My Applications: • Submitted – application has been submitted by the grantee • Under Review – application has been assigned for review • Correcting – application is being edited by the grantee • Approved – application has been approved, following any necessary revisions by the grantee • Awarded – award of contract documents being signed by grantee and grantor My Applications – Archived Applications: • Editing – application was initiated but never submitted prior to the close of the funding opportunity • Withdrawn – application has been withdrawn from consideration by the grantee (or grantor per request by the grantee) My Grants: • Underway – application officially becomes a grant • Suspended – grant has been “frozen” due to delinquent reporting and/or inappropriate activities My Grants – Closed Grants: • Closed – grant has been closed by grantor
SCCG GRANT COMPONENTS General Information Contact Information Budget Claims Correspondence Contract Adjustments Contract Adjustment Notices Status Reports Site Visits Award Documents – Need Signatures Award Documents - Final Attachments Closeout Opportunity Application
GENERAL INFORMATION • Contains information relating to your contract • Identifies your Primary Grantee Contact and Additional Contacts • Identifies your DPS Internal Contact (a.k.a. Additional Internal Contacts) If someone is a registered user with your organization but is not listed here, contact DPS via the “Correspondence” component! They are not receiving alerts! Check this form now…and after any change of informations!!